Internal Revenue Code:Sec. 408A. Roth IRAs
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TITLE 26 - INTERNAL REVENUE CODE
Subtitle A - Income Taxes
CHAPTER 1 - NORMAL TAXES AND SURTAXES
Subchapter D - Deferred Compensation, Etc.
PART I - PENSION, PROFIT-SHARING, STOCK BONUS PLANS, ETC.
Subpart A - General Rule
Statute
Sec. 408A. Roth IRAs
(a) General rule
Except as provided in this section, a Roth IRA shall be treated
for purposes of this title in the same manner as an individual
retirement plan.
(b) Roth IRA
For purposes of this title, the term ''Roth IRA'' means an
individual retirement plan (as defined in section 7701(a)(37))
which is designated (in such manner as the Secretary may prescribe)
at the time of establishment of the plan as a Roth IRA. Such
designation shall be made in such manner as the Secretary may
prescribe.
(c) Treatment of contributions
(1) No deduction allowed
No deduction shall be allowed under section 219 for a
contribution to a Roth IRA.
(2) Contribution limit
The aggregate amount of contributions for any taxable year to
all Roth IRAs maintained for the benefit of an individual shall
not exceed the excess (if any) of -
(A) the maximum amount allowable as a deduction under section
219 with respect to such individual for such taxable year
(computed without regard to subsection (d)(1) or (g) of such
section), over
(B) the aggregate amount of contributions for such taxable
year to all other individual retirement plans (other than Roth
IRAs) maintained for the benefit of the individual.
(3) Limits based on modified adjusted gross income
(A) Dollar limit
The amount determined under paragraph (2) for any taxable
year shall not exceed an amount equal to the amount determined
under paragraph (2)(A) for such taxable year, reduced (but not
below zero) by the amount which bears the same ratio to such
amount as -
(i) the excess of -
(I) the taxpayer's adjusted gross income for such taxable
year, over
(II) the applicable dollar amount, bears to
(ii) $15,000 ($10,000 in the case of a joint return or a
married individual filing a separate return).
The rules of subparagraphs (B) and (C) of section 219(g)(2)
shall apply to any reduction under this subparagraph.
(B) Definitions
For purposes of this paragraph -
(i) adjusted gross income shall be determined in the same
manner as under section 219(g)(3), except that any amount
included in gross income under subsection (d)(3) shall not be
taken into account, and
(ii) the applicable dollar amount is -
(I) in the case of a taxpayer filing a joint return,
$150,000,
(II) in the case of any other taxpayer (other than a
married individual filing a separate return), $95,000, and
(III) in the case of a married individual filing a
separate return, zero.
(C) Marital status
Section 219(g)(4) shall apply for purposes of this paragraph.
(D) Inflation adjustment.--In the case of any
taxable year beginning in a calendar year after 2006,
the dollar amounts in subclauses (I) and (II) of
subparagraph (C)(ii) shall each be increased by an
amount equal to--
(i) such dollar amount, multiplied by
(ii) the cost-of-living adjustment
determined under section 1(f)(3) for the calendar
year in which the taxable year begins, determined
by substituting `calendar year 2005' for `calendar
year 1992' in subparagraph (B) thereof.
Any increase determined under the preceding sentence
shall be rounded to the nearest multiple of $1,000.
(4) Contributions permitted after age 70 1/2
Contributions to a Roth IRA may be made even after the
individual for whom the account is maintained has attained age 70
1/2.
(5) Mandatory distribution rules not to apply before death
Notwithstanding subsections (a)(6) and (b)(3) of section 408
(relating to required distributions), the following provisions
shall not apply to any Roth IRA:
(A) Section 401(a)(9)(A).
(B) The incidental death benefit requirements of section
401(a).
(6) Rollover contributions
(A) In general
No rollover contribution may be made to a Roth IRA unless it
is a qualified rollover contribution.
(B) Coordination with limit
A qualified rollover contribution shall not be taken into
account for purposes of paragraph (2).
(7) Time when contributions made
For purposes of this section, the rule of section 219(f)(3)
shall apply.
(d) Distribution rules
For purposes of this title -
(1) Exclusion
Any qualified distribution from a Roth IRA shall not be
includible in gross income.
