for the following taxable year. (2) Credit-equivalent of excess deductions For purposes of paragraph (1), the credit-equivalent of the excess described in paragraph (1) for any taxable year is an amount equal to— (A) the sum of— (i) such excess, plus (ii) the product of such excess and the 3-month Treasury rate for the last month of such taxable year, multiplied by (B) the rate of the tax imposed by subsection (a) for such taxable year. (3) Carryover of unused credit If the credit allowable for any taxable year by reason of this subsection exceeds the tax imposed by this section for such year, then (in lieu of treating such excess as an overpayment) the sum of— (A) such excess, plus (B) the product of such excess and the 3-month Treasury rate for the last month of such taxable year, shall be allowed as a credit against the tax imposed by this section for the following taxable year. (4) 3-month Treasury rate For purposes of this subsection, the 3-month Treasury rate is the rate determined by the Secretary based on the average market yield (during any 1-month period selected by the Secretary and ending in the calendar month in which the determination is made) on outstanding marketable obligations of the United States with remaining periods to maturity of 3 months or less. 60C. Tax on noncash compensation provided to employees not engaged in business activity (a) Imposition of tax There is hereby imposed on every employer of an employee to whom this section applies and who makes an election to be taxed under this part a tax equal to— (1) 19 percent of the value of excludable compensation provided during the calendar year by the employer for the benefit of employees to whom this section applies in the case of the first 2 calendar years beginning with the calendar year for which the election under section 60 is made, and (2) 17 percent of such excludable compensation during the calendar year in the case of all calendar years subsequent to the calendar years described in paragraph (1). (b) Liability for tax The tax