credit is being determined. (B) Credit rate The credit determined under this paragraph shall be equal to 10 percent of the adjusted qualified training expenditures for the taxable year. (2) Aggregation and allocation of expenditures, etc Rules similar to the rules of paragraphs (1), (2), (3), (4), and (5) of section 41(f) shall apply. (e) Election To apply credit against payroll taxes (1) In general At the election of a qualified small business or a qualified tax-exempt organization (as defined in section 3111(e)(5)(A)) for any taxable year, section 3111(g) shall apply to the payroll tax credit portion of the credit otherwise determined under subsection (a) for the taxable year and such portion shall not be treated (other than for purposes of section 280C) as a credit determined under subsection (a). (2) Payroll tax credit portion For purposes of this subsection, the payroll tax credit portion of the credit determined under subsection (a) with respect to any qualified small business or qualified tax-exempt organization for any taxable year is the least of— (A) the amount specified in the election made under this subsection, (B) the credit determined under subsection (a) for the taxable year (determined before the application of this subsection), or (C) in the case of a qualified small business other than a partnership or S corporation, the amount of the business credit carryforward under section 39 carried from the taxable year (determined before the application of this subsection to the taxable year). (3) Qualified small business For purposes of this subsection— (A) In general The term qualified small business means, with respect to any taxable year— (i) a corporation or partnership, if— (I) the gross receipts (as determined under the rules of section 448(c)(3), without regard to subparagraph (A) thereof) of such entity for the taxable year is less than $5,000,000, and (II) such entity did not have gross receipts (as so determined) for any taxable year preceding the 5-taxable-year period ending with such