to the comparable amount (determined without regard to this subparagraph) as such portion bears to the entire calendar year. (3) Comparable participating employees (A) In general For purposes of paragraph (1), the term comparable participating employees means all employees— (i) who are eligible individuals covered under any high deductible health plan of the employer, and (ii) who have the same category of coverage. (B) Categories of coverage For purposes of subparagraph (B), the categories of coverage are self-only and family coverage. (4) Part-time employees (A) In general Paragraph (3) shall be applied separately with respect to part-time employees and other employees. (B) Part-time employee For purposes of subparagraph (A), the term part-time employee means any employee who is customarily employed for fewer than 30 hours per week. (5) Special rule for non-highly compensated employees For purposes of applying this section to a contribution to a health savings account of an employee who is not a highly compensated employee (as defined in section 414(q)), highly compensated employees shall not be treated as comparable participating employees. (e) Controlled groups For purposes of this section, all persons treated as a single employer under subsection (b), (c), (m), or (o) of section 414 shall be treated as 1 employer. (f) Definitions Terms used in this section which are also used in section 223 have the respective meanings given such terms in section 223. (g) Regulations The Secretary shall issue regulations to carry out the purposes of this section. . (11) Section 6051(a) is amended by striking paragraph (11). (12) Section 6051(a)(14)(A) is amended by striking paragraphs (11) and (12) and inserting paragraph (12) . (d) Effective date The amendment made by this section shall apply to taxable years beginning after December 31, 2017. 1312. Denial of deduction for expenses attributable to the trade or business of being an employee (a) In general Part IX of subchapter B of chapter 1 is amended by inserting after