1. Internal Revenue Code, 26 U.S.C. § 816(a). This is the primary legal source defining a life insurance company for tax purposes. Section 816(a) explicitly states the "more than 50 percent" rule for the reserve test.
2. Pike, A. D. (2023). Federal Income Taxation of Life Insurance Companies. American Bar Association. Chapter 2, Section II.A, "The 'More Than 50 Percent' Reserve Test." This treatise details the application of IRC § 816(a).
3. KPMG. (2023). Taxation of Insurance Companies - United States. Section 3.2, "Definition of a life insurance company." This publication, often used in advanced accounting and tax courses, explains that "a company is a life insurance company for US federal income tax purposes if its life insurance reserves... comprise more than 50% of its total reserves."
4. PricewaterhouseCoopers (PwC). (2022). U.S. Taxation of Insurance Companies. Chapter 2, "Life Insurance Company Taxation," pp. 10-12. This guide, used as a reference in professional and academic settings, confirms the "more than 50 percent of total reserves" test under IRC Sec. 816.