To amend the Internal Revenue Code of 1986 to require foreign insurance companies to use same year tax return data in calculating minimum effectively connected net investment income, to provide for a carryover account, and to allow an election to use an individualized company yield.

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. Allows a foreign company to elect to use the individualized company yield method for determining such company's minimum effectively connected net investment income. Bases such method on United States dollar-denominated assets.