6 5 "(B) the number of qualified vocational edu cation instructors who were employed by the tax payer during the taxable year. "(b) LIMITATIONS. "(1) LIMITATION ON THE NUMBER OF COURSES TAUGHT PER EMPLOYEE.-No more than 5 postsecon dary vocational education courses taught by the same qualified teaching employee may be taken into account under subsection (a)(1)(B). "(2) LIMITATION BASED ON AMOUNT OF TAX.— "(A) IN GENERAL.-Except as provided in subparagraph (B), the credit allowed by subsection (a) for any taxable year shall not exceed the amount of the tax imposed by this chapter for the taxable year reduced by the sum of the credits al lowable for the taxable year under a section of this part having a lower number or letter designa tion than this section, other than the credits al lowable by sections 31, 39, and 43. For purposes of the preceding sentence, the term 'tax imposed by this chapter' shall not include any tax treated as not imposed by this chapter under the last sen tence of section 53(a). "(B) SPECIAL RULE FOR PASSTHROUGH OF CREDIT. In the case of an individual who 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 6 "(i) owns an interest in an unincorporat ed trade or business, “(ii) is a partner in a partnership, "(iii) is a beneficiary of an estate or trust, or "(iv) is a shareholder in an electing small business corporation (within the meaning of section 1371(b)), the credit allowed by subsection (a) for any taxable year shall not exceed the lesser of the amount determined under subparagraph (A) for the taxable year or an amount (separately computed with respect to such person's interest in such trade or business or entity) equal to the amount of tax attributable to that portion of a person's taxable income which is allocable or ap portionable to the person's interest in such trade, business, or entity. (c) DEFINITIONS AND SPECIAL RULES.-For purposes 19 of this section "(1) POSTSECONDARY VOCATIONAL EDUCATION COURSES.-The term 'postsecondary vocational educa tion course' means any course of instruction which"(A) is offered by an institution of higher education as part of an organized education pro gram that 7 “(i) is a 2-year program in engineering, mathematics, or the physical or biological sciences, designed to prepare a student to work as a technician or at the semiprofessional level in engineering, scientific, or other technological fields requiring the understanding and application of basic engineering, scientific, or mathematical principles of knowledge, or "(ii) is directly related to the preparation of individuals for paid or unpaid employ ment or for a career which does not require a baccalaureate or advanced degree, “(B) consists of a period of instruction which is at least equivalent to a course of instruction that provides 3 hours of instruction per week during an academic semester, and "(C) has been completed before the close of the taxable year. "(2) QUALIFIED VOCATIONAL EDUCATION INSTRUCTOR.-The term 'qualified vocational education instructor' means an individual who— "(A) was employed by the taxpayer on a full-time basis for at least 3 months but not more 8 than 12 months during the 2-year period ending at the close of the taxable year, "(B) prior to such employment, taught postsecondary vocational education courses on a fulltime basis at an institution of higher education, "(C) is teaching such courses on a full-time basis at an institution of higher education at the close of such taxable year, and "(D) is not employed by the taxpayer at the close of the taxable year. "(3) QUALIFIED TEACHING EMPLOYEE.-The term 'qualified teaching employee' means an individual who “(A) taught at least one postsecondary vocational education course on a part-time basis at an institution of higher education during the taxable year, "(B) is a full-time employee of the taxpayer for the entire taxable year, "(C) does not receive any compensation from such institution of higher education, and "(D) was not a qualified vocational education instructor at any time during the taxable year. “(4) INSTITUTION OF HIGHER EDUCATION.—The term 'institution of higher education' has the meaning 9 given such term in section 1201(a) of the Higher Edu cation Act of 1965. "(5) ALLOCATION. "(A) CONTROLLED GROUP OF CORPORA TIONS.-In determining the amount of the credit under this section "(i) all members of the same controlled group of corporations shall be treated as a single taxpayer, and “(ii) the credit (if any) allowable by this section to each such member with respect to any qualified teaching employee or qualified vocational education instructor shall be in proportion to the member's share of the wages paid for the taxable year to such qualified teaching employee or qualified vocational education instructor. "(B) COMMON CONTROL.-Under regulations prescribed by the Secretary, in determining the amount of credit under this section— "(i) all trades or businesses (whether or not incorporated) which are under common control shall be treated as a single taxpayer, and |