1. National Association of Insurance Commissioners (NAIC). Accounting Practices and Procedures Manual. Vol. III, Statement of Statutory Accounting Principles No. 101—Income Taxes, Paragraph 10.
Quote: "An admissibility test shall be applied to the gross DTAs... The amount of DTA that is admitted shall be the amount that is expected to be realized... Realization is dependent on the existence of sufficient taxable income of the appropriate character within the carryback or carryforward periods." This directly states that the test is applied to the Gross DTAs.
2. Society of Actuaries (SOA). Exam 7 Study Note: Introduction to Statutory Financial Reporting in the United States. Spring 2021, Section 3.3.2, p. 11.
Reference: This educational material from a professional actuarial body explains the SSAP 101 admissibility test, stating, "The amount of gross DTA that can be admitted as an asset is limited based on a three-tiered test." This confirms that the Gross DTA is the subject of the limitation test.