To amend section 842 of the Internal Revenue Code of 1986 to require the use of same year tax return data in calculating minimum effectively connected net investment income and to provide for a carryover account.

Amends the Internal Revenue Code with respect to foreign companies carrying on insurance business in the United States. Requires the use of domestic company tax return data from the same taxable year as the year for which minimum effectively connected net investment income calculations are made. Requires the use of a carryover account for year-to-year income comparisons.