(a) General rule For purposes of section 38, in the case of an eligible business, the manufacturing facility expenditure credit for any taxable year is an amount equal to 25 percent of the qualified facility construction expenditures of the taxpayer for the taxable year. (b) Eligible business For purposes of this section— (1) In general The term eligible business means any corporation or partnership— (A) which is engaged in an active trade or business, (B) which is headquartered in the United States, (C) substantially all of the management or administrative activities of which are performed in the United States, (D) which has not (prior to placing into service the manufacturing facility designated for purposes of this section) placed in service a manufacturing facility, (E) which is a start-up company, and (F) with respect to which all debt obligations issued by, and equity interests in, have a rating of B minus (or its substantial equivalent) or higher from a credit rating agency registered with the Securities and Exchange Commission as a nationally recognized statistical rating organization (as defined in section 3(a) of the Securities Exchange Act of 1934). (2) Start-up company The term start-up company means any corporation or partnership— (A) which first has both gross receipts and qualified research expenses (as defined in section 41(b)) in a taxable year beginning after December 31, 2016, or (B) which both gross receipts and qualified research expenses (as so defined) in fewer than 3 taxable years beginning after December 31, 2016, and before January 1, 2022. (c) Qualified facility construction expenditures For purposes of this section— (1) In general The term qualified facility construction expenditures means amounts paid or incurred by the taxpayer— (A) for the construction of a facility (designated for purposes of this section by the taxpayer at such time and in such form and manner as the Secretary shall prescribe) in the United States to manufacture a qualified product (including amounts for