section. (e) Election This section shall apply to a taxpayer for a taxable year only if such taxpayer elects to have this section apply for such taxable year. . (2) Conforming amendments Section 38(b) of such Code, as amended by this Act, is amended by striking plus at the end of paragraph (37), by striking the period and inserting , plus at the end of paragraph (38), and by adding at the end of the following new paragraph: (39) the education scholarship credit determined under section 45U(a). . (3) Clerical amendment The table of sections for subpart D of part IV of subchapter A of chapter 1 of such Code, as amended by this Act, is amended by adding at the end the following new item: Sec. 45U. Contributions to scholarship granting organizations. . (c) Excise tax on failure of scholarship granting organizations To make distributions (1) In general Chapter 42 of such Code is amended by adding at the end the following new subchapter: I Organizations Providing Workforce Development, Apprenticeship Training, or Scholarships Sec. 4969. Tax on failure to distribute receipts. 4969. Tax on failure to distribute receipts (a) Tax imposed There is hereby imposed a tax on the failure of a workforce development or apprenticeship training organization (as defined in section 25E) or a scholarship granting organization (as defined in section 25F) to make distributions in any taxable year in an amount equal to or in excess of the required distribution amount before the distribution deadline relating to a taxable year. (b) Amount of tax The tax imposed by subsection (a) with respect to a taxable year shall be equal to 15 percent of the greater of— (1) the required distribution amount with respect to the taxable year, or (2) the amount of receipts of the qualified scholarship granting organization for each taxable year which are distributed before the distribution deadline with respect to such receipts. (c) Definitions For purposes of this section— (1) Required distribution amount (A) In general The required distribution amount