Qualified wages.   Qualified wages are wages paid or incurred by the corporation during the tax year in connection with the active conduct of a trade or business in American Samoa to an employee for services performed in American Samoa, but only if the services are performed while the employee's principal place of employment is in American Samoa.

  The term “wages” generally means wages as defined in section 3306(b), but without regard to any dollar limitation contained in that section. For this purpose, section 3306(b) is applied as if the term “United States” includes American Samoa. See section 936(i)(1)(D)(ii) for a special rule for agricultural labor and railway labor.

  The wages that are taken into account for the tax year for any employee are limited to 85% of the old-age, survivors, and disability insurance (OASDI) contribution and benefit base for the calendar year in which that tax year begins. The OASDI contribution and benefit base for 2012 is $110,100 and for 2013 is $113,700.

  Special rules apply to part-time employees and employees whose principal place of employment with the corporation is not within American Samoa at all times during the tax year.

  For more information, see section 936(i)(1).

Allocable employee fringe benefit expenses.   The total amount of employee fringe benefit expenses taken into account in figuring the economic-activity limitation is the amount deductible by the corporation in the tax year for:

  The amount of allocable employee fringe benefit expenses for a tax year is equal to the total amount of employee fringe benefit expenses (defined above) multiplied by a fraction. The fraction consists of the corporation's qualified wages (defined above) for the tax year, divided by the aggregate amount of wages paid or incurred by the corporation during the tax year.

  The allocable employee fringe benefit expenses cannot exceed 15% of the corporation's qualified wages for the tax year.

  For more information, see section 936(i)(2).