aliens working outside the United States). (e) Definitions and special rules For purposes of this section— (1) Wages The term wages has the meaning given such term by section 3121(a) (determined without regard to any dollar limitation contained in such section). (2) Allocation of tax The Secretary shall prescribe such rules as necessary for the allocation of the tax imposed by subsection (a) among different entities treated as a single employer under subsection (b)(1)(C). . (b) Conforming amendment The table of chapters of the Internal Revenue Code of 1986 is amended by inserting after the item relating to chapter 36 the following new item: Chapter 37—Corporate responsibility tax . (c) Effective date The amendments made by this section shall apply to calendar years beginning after the date of the enactment of this Act.