allowed under subsection (e) or (f) of section 3111) on the wages paid with respect to the employment of all the employees of the employer for such calendar quarter. (2) Carryover as employment or income tax credit If the amount of any credit under subsection (a) exceeds the limitation of paragraph (1) for any calendar quarter, such excess— (A) except as provided in subparagraph (B), shall be carried to the succeeding calendar quarter and allowed as a credit under subsection (a) for such quarter, or (B) if the employer elects the application of this subparagraph (at such time and in such manner as the Secretary may provide), shall taken into account as a current year business credit under section 38(b)(42) for the taxable year of the employer in which or with which such calendar quarter ends. (e) Recapture (1) In general If credit is determined under this section with respect to any employee and such employee fails to succeed at training, the applicable employment taxes of the employer with respect to which such credit is determined shall be increased for the calendar quarter which includes the date of such failure by the aggregate amount of such credits. (2) Determination of failure An employee shall be treated as failing to succeed at training if such employee fails to complete the training program or fails to obtain the skill, employment classification, or certification with respect to which the training program relates. (f) Special rules (1) Aggregation rule For purposes of subsection (b), all persons treated as a single employer under subsection (a) or (b) of section 52, or subsection (m) or (o) of section 414, shall be treated as one employer. (2) Denial of double benefit No deduction or credit (other than the credit determined under this section) shall be allowed for that portion of the qualified workforce training expenses paid or incurred in a taxable year which is equal to the credit determined under this section with respect to such expenses. (3) Exclusion of governmental and non-profit employers No