(2) Qualified distribution
For purposes of this subsection -
(A) In general
The term ''qualified distribution'' means any payment or
distribution -
(i) made on or after the date on which the individual
attains age 59 1/2,
(ii) made to a beneficiary (or to the estate of the
individual) on or after the death of the individual,
(iii) attributable to the individual's being disabled
(within the meaning of section 72(m)(7)), or
(iv) which is a qualified special purpose distribution.
(B) Distributions within nonexclusion period
A payment 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.
(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.
(3) Rollovers from an eligible retirement plan other than a Roth IRA
(A) In general
Notwithstanding sections 402(c), 403(b)(8),
408(d)(3), and 457(e)(16), in the case of any
distribution to which this paragraph applies -
(i) there shall be included in gross income any amount
which would be includible were it not part of a qualified
rollover contribution,
(ii) section 72(t) shall not apply, and
(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.
Any election under clause (iii) for any distributions during a
taxable year may not be changed after the due date for such
taxable year.
(B) Distributions to which paragraph applies
This paragraph shall apply to a distribution from an
eligible retirement plan (as defined by section 402(c)(8)(B))
(other than a Roth IRA) maintained for the benefit of an
individual which is contributed to a Roth IRA maintained
for the benefit of such individual in a qualified rollover contribution.
(C) Conversions
The conversion of an individual retirement plan (other than a
Roth IRA) to a Roth IRA shall be treated for purposes of this
paragraph as a distribution to which this paragraph applies.
(D) Additional reporting requirements
Trustees of Roth IRAs, trustees of individual retirement
plans, persons subject to section 6047(d)(1), or
all of the foregoing persons, whichever is appropriate,
shall include such additional information in reports required
under section 408(i) or 6047 as the Secretary may require to
ensure that amounts required to be included in gross income under
subparagraph (A) are so included.
(E) Special rules for contributions to which 2-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 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.
(ii) Death of distributee
(I) In general
If the individual required to include amounts in gross
income under such subparagraph dies before all of such
amounts are included, all remaining amounts shall be
included in gross income for the taxable year which
includes the date of death.
(II) Special rule for surviving spouse
If the spouse of the individual described in subclause
(I) acquires the individual's entire interest in any Roth
IRA to which such qualified rollover contribution is
properly allocable, the spouse may elect to treat the
remaining amounts described in subclause (I) as includible
in the spouse's gross income in the taxable years of the
spouse ending with or within the taxable years of such
individual in which such amounts would otherwise have been
includible. Any such election may not be made or changed
after the due date for the spouse's taxable year which
includes the date of death.
(F) Special rule for applying section 72
(i) In general
If -
(I) any portion of a distribution from a Roth IRA is
properly allocable to a qualified rollover contribution
described in this paragraph; and
(II) such distribution is made within the 5-taxable year
period beginning with the taxable year in which such
contribution was made,
then section 72(t) shall be applied as if such portion were
includible in gross income.
(ii) Limitation
Clause (i) shall apply only to the extent of the amount of
the qualified rollover contribution includible in gross
income under subparagraph (A)(i).
(4) Aggregation and ordering rules
(A) Aggregation rules
Section 408(d)(2) shall be applied separately with respect to
Roth IRAs and other individual retirement plans.
(B) Ordering rules
For purposes of applying this section and section 72 to any
distribution from a Roth IRA, such distribution shall be
treated as made -
(i) from contributions to the extent that the amount of
such distribution, when added to all previous distributions
from the Roth IRA, does not exceed the aggregate
contributions to the Roth IRA; and
(ii) from such contributions in the following order:
(I) Contributions other than qualified rollover
contributions to which paragraph (3) applies.
(II) Qualified rollover contributions to which paragraph
(3) applies on a first-in, first-out basis.
Any distribution allocated to a qualified rollover contribution
under clause (ii)(II) shall be allocated first to the portion
of such contribution required to be included in gross income.
(5) Qualified special purpose distribution
For purposes of this section, the term ''qualified special
purpose distribution'' means any distribution to which
subparagraph (F) of section 72(t)(2) applies.
(6) Taxpayer may make adjustments before due date
(A) In general
Except as provided by the Secretary, if, on or before the due
date for any taxable year, a taxpayer transfers in a
trustee-to-trustee transfer any contribution to an individual
retirement plan made during such taxable year from such plan to
any other individual retirement plan, then, for purposes of
this chapter, such contribution shall be treated as having been
made to the transferee plan (and not the transferor plan).
(B) Special rules
(i) Transfer of earnings
Subparagraph (A) shall not apply to the transfer of any
contribution unless such transfer is accompanied by any net
income allocable to such contribution.
