‘‘(1) IN GENERAL.—The credit allowed under 
subsection (a) with respect to any individual for any 
taxable year shall not exceed the specified employ-
ment taxes with respect to such individual for such 
taxable year. 
‘‘(2) SPECIFIED
EMPLOYMENT
TAXES.—For 
purposes of this subsection, the term ‘specified em-
ployment taxes’ means, with respect to any indi-
vidual for any taxable year, the sum of— 
‘‘(A) the taxes imposed under sections 
3101(a), 3101(b), 3111(a), 3111(b), 3201(a), 
3211(a), and 3221(a) (taking into account any 
adjustments or refunds under section 6413) 
with respect to wages and compensation re-
ceived by such individual during the calendar 
year in which such taxable year begins, and 
‘‘(B) the taxes imposed under subsections 
(a) and (b) of section 1401 with respect to the 
self-employment income of such individual for 
such taxable year. 
‘‘(c) SPECIAL RULE FOR EMPLOYMENT COMPENSA-
TION IN EXCESS OF SOCIAL SECURITY CONTRIBUTION 
BASE.— 
‘‘(1) IN GENERAL.—If the aggregate amount of 
employment compensation received by any individual 
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during the calendar year in which the taxable year 
begins exceeds the contribution and benefit base (as 
determined under section 230 of the Social Security 
Act), the amount of the credit determined under 
subsection (a) (determined before application of sub-
section (b)) shall be equal to the sum of— 
‘‘(A) the amount determined under sub-
section (a) by only taking into account so much 
of the amount determined under subsection 
(a)(2) as does not exceed such excess and by 
only taking into account the rates of tax in ef-
fect under section 3101(b) and 3111(b), and 
‘‘(B) the amount determined under sub-
section (a) by only taking into account so much 
of the amount determined under subsection 
(a)(2) as is not taken into account under sub-
paragraph (A) and by taking into account each 
of the rates of tax referred to in subsection 
(a)(1). 
‘‘(2) EMPLOYMENT COMPENSATION.—For pur-
poses of this subsection, the term ‘employment com-
pensation’ means, with respect to any individual for 
any taxable year, the sum of— 
‘‘(A) the wages (as defined in section 
3121(a)) and compensation (as defined in sec-
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tion 3231(e)) received by such individual during 
the calendar year in which such taxable year 
begins, and 
‘‘(B) the self-employment income (as de-
fined in section 1402(b)) of such individual for 
such taxable year. 
‘‘(d) RECAPTURE
OF CONTRIBUTION CREDIT
IN 
CASE OF CERTAIN NONQUALIFIED DISTRIBUTIONS FROM 
HEALTH SAVINGS ACCOUNTS.— 
‘‘(1) IN GENERAL.—In the case of a taxpayer 
whose gross income for any taxable year includes a 
payment or distribution from a health savings ac-
count of the taxpayer by reason of section 223(f)(2) 
and with respect to whom there is a contribution 
credit recapture amount for such taxable year, the 
tax imposed by this chapter on such taxpayer for 
such taxable year shall be increased by the lesser 
of— 
‘‘(A) the product of— 
‘‘(i) the sum of the rates of tax in ef-
fect under sections 3101(a), 3101(b), 
3111(a), and 3111(b) for the calendar year 
in which such taxable year begins, multi-
plied by 
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