(or equivalent thereof) not less than an amount equal to 218 percent of the Federal poverty level for an individual for the calendar year in which the taxable year begins divided by 1,750, (II) meets the retirement plan requirements of subsection (c) with respect to at least 90 percent of its employees providing services during the taxable year who are not highly compensated employees, and (III) meets the additional requirements of subparagraphs (A) and (B) of paragraph (2), or (ii) any other taxpayer, which meets the requirements of either subclause (I) or (II) of clause (i) for the taxable year. (2) Additional requirements for large employers (A) United States employment The requirements of this subparagraph are met for any taxable year if— (i) in any case in which the taxpayer increases the number of employees performing substantially all of their services for the taxable year outside the United States, the taxpayer either— (I) increases the number of employees performing substantially all of their services inside the United States by an amount not less than the increase in such number for employees outside the United States, or (II) has a percentage increase in such employees inside the United States which is not less than the percentage increase in such employees outside the United States, (ii) in any case in which the taxpayer decreases the number of employees performing substantially all of their services for the taxable year inside the United States, the taxpayer either— (I) decreases the number of employees performing substantially all of their services outside the United States by an amount not less than the decrease in such number for employees inside the United States, or (II) has a percentage decrease in employees outside the United States which is not less than the percentage decrease in such employees inside the United States, and (iii) there is not a decrease in the number of employees performing substantially all of their services for the taxable year inside the United States by reason of the