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in computing the income from a business other than an active business for a taxation year of a foreign affiliate of a taxpayer
in computing the income from a business other than an active business for a taxation year of a foreign affiliate of a taxpayer
in computing the income from a business other than an active business for a taxation year of a foreign affiliate of a taxpayer
in computing the income from a business other than an active business for a taxation year of a foreign affiliate of a taxpayer there shall be included the income of the affiliate for the year from the insurance of a risk (which, for the purposes of this paragraph, includes income of the affiliate for the year from the reinsurance of a risk) where the risk was in respect of