(ii) No deduction
Subparagraph (A) shall apply to the transfer of any
contribution only to the extent no deduction was allowed with
respect to the contribution to the transferor plan.
(7) Due date
For purposes of this subsection, the due date for any taxable
year is the date prescribed by law (including extensions of time)
for filing the taxpayer's return for such taxable year.
(e) Qualified Rollover Contribution.--For purposes of this
section, the term `qualified rollover contribution' means a rollover
contribution--
(1) to a Roth IRA from another such account,
(2) from an eligible retirement plan, but only if--
(A) in the case of an individual retirement plan,
such rollover contribution meets the requirements of
section 408(d)(3), and
(B) in the case of any eligible retirement plan
(as defined in section 402(c)(8)(B) other than clauses
(i) and (ii) thereof), such rollover contribution meets
the requirements of section 402(c), 403(b)(8), or
457(e)(16), as applicable.
For purposes of section 408(d)(3)(B), there shall be disregarded any
qualified rollover contribution from an individual retirement plan
(other than a Roth IRA) to a Roth IRA.
(f) Individual retirement plan
For purposes of this section -
(1) a simplified employee pension or a simple retirement
account may not be designated as a Roth IRA; and
(2) contributions to any such pension or account shall not be
taken into account for purposes of subsection (c)(2)(B).
Sources
(Added Pub. L. 105-34, title III, Sec. 302(a), Aug. 5, 1997, 111
Stat. 825; amended Pub. L. 105-206, title VI, Sec. 6005(b)(1)-(7),
(9), title VII, Sec. 7004(a), July 22, 1998, 112 Stat. 796-800,
833; Pub. L. 105-277, div. J, title IV, Sec. 4002(j), Oct. 21,
1998, 112 Stat. 2681-908; Pub. L. 107-16, title VI, Sec. 617(e)(1),
June 7, 2001, 115 Stat. 106.)
Amendment of Section
AMENDMENT OF SUBSECTION (E)
Pub. L. 107-16, title VI, Sec. 617(e)(1), (f), title IX, Sec.
901, June 7, 2001, 115 Stat. 106, 150, provided that, applicable
to taxable years beginning after Dec. 31, 2005, subsection (e) of
this section is temporarily amended by inserting after the first
sentence ''Such term includes a rollover contribution described
in section 402A(c)(3)(A).'' See Effective and Termination Dates
of 2001 Amendment note below.
Miscellaneous
AMENDMENTS
2006 - Pension Protection Act of 2006 (P.L. 109-280)
Section 833(c) Contribution Limitation for Roth IRAs.--Section 408A(c)(3) of
such Code is amended by adding at the end the following new
subparagraph:
``(C) Inflation adjustment.--In the case of any
taxable year beginning in a calendar year after 2006,
the dollar amounts in subclauses (I) and (II) of
subparagraph (C)(ii) shall each be increased by an
amount equal to--
``(i) such dollar amount, multiplied by
``(ii) the cost-of-living adjustment
determined under section 1(f)(3) for the calendar
year in which the taxable year begins, determined
by substituting `calendar year 2005' for `calendar
year 1992' in subparagraph (B) thereof.
Any increase determined under the preceding sentence
shall be rounded to the nearest multiple of $1,000.''.
2006 - Pension Protection Act of 2006 (P.L. 109-280)
SEC. 824. ALLOW DIRECT ROLLOVERS FROM RETIREMENT PLANS TO ROTH IRAS.
(a) In General.--Subsection (e) of section 408A of the Internal
Revenue Code of 1986 (defining qualified rollover contribution) is
amended to read as follows:
``(e) Qualified Rollover Contribution.--For purposes of this
section, the term `qualified rollover contribution' means a rollover
contribution--
``(1) to a Roth IRA from another such account,
``(2) from an eligible retirement plan, but only if--
``(A) in the case of an individual retirement plan,
such rollover contribution meets the requirements of
section 408(d)(3), and
``(B) in the case of any eligible retirement plan
(as defined in section 402(c)(8)(B) other than clauses
(i) and (ii) thereof), such rollover contribution meets
the requirements of section 402(c), 403(b)(8), or
457(e)(16), as applicable.
For purposes of section 408(d)(3)(B), there shall be disregarded any
qualified rollover contribution from an individual retirement plan
(other than a Roth IRA) to a Roth IRA.''.
