; and (B) having outstanding qualified education loans (as defined in section 221) of not less than $10,000. . (c) Effective date The amendments made by this section shall apply with respect to individuals who begin work for the employer after the date of the enactment of this Act. 3. Student loan program startup costs credit (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. Student loan program startup costs credit (a) In general For purposes of section 38, in the case of an eligible employer, the student loan program startup costs credit determined under this section for any taxable year is an amount equal to 50 percent of the qualified startup costs paid or incurred by the taxpayer during the taxable year. (b) Dollar limitation The amount of the credit determined under this section for any taxable year for a qualified employer shall not exceed— (1) for the first credit year and each of the 2 taxable years immediately following the first credit year, the product of— (A) $500, multiplied by (B) the number of employees participating during such taxable year in an eligible employer plan for which the employer is eligible for a credit under this section, and (2) for any other taxable year, zero. (c) Eligible employer For purposes of this section, the term eligible employer means an employer if such employer, or any member of any controlled group including the employer (or any predecessor of either), during the 3-taxable-year period immediately preceding the first taxable year for which the credit under this section is otherwise allowable for a qualified employer plan of the employer, has not established or maintained a qualified employer plan with respect 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