PUBLIC LAW 105-206-^ULY 22, 1998 112 STAT. 797 an amount equal to the amount determined under paragraph (2)(A) for such taxable year, reduced". (2) Section 408A(c)(3) of the 1986 Code (relating to limits based on modified adjusted gross income) is amended— (A) by inserting "or a married individual filing a separate return" after "joint return" in subparagraph (A)(ii), (B) in subparagraph (B)— (i) by inserting ", for the taxable year of the distribution to which such contribution relates" after "if"; and (ii) by striking "for such taxable year" in clause (i), and (C) by striking "and the deduction under section 219 shall be taken into account" in subparagraph (C)(i). (3)(A) Section 408A(d)(2) of the 1986 Code (defining qualified distribution) is amended by striking subparagraph (B) and inserting the following new subparagraph: "(B) DISTRIBUTIONS WITHIN NONEXCLUSION PERIOD.— A pa3mfient or distribution from a Roth IRA shall not be treated as a qualified distribution under subparagraph (A) if such payment or distribution is made within the 5- taxable year period beginning with the first taxable year for which the individual made a contribution to a Roth IRA (or such individual's spouse made a contribution to a Roth IRA) established for such individual.". (B) Section 408A(d)(2) of the 1986 Code is amended by adding at the end the following new subparagraph: " (C) DISTRIBUTIONS OF EXCESS CONTRIBUTIONS AND EARNINGS. —The term 'qualified distribution' shall not include any distribution of any contribution described in section 408(d)(4) and any net income allocable to the contribution.". (4) Section 408A(d)(3) of the 1986 Code (relating to rollovers from IRAs other than Roth IRAs) is amended— (A) by striking clause (iii) of subparagraph (A) and inserting: "(iii) unless the taxpayer elects not to have this clause apply for any taxable year, any amount required to be included in gross income for such taxable year by reason of this paragraph for any distribution before January 1, 1999, shall be so included ratably over the 4-taxable year period beginning with such taxable year. Any election under clause (iii) for any distributions during a taxable year may not be changed after the due date for such taxable year."; and (B) by adding at the end the following new subparagraph: "(F) SPECIAL RULES FOR CONTRIBUTIONS TO WHICH 4-YEAR AVERAGING APPLIES.—In the case of a qualified rollover contribution to a Roth IRA of a distribution to which subparagraph (A)(iii) applied, the following rules shall apply: " (i) ACCELERATION OF INCLUSION.— "(I) IN GENERAL.The amount required to be included in gross income for each of the first 3
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