(b) Conforming Amendments.--
(1) <<NOTE: 26 USC 408A and note.>> Section 408A(c)(3)(B) of
such Code, as in effect before the Tax Increase Prevention and
Reconciliation Act of 2005, is amended--
(A) in the text by striking ``individual retirement
plan'' and inserting ``an eligible retirement plan (as
defined by section 402(c)(8)(B))'', and
(B) in the heading by striking ``IRA'' the first
place it appears and inserting ``eligible retirement
plan''.
(2) Section 408A(d)(3) of such Code <<NOTE: 26 USC
408A.>> is amended--
(A) in subparagraph (A), by striking ``section
408(d)(3)'' inserting ``sections 402(c), 403(b)(8),
408(d)(3), and 457(e)(16)'',
(B) in subparagraph (B), by striking ``individual
retirement plan'' and inserting ``eligible retirement
plan (as defined by section 402(c)(8)(B))'',
(C) in subparagraph (D), by inserting ``or 6047''
after ``408(i)'',
(D) in subparagraph (D), by striking ``or both'' and
inserting ``persons subject to section 6047(d)(1), or
all of the foregoing persons'', and
(E) in the heading, by striking ``IRA'' the first
place it appears and inserting ``eligible retirement
plan''.
(c) <<NOTE: 26 USC 408A note.>> Effective Date.--The amendments made
by this section shall apply to distributions after December 31, 2007.
2006 - P.L. 109-222
SEC. 512. CONVERSIONS TO ROTH IRAS.
(a) Repeal of Income Limitations.--
(1) In general.--Paragraph (3) of <<NOTE: 26 USC
408A.>> 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 <<NOTE: 26 USC 408A.>> section
408A(d)(3)(E) is amended by striking ``4-year'' and
inserting ``2-year''.
(c) Effective Date.--The <<NOTE: 26 USC 408A note.>> amendments made
by this section shall apply to taxable years beginning after December
31, 2009.
1998 - Subsec. (c)(3)(A). Pub. L. 105-206, Sec. 6005(b)(1),
substituted ''shall not exceed an amount equal to the amount
determined under paragraph (2)(A) for such taxable year, reduced''
for ''shall be reduced'' in introductory provisions.
Subsec. (c)(3)(A)(ii). Pub. L. 105-206, Sec. 6005(b)(2)(A),
inserted ''or a married individual filing a separate return'' after
''joint return''.
Subsec. (c)(3)(B). Pub. L. 105-206, Sec. 6005(b)(2)(B)(i),
inserted '', for the taxable year of the distribution to which such
contribution relates'' after ''if'' in introductory provisions.
Subsec. (c)(3)(B)(i). Pub. L. 105-206, Sec. 6005(b)(2)(B)(ii),
struck out ''for such taxable year'' after ''gross income''.
Subsec. (c)(3)(C)(i). Pub. L. 105-206, Sec. 7004(a), amended cl.
(i) generally. Prior to amendment, cl. (i) read as follows:
''adjusted gross income shall be determined in the same manner as
under section 219(g)(3), except that any amount included in gross
income under subsection (d)(3) shall not be taken into account,
and''.
Pub. L. 105-206, Sec. 6005(b)(2)(C), struck out ''and the
deduction under section 219 shall be taken into account'' after
''taken into account''.
Subsec. (c)(3)(C)(i)(II). Pub. L. 105-277 substituted '', and''
for period at end.
Subsec. (d)(1). Pub. L. 105-206, Sec. 6005(b)(5)(B), substituted
''Exclusion'' for ''General rules'' in heading and amended text
generally. Prior to amendment, text read as follows:
''(A) Exclusions from gross income. - Any qualified distribution
from a Roth IRA shall not be includible in gross income.
''(B) Nonqualified distributions. - In applying section 72 to any
distribution from a Roth IRA which is not a qualified distribution,
such distribution shall be treated as made from contributions to
the Roth IRA to the extent that such distribution, when added to
all previous distributions from the Roth IRA, does not exceed the
aggregate amount of contributions to the Roth IRA.''
Subsec. (d)(2)(B). Pub. L. 105-206, Sec. 6005(b)(3)(A), added
subpar. (B) and struck out heading and text of former subpar. (B).
