to which contributions were made, or benefits were accrued, for substantially the same employees as are in the qualified employer plan. (d) Other definitions For purposes of this section— (1) Qualified startup costs (A) In general The term qualified startup costs means any ordinary and necessary expenses of an eligible employer which are paid or incurred in connection with the establishment or administration of an eligible employer plan. Such term shall not include any payment made to, or on behalf of, any employee pursuant to such plan. (B) Plan must have at least one participant Such term shall not include any expense in connection with a plan that does not have at least one employee eligible to participate who is not a highly compensated employee. (2) Eligible employer plan The term eligible employer plan means a student loan repayment plan administered by an employer through which the employer provides, for each employee for each year, qualified matching contributions. (3) Qualified matching contribution The term qualified matching contribution means an employer contribution made to an eligible employer plan on behalf of an employee on account of an employee contribution made by such employee if such employer contribution is at least the lesser of— (A) the amount of such employee contribution, and (B) $2,000. (4) First credit year The term first credit year means— (A) the taxable year which includes the date that the eligible employer plan to which such costs relate becomes effective, or (B) at the election of the eligible employer, the taxable year preceding the taxable year referred to in subparagraph (A). (e) Special rules For purposes of this section— (1) Aggregation rules All persons treated as a single employer under subsection (a) or (b) of section 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