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Tax Increase Prevention and Reconciliation Act of 2005 (Enrolled as Agreed to or Passed by Both House and Senate)
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(a) Repeal of Income Limitations-
(1) IN GENERAL- Paragraph (3) of section 408A(c) (relating to limits based on modified adjusted gross income) is amended by striking subparagraph (B) and redesignating subparagraphs (C) and (D) as subparagraphs (B) and (C), respectively.
(2) CONFORMING AMENDMENT- Clause (i) of section 408A(c)(3)(B) (as redesignated by paragraph (1)) is amended by striking `except that--' and all that follows and inserting `except that any amount included in gross income under subsection (d)(3) shall not be taken into account, and'.
(b) Rollovers to a Roth IRA From an IRA Other Than a Roth IRA-
(1) IN GENERAL- Clause (iii) of section 408A(d)(3)(A) (relating to rollovers from an IRA other than a Roth IRA) is amended to read as follows:
`(iii) unless the taxpayer elects not to have this clause apply, any amount required to be included in gross income for any taxable year beginning in 2010 by reason of this paragraph shall be so included ratably over the 2-taxable-year period beginning with the first taxable year beginning in 2011.'.
(2) CONFORMING AMENDMENTS-
(A) Clause (i) of section 408A(d)(3)(E) is amended to read as follows:
`(i) ACCELERATION OF INCLUSION-
`(I) IN GENERAL- The amount otherwise required to be included in gross income for any taxable year beginning in 2010 or the first taxable year in the 2-year period under subparagraph (A)(iii) shall be increased by the aggregate distributions from Roth IRAs for such taxable year which are allocable under paragraph (4) to the portion of such qualified rollover contribution required to be included in gross income under subparagraph (A)(i).
`(II) LIMITATION ON AGGREGATE AMOUNT INCLUDED- The amount required to be included in gross income for any taxable year under subparagraph (A)(iii) shall not exceed the aggregate amount required to be included in gross income under subparagraph (A)(iii) for all taxable years in the 2-year period (without regard to subclause (I)) reduced by amounts included for all preceding taxable years.'.
(B) The heading for section 408A(d)(3)(E) is amended by striking `4-YEAR' and inserting `2-YEAR'.
(c) Effective Date- The amendments made by this section shall apply to taxable years beginning after December 31, 2009.
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