Only schools with 3,000 or more paying students are reached
What the document says“which had at least 3,000 tuition-paying students during the preceding taxable year,”
The section defines an applicable educational institution as an eligible educational institution as defined in section 25A(f)(2) that had at least 3,000 tuition-paying students in the preceding taxable year, has more than 50 percent of those students in the United States, has a student adjusted endowment of at least $500,000, and is not a State college or university described in the first sentence of section 511(a)(2)(B).
What the document actually says“which had at least 3,000 tuition-paying students during the preceding taxable year,”
The school must have had at least 3,000 paying students. That is counted for the year before.
More than half of them must be in the United States. The endowment per student must reach $500,000. State schools are left out.
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