106 STAT. 304 PUBLIC LAW 102-318—JULY 3, 1992 to any employee, paragraphs (1) and (3) of subsection (d) shall not apply to any distribution (paid after such distribution) of the balance to the credit of the employee under the plan under which the preceding distribution was made (or under any other plan which, under subsection (d)(4)(C), would be aggregated with such plan). "(d) TAX ON LUMP SUM DiSTRffiunoNS.— "(1) IMPOSITION OF SEPARATE TAX ON LUMP SUM DIS- TRIBUTIONS.— "(A) SEPARATE TAX. — There is hereby imposed a tax (in the amount determined under subparagraph (B)) on a lump siun distribution. "(B) AMOUNT OF TAX. —The amount of tax imposed by subparagraph (A) for any taxable year is an amount equal to 5 times the tax which would be imposed by subsection (c) of section 1 if the recipient were an individual referred to in such subsection and the taxable income were an amount equal to VB of the excess of— "(i) the total taxable amount of the lump sum distribution for the tsixable year, over "(ii) the minimum distribution allowance. "(C) MINIMUM DISTRIBUTION ALLOWANCE. —For purposes of this paragraph, the minimum distribution allowance for any taxable year is an amount equal to— "(i) the lesser of $10,000 or one-half of the total taxable amount of the lump sum distribution for the taxable year, reduced (but not below zero) by "(ii) 20 percent of the amount (if any) by which such total taxable amount exceeds $20,000. "(D) LIABILITY FOR TAX. — The recipient shall be Hable for the tax imposed by this paragraph. "(2) DISTRIBUTIONS OF ANNUITY CONTRACTS.— "(A) IN GENERAL. — In the case of any recipient of a lump sum distribution for any taxable year, if the distribution (or any part thereof) is an annuity contract, the total taxable amount of the distribution shall be aggregated for purposes of computing the tax imposed by paragraph (1)(A), except that the amount of tax so computed shall be reduced (but not below zero) by that portion of the tax on the aggregate total taxable amount which is attributable to annuity contracts. "(B) BENEFICIARIES.— For purposes of this paragraph, a beneficiary of a trust to which a lump sum distribution is made shall be treated as the recipient of such distribution if the beneficiary is an employee (including an employee within the meaning of section 401(c)(l)) with respect to the plan under which the distribution is made or if the beneficiary is treated as the owner of such trust for purposes of subpart E of part I of subchapter J. "(C) ANNUITY CONTRACTS.— For purposes of this paragraph, in the case of the distribution of an annuity contract, the taxable amount of such distribution shall be deemed to be the current actuarial value of the contract, determined on the date of such distribution. "(D) TRUSTS.—In the case of a lump sum distribution with respect to any individual which is made only to 2 or more trusts, the tax imposed by paragraph (I)(A) shall
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