unless— (1) it files with its return for the taxable year an election to be a catastrophic risk transfer company or has made such election for a previous taxable year, (2) at least 90 percent of its gross income is derived from— (A) investment income from qualified investments, and (B) (i) reinsurance premiums received from a regulated insurance company, or (ii) insurance premiums from— (I) a governmental agency, (II) a company the assets of which exceed $100,000,000, or (III) a company that is transferring a sufficiently large pool of a single type of underlying risk that the insurance of such pool of risk would on a stand-alone basis constitute operation of an insurance business under part II of subchapter L, and (3) the limit of the insurance or reinsurance being provided is fully collateralized. (c) Special rule for series issuances If a catastrophic risk transfer company (within the meaning of subsection (a)), or a protected cell of such company, issues a series or class of securities which primarily has recourse to, or is primarily linked to, a designated reinsurance agreement and pool of collateral or assets, such series or class shall be treated as a separate corporation for purposes of this title (other than determining whether the requirements of subsection (a) are met). (d) Failure To satisfy gross income test (1) Disclosure requirement A catastrophic risk transfer company which fails to meet the requirement of paragraph (2) of subsection (b) for any taxable year shall nevertheless be considered to have satisfied the requirement of such paragraph for such taxable year if— (A) following the catastrophic risk transfer company identification of the failure to meet such requirement for such taxable year, a description of each item of its gross income described in such paragraph is set forth in a schedule for such taxable year filed in the manner provided by the Secretary, and (B) the failure to meet such requirement is due to reasonable cause and not due to willful neglect. (2) Imposition of tax on