The amount included under section
810
(a) or
832
(c)(10) (as the case may be) by reason of the application of subsection (a) shall not exceed the amount that would have constituted the loss carryover under such section if for all relevant taxable years the company had been subject to the tax imposed by the part referred to in subsection (a)(1) rather than the part referred to in subsection (a)(2). For purposes of applying the preceding sentence, section
810
(b)(1)(C) (relating to additional years to which losses may be carried by new life insurance companies) shall not apply.