52, or subsection (m) or (o) of section 414, shall be treated as one person. All eligible employer plans shall be treated as one eligible employer plan. (2) Disallowance of deduction No deduction shall be allowed for that portion of the qualified startup costs paid or incurred for the taxable year which is equal to the credit determined under subsection (a). (3) Deduction for matching contribution For deductions for qualified matching contributions, see section 162. (4) Election not to claim credit This section shall not apply to a taxpayer for any taxable year if such taxpayer elects to have this section not apply for such taxable year. . (b) Conforming amendments (1) In general Subsection (b) of section 38 is amended by striking plus at the end of paragraph (35), by striking the period at the end of paragraph (36) and inserting , plus , and by adding at the end the following new paragraph: (37) the student loan program startup costs credit determined under section 45S(a). . (2) Deduction for Unused Credit Subsection (c) of section 196 is amended by striking and at the end of paragraph (13), by striking the period at the end of paragraph (14) and inserting , and , and by adding at the end the following new paragraph: (15) the student loan program startup costs credit determined under section 45S(a). . (c) Clerical Amendment The table of sections for subpart D of part IV of subchapter A of chapter 1 is amended by adding at the end the following new item: Sec. 45S. Student loan program startup costs credit. . (d) Effective date The amendments made by this section shall apply to taxable years beginning after the date of the enactment of this Act.