section. . (i) Effective date The amendments made by this section shall take effect as if included in section 2301 of the CARES Act. 20212. Payroll credit for certain fixed expenses of employers subject to closure by reason of COVID–19 (a) In general In the case of an eligible employer, there shall be allowed as a credit against applicable employment taxes for each calendar quarter an amount equal to 50 percent of the qualified fixed expenses paid or incurred by such employer during such calendar quarter. (b) Limitations and refundability (1) Limitation The qualified fixed expenses which may be taken into account under subsection (a) by any eligible employer for any calendar quarter shall not exceed the least of— (A) the qualified fixed expenses paid by the eligible employer in the same calendar quarter of calendar year 2019, (B) $50,000, or (C) the greater of— (i) 25 percent of the wages paid with respect to the employment of all the employees of the eligible employer for such calendar quarter, or (ii) 6.25 percent of the gross receipts of the eligible employer for calendar year 2019. (2) Credit limited to certain employment taxes The credit allowed by subsection (a) with respect to any calendar quarter shall not exceed the applicable employment taxes for such calendar quarter (reduced by any credits allowed under subsections (e) and (f) of section 3111 of such Code, sections 7001 and 7003 of the Families First Coronavirus Response Act, section 2301 of the CARES Act, and section 20204 of this division, for such quarter) on the wages paid with respect to the employment of all the employees of the eligible employer for such calendar quarter. (3) Refundability of excess credit (A) In general If the amount of the credit under subsection (a) exceeds the limitation of paragraph (2) for any calendar quarter, such excess shall be treated as an overpayment that shall be refunded under sections 6402(a) and 6413(b) of the Internal Revenue Code of 1986. (B) Treatment of payments For purposes of section 1324 of title 31,