‘‘SEC. 30D. SUB-SAHARAN AFRICA ECONOMIC ACTIVITY 
CREDIT. 
‘‘(a) ALLOWANCE OF CREDIT.—Except as otherwise 
provided in this section, if a domestic corporation elects 
the application of this section, there shall be allowed as 
a credit against the tax imposed by this chapter the 
amount determined under subsection (b). 
‘‘(b) AMOUNT OF CREDIT.—The amount determined 
under this subsection is the excess of— 
‘‘(1) the product of the highest rate of tax spec-
ified in section 11(b) multiplied by the taxable in-
come (determined without regard to any deduction 
for the taxes described in paragraph (2)), from 
sources without the United States, from the active 
conduct of a qualified trade or business within sub- 
Saharan Africa, over 
‘‘(2) the aggregate taxes described in section 
901(b)(1) which are paid or accrued with respect to 
such income. 
‘‘(c) LIMITATION TO TAX ATTRIBUTABLE TO FOR-
EIGN SOURCE INCOME.— 
‘‘(1) IN
GENERAL.—The amount determined 
under subsection (b) for any taxable year shall not 
exceed the excess of— 
‘‘(A) the amount which bears the same 
ratio to the tax against which such credit is 
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taken which the taxpayer’s taxable income from 
sources without the United States (but not in 
excess of the taxpayer’s entire taxable income) 
bears to the taxpayer’s entire taxable income 
for the same taxable year, over 
‘‘(B) the sum of the credits allowed under 
section 901, 30A, and 936 for the taxable year. 
‘‘(2) ALLOCABLE SHARE OF SPECIFIED ITEMS 
TAKEN INTO ACCOUNT.—In the case of a taxpayer 
whose specified items are increased under subsection 
(f), paragraph (1) shall be applied— 
‘‘(A) by treating the taxpayer’s aggregate 
allocable share of the taxable income referred to 
in subsection (f)(2)(A) as taxable income of the 
taxpayer from sources without the United 
States, and 
‘‘(B) by increasing the amount described in 
paragraph (1)(B) by the taxpayer’s aggregate 
allocable share of taxes referred to in subsection 
(f)(2)(B). 
‘‘(d) LIMITATIONS ON CREDIT FOR ACTIVE BUSI-
NESS INCOME.—The amount determined under subsection 
(b) for any taxable year shall not exceed the sum of the 
following amounts: 
‘‘(1) 60 percent of the sum of— 
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‘‘(A) the aggregate amount of the domestic 
corporation’s qualified Africa wages for such 
taxable year, plus 
‘‘(B) the allocable qualified employee fringe 
benefit expenses of the domestic corporation for 
such taxable year. 
‘‘(2) The sum of— 
‘‘(A) 15 percent of the depreciation allow-
ances for the taxable year with respect to short- 
life qualified tangible property, 
‘‘(B) 40 percent of the depreciation allow-
ances for the taxable year with respect to me-
dium-life qualified tangible property, and 
‘‘(C) 65 percent of the depreciation allow-
ances for the taxable year with respect to long- 
life qualified tangible property. 
‘‘(e) DEFINITIONS.—For purposes of this section— 
‘‘(1) QUALIFIED
TRADE
OR
BUSINESS.—The 
term ‘qualified trade or business’ means any trade 
or business other than— 
‘‘(A) the trade or business of mining (as 
defined in section 613(c)(2)), and 
‘‘(B) the trade or business of exploring for, 
developing, producing, refining, transporting, or 
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selling crude oil or natural gas, or any product 
thereof. 
‘‘(2) QUALIFIED AFRICA WAGES.— 
‘‘(A) IN
GENERAL.—The term ‘qualified 
Africa wages’ means, with respect to any tax-
able year, the excess of— 
‘‘(i) the sum of the wages which are 
paid or incurred during such taxable year 
in connection with the active conduct of a 
qualified trade or business within sub-Sa-
haran Africa to any employee for services 
performed in sub-Saharan Africa, but only 
if such services are performed while the 
principal place of employment of such em-
ployee is within sub-Saharan Africa, over 
‘‘(ii) the sum of wages (if any) paid or 
incurred during the last taxable year end-
ing before the date of the enactment of 
this section in connection with the active 
conduct of a qualified trade or business 
within sub-Saharan Africa (determined as 
of the first day of the taxable year referred 
to in clause (i)) to any employee for serv-
ices performed in sub-Saharan Africa (as 
so determined), but only if such services 
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are performed while the principal place of 
employment of such employee is within 
sub-Saharan Africa (as so determined). 
‘‘(B) APPLICABLE
RULES
FOR
DETER-
MINING WAGES.—For purposes of subparagraph 
(A), rules similar to the rules of subparagraphs 
(B), (C), and (D) of section 936(i)(1) shall 
apply. 
‘‘(3) QUALIFIED EMPLOYEE FRINGE BENEFIT 
EXPENSES.— 
‘‘(A) IN
GENERAL.—The term ‘qualified 
employee fringe benefit expense’ means, with 
respect to any taxable year, the excess of— 
‘‘(i) the sum of the employee fringe 
benefit expenses which are paid or incurred 
during such taxable year in connection 
with the active conduct of a qualified trade 
or business within sub-Saharan Africa to 
or for the benefit of any employee for serv-
ices performed in sub-Saharan Africa, but 
only if such services are performed while 
the principal place of employment of such 
employee is within sub-Saharan Africa, 
over 
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‘‘(ii) the sum of the employee fringe 
benefit expenses paid or incurred during 
the last taxable year ending before the date 
of the enactment of this section in connec-
tion with the active conduct of a qualified 
trade or business within sub-Saharan Afri-
ca (determined as of the first day of the 
taxable year referred to in clause (i)) to or 
for the benefit of any employee for services 
performed in sub-Saharan Africa (as so de-
termined), but only if such services are 
performed while the principal place of em-
ployment of such employee is within sub- 
Saharan Africa (as so determined). 
‘‘(B) EMPLOYEE
FRINGE
BENEFIT
EX-
PENSES.—The term ‘employee fringe benefit ex-
penses’ means with respect to any taxable year 
the expenses described in section 936(i)(2)(B). 
‘‘(4) DEFINITIONS
RELATED
TO
DEPRECIA-
TION.— 
‘‘(A) DEPRECIATION
ALLOWANCES.—The 
term ‘depreciation allowances’ means the depre-
ciation deductions allowable under section 167 
to the taxpayer. 
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