; denial of double benefit Paragraph (1) of section 221(e) of the Internal Revenue Code of 1986 is amended by inserting before the period the following: , or for which an exclusion is allowable under section 127 to the taxpayer's employer by reason of the payment by such employer of any indebtedness on a qualified education loan of the taxpayer . (3) Effective date The amendments made by this subsection shall apply to taxable years beginning after the date of the enactment of this Act. 4. Deduction of qualified enterprise income (a) In general Part VI of subchapter B of chapter 1 of the Internal Revenue Code of 1986 is amended by inserting after section 181 the following new section: 182. Qualified enterprise income (a) In general In the case of a qualified taxpayer, there shall be allowed as a deduction an amount equal to any qualified enterprise income of such taxpayer. (b) Limitation The amount of the deduction allowed under subsection (a) for any taxable year shall not exceed an amount equal to 50 percent of the W–2 wages paid by the qualified taxpayer during such taxable year. (c) Definitions In this section: (1) Qualified enterprise income (A) In general The term qualified enterprise income means the amount equal to the excess (if any) of— (i) the gross receipts of the qualified taxpayer for the taxable year which are properly allocable to a qualified facility, over (ii) an amount equal to the sum of— (I) the cost of goods sold which are allocable to such receipts, and (II) any other expenses, losses or deductions (with the exception of the deduction allowed under this section) which are allocable to such receipts. (B) Limitation The term qualified enterprise income shall apply only to gross receipts described in subparagraph (A) for the 3-taxable-year period beginning after the qualified facility is placed in service. (C) Method of allocation The Secretary shall prescribe regulations for ensuring proper allocation of amounts under subparagraph (A). (2) Qualified facility (A) In general The term qualified