under this paragraph, the Secretary shall give priority to taxpayers that have qualified programs which serve either urban or rural underserved areas (determined on the basis of the most recent United States census data available). (c) Limitations relating to expenditures (1) Direct activity Twenty-five percent of the amount allowed as a credit under subsection (a) shall be for amounts paid or incurred for direct activities as defined in section 5533(b)(1) of the Elementary and Secondary Education Act of 1965 ( 20 U.S.C. 7267b(b)(1) )(as in effect on the day before the date of enactment of the Every Student Succeeds Act). (2) Subgrants Seventy-five percent of the amount allowed as a credit under subsection (a) shall be for amounts paid or incurred for subgrants (as defined in section 5533(b)(2) of the Elementary and Secondary Education Act of 1965 ( 20 U.S.C. 7267b(b)(1) ), as in effect on the day before the date of enactment of the Every Student Succeeds Act), determined by treating amounts so paid or incurred as funds made available through a grant. (d) Definitions and special rules For purposes of this section— (1) Qualified program The term qualified program means a program in writing under which an eligible for profit organization awards one or more grants for the purpose of carrying out the objectives of promoting economic and financial literacy, as specified in section 5532 of the Elementary and Secondary Education Act of 1965 ( 20 U.S.C. 7267a ), that meet the requirements of section 5533 of the Elementary and Secondary Education Act of 1965 ( 20 U.S.C. 7267b ), as such sections are in effect on the day before the date of enactment of the Every Student Succeeds Act. (2) Eligible for profit organization The term eligible for profit organization means with respect to a taxable year, an organization that— (A) has a qualified program in effect for the taxable year, and (B) has been determined by the Secretary under subsection (b)(2) to be an organization to whom the credit is allowed for the taxable year.