Act) in which the employment loss (excluding any part-time employees) for positions which will be moved to a country outside of the United States, as determined pursuant to the outsourcing statement (as described in paragraph (1) of such section 3(e) of such Act) served by the taxpayer during the taxable year, exceeds 50 employees. (c) Expanded affiliated group treated as single taxpayer For purposes of this section, the members of an expanded affiliated group (as defined in section 280I(b)(4)) shall be treated as a single taxpayer. . (b) Clerical amendment The table of subparts for part IV of subchapter A of chapter 1 of such Code is amended by adding at the end the following new item: Subpart K. Recapture of credits for outsourcing employers . (c) Effective date The amendments made by this section shall apply to taxable years beginning after the date of the enactment of this Act. 6. Credit for insourcing expenses (a) In general Subpart D of part IV of subchapter A of chapter 1 of the Internal Revenue Code of 1986 is amended by adding at the end the following new section: 45S. Credit for insourcing expenses (a) In general For purposes of section 38, the insourcing expenses credit for any taxable year is an amount equal to 20 percent of the eligible insourcing expenses of the taxpayer which are taken into account in such taxable year under subsection (d). (b) Eligible insourcing expenses For purposes of this section— (1) In general The term eligible insourcing expenses means— (A) eligible expenses paid or incurred by the taxpayer in connection with the elimination of any business unit of the taxpayer (or of any member of any expanded affiliated group in which the taxpayer is also a member) located outside the United States, and (B) eligible expenses paid or incurred by the taxpayer in connection with the establishment of any business unit of the taxpayer (or of any member of any expanded affiliated group in which the taxpayer is also a member) located within— (i) a HUBZone (as defined in section 3(p)(2) of the