; and (2) by inserting after subsection (b) the following: (c) Special rule for certain motor vehicle manufacturers (1) In general The amount determined under subsection (a)(1)(B) shall be zero for any taxable year of a domestic corporation described in paragraph (2) if the number of full-time employees of such corporation performing substantially all of their services inside the United States during such taxable year is less than the number of such employees on December 20, 2017. (2) Domestic corporation described A domestic corporation is described in this paragraph with respect to any taxable year if such domestic corporation— (A) is a manufacturer (within the meaning of section 30B) of motor vehicles (as defined in section 30B(h)(1)), and (B) is a United States shareholder of a controlled foreign corporation which increases the number of full-time employees of such controlled foreign corporation during period comprising of the taxable year of such domestic corporation. . (b) Effective date The amendments made by this section shall apply to taxable years beginning after the date of enactment of this Act.