for which the employer could adopt such an arrangement and subsequently adopts an eligible employer plan for its employees for any of those years which it maintains for such third taxable year, then section 45E(b)(1) shall be applied with respect to the eligible employer by replacing 2 taxable years with 3 taxable years . (c) Eligible employer For purposes of this section, the term eligible employer means, with respect to any calendar year in which the taxable year begins, an employer which— (1) maintains an automatic IRA arrangement meeting the requirements of section 408B, (2) on each day during the preceding calendar year, had no more than 100 employees, and (3) did not maintain a qualifying plan or arrangement (described in section 408B(b)) during the portion of the calendar year preceding the adoption of the automatic IRA arrangement and the 2 preceding calendar years. (d) Other rules For purposes of this section, the rules of section 45E(e) shall apply. . (b) Credit allowed as part of general business credit Section 38(b) 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) in the case of an eligible employer (as defined in section 45S(c)) maintaining an automatic IRA arrangement meeting the requirements of section 408B, the small employer automatic IRA arrangement 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. Small employer automatic IRA arrangement. . (d) Effective date The amendments made by this section shall apply to taxable years beginning after December 31, 2018. 4. Studies (a) In general The Secretary of the Treasury and the Secretary of Labor shall jointly conduct a separate study of the feasibility and desirability of each of the following: (1) Extending to automatic IRA arrangements spousal consent