§ 9106. Exemptions from taxation. The following shall be exempt from
the payment of any taxes imposed under the provisions of this article:

(a) the government of the United States, or of any state or
municipality thereof, or any instrumentality of any such government
which is not subject to taxation by this state;

(b) the persons, firms, associations or corporations which are
exempted from the requirement that they obtain a license to do business
in this state, under the provisions of section one thousand one hundred
eight of this chapter;

(c) any foreign or alien fraternal benefit society; and

(d) any corporation otherwise subject to the provisions of this
article which as a health maintenance organization offers a
comprehensive health services plan pursuant to the provisions of article
forty-four of the public health law to subscribers. Such exemption shall
be limited to that income derived from subscriber prepayments to such
plan.