for the 3-taxable-year period ending with the taxable year which precedes such taxable year are less than $100,000,000. (2) Amount of penalty The penalty determined under this paragraph is an increase, expressed in percentage points, determined in accordance with the following table: If the pay ratio is: The increase is: Greater than 50 to 1, but not greater than 100 to 1 0.5 Greater than 100 to 1, but not greater than 200 to 1 1 Greater than 200 to 1, but not greater than 300 to 1 2 Greater than 300 to 1, but not greater than 400 to 1 3 Greater than 400 to 1, but not greater than 500 to 1 4 Greater than 500 to 1 5. . (b) Conforming amendments (1) The following sections of the Internal Revenue Code of 1986 are each amended by inserting applicable to the corporation (after the application of section 11(e)) after section 11(b) : (A) Section 280C(c)(2)(B)(ii)(II). (B) Paragraphs (2)(B) and (6)(A)(ii) of section 860E(e). (C) Section 7874(e)(1)(B). (2) Section 852(b)(3)(A) of such Code is amended by inserting (after the application of section 11(e)) after section 11(b) . (3) Paragraphs (1) and (2) of section 1445(e) of such Code are each amended by striking in effect for the taxable year under section 11(b) and inserting applicable to such corporation under section 11 for the taxable year . (4) Section 1446(b)(2)(B) of such Code is amended by striking specified in section 11(b) and inserting applicable to such corporation under section 11 for the taxable year . (c) Effective date The amendments made by this section shall apply to taxable years beginning after December 31, 2024. (d) Regulations The Secretary of the Treasury (or the Secretary's delegate) shall issue regulations as necessary to prevent avoidance of the purposes of the amendments made by subsection (a), including regulations to prevent the manipulation of the compensation ratio under section 11(e) of the Internal Revenue Code of 1986 by changes to the composition of the workforce (including by using the services of contractors rather than employees).