; limitations applicable to dividends received from catastrophic risk transfer company. Sec. 860P. Dividends paid by catastrophic risk transfer company after close of taxable year. 860M. Catastrophic risk transfer companies (a) General rule For purposes of this subtitle, the term catastrophic risk transfer company means any domestic corporation which— (1) is— (A) created or organized under the laws of a State which has enacted a State law which enables the organization and licensure of a special purpose insurer (whether or not designated as such under such State law) which is capable of carrying out the activities described in paragraph (2), and (B) regulated and licensed as such a special purpose insurer by the State commissioner of insurance or other State official charged with regulation of insurance within the State, (2) the principal purpose of which is the carrying out of the activities of catastrophic risk transfer, but only if— (A) substantially all of such activities relate to business other than general annuity business, and (B) such activities are limited to— (i) issuing equity and debt securities, (ii) owning qualified investments, and (iii) entering into one or more insurance or reinsurance agreements covering catastrophic risks from persons who are not related to such corporation at any time during the period beginning with the date such agreements are entered into and ending with the last day of the period such agreements are in effect, and (3) is authorized by the State commissioner of insurance or other State official charged with regulation of insurance within the State to carry out the activities of catastrophic risk transfer. (b) Limitations A corporation shall not be considered a catastrophic risk transfer company for any taxable year 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