does not include any amount in excess of— (A) the amount determined under section 802(a)(2) of the Employee Retirement Income Security Act with respect to each employee of the employer, or (B) the amount which would be so determined if the employer were subject to the requirement of section 802(a)(1) of such Act. (d) Employers excluded for failure To make contributions Subsection (a) shall not apply to any employer which fails, within the time prescribed by the Secretary, to make any contribution required to be made by such employer under section 802 of the Employee Retirement Income Security Act of 1974 for the taxable year or any of the 4 taxable years preceding such year. (e) Special rules For purposes of this section— (1) Aggregation rules, etc Rules similar to the rules of section 45E(e) shall apply. (2) Denial of double benefit No credit shall be allowed under this section for any taxable year in which the credit under section 45E is allowed with respect to the taxpayer. (f) Credit made available to tax-Exempt eligible employers (1) In general In the case of a tax-exempt eligible employer, there shall be treated as a credit allowable under subpart C (and not allowable under this subpart) the lesser of— (A) the amount of the credit determined under this section with respect to such employer, or (B) the amount of the payroll taxes of the employer during the calendar year in which the taxable year begins. (2) Tax-exempt eligible employer For purposes of this section, the term tax-exempt eligible employer means an eligible employer which is any organization described in section 501(c) which is exempt from taxation under section 501(a). (3) Payroll taxes For purposes of this subsection— (A) In general The term payroll taxes means— (i) amounts required to be withheld from the employees of the tax-exempt eligible employer under section 3401(a), (ii) amounts required to be withheld from such employees under section 3101(b), and (iii) amounts of the taxes imposed on the tax-exempt eligible employer under section