Text read as follows: ''A payment or distribution shall not be
treated as a qualified distribution under subparagraph (A) if -
''(i) it is made within the 5-taxable year period beginning
with the 1st 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, or
''(ii) in the case of a payment or distribution properly
allocable (as determined in the manner prescribed by the
Secretary) to a qualified rollover contribution from an
individual retirement plan other than a Roth IRA (or income
allocable thereto), it is made within the 5-taxable year period
beginning with the taxable year in which the rollover
contribution was made.''
Subsec. (d)(2)(C). Pub. L. 105-206, Sec. 6005(b)(3)(B), added
subpar. (C).
Subsec. (d)(3)(A). Pub. L. 105-206, Sec. 6005(b)(4)(A), added cl.
(iii) and concluding provisions and struck out former cl. (iii)
which read as follows: ''in the case of a distribution before
January 1, 1999, any amount required to be included in gross income
by reason of this paragraph shall be so included ratably over the
4-taxable year period beginning with the taxable year in which the
payment or distribution is made.''
Subsec. (d)(3)(D). Pub. L. 105-206, Sec. 6005(b)(6)(B),
redesignated subpar. (E) as (D) and struck out heading and text of
former subpar. (D). Text read as follows: ''If, no later than the
due date for filing the return of tax for any taxable year (without
regard to extensions), an individual transfers, from an individual
retirement plan (other than a Roth IRA), contributions for such
taxable year (and any earnings allocable thereto) to a Roth IRA, no
such amount shall be includible in gross income to the extent no
deduction was allowed with respect to such amount.''
Subsec. (d)(3)(E). Pub. L. 105-206, Sec. 6005(b)(6)(B),
redesignated subpar. (F) as (E). Former subpar. (E) redesignated
(D).
Subsec. (d)(3)(F). Pub. L. 105-206, Sec. 6005(b)(6)(B),
redesignated subpar. (G) as (F). Former subpar. (F) redesignated
(E).
Pub. L. 105-206, Sec. 6005(b)(4)(B), added subpar. (F).
Subsec. (d)(3)(G). Pub. L. 105-206, Sec. 6005(b)(6)(B),
redesignated subpar. (G) as (F).
Pub. L. 105-206, Sec. 6005(b)(4)(B), added subpar. (G).
Subsec. (d)(4). Pub. L. 105-206, Sec. 6005(b)(5)(A), substituted
''Aggregation and ordering rules'' for ''Coordination with
individual retirement accounts'' in heading and amended text
generally. Prior to amendment, text read as follows: ''Section
408(d)(2) shall be applied separately with respect to Roth IRAs and
other individual retirement plans.''
Subsec. (d)(6). Pub. L. 105-206, Sec. 6005(b)(6)(A), added par.
(6).
Subsec. (d)(7). Pub. L. 105-206, Sec. 6005(b)(7), added par. (7).
Subsec. (f). Pub. L. 105-206, Sec. 6005(b)(9), added subsec. (f).
EFFECTIVE DATE OF 2006 AMENDMENT
2006 - Pension Protection Act of 2006 (P.L. 109-280)
SEC. 824. ALLOW DIRECT ROLLOVERS FROM RETIREMENT PLANS TO ROTH IRAS.
(c) <<NOTE: 26 USC 408A note.>> Effective Date.--The amendments made
by this section shall apply to distributions after December 31, 2007.
EFFECTIVE DATE OF 2006 AMENDMENT
2006 - P.L. 109-222
SEC. 512. CONVERSIONS TO ROTH IRAS.
(c) Effective Date.--The <<NOTE: 26 USC 408A note.>> amendments made
by this section shall apply to taxable years beginning after December
31, 2009.
EFFECTIVE AND TERMINATION DATES OF 2001 AMENDMENT
Amendment by Pub. L. 107-16 applicable to taxable years beginning
after Dec. 31, 2005, see section 617(f) of Pub. L. 107-16, set out
as a note under section 402 of this title.
Amendment by Pub. L. 107-16 inapplicable to taxable, plan, or
limitation years beginning after Dec. 31, 2010, and the Internal
Revenue Code of 1986 to be applied and administered to such years
as if such amendment had never been enacted, see section 901 of
Pub. L. 107-16, set out as a note under section 1 of this title.
EFFECTIVE DATE OF 1998 AMENDMENTS
Amendment by Pub. L. 105-277 effective as if included in the
provision of the Internal Revenue Service Restructuring and Reform
Act of 1998, Pub. L. 105-206, to which such amendment relates, see
section 4002(k) of Pub. L. 105-277, set out as a note under section
1 of this title.
Amendment by section 6005(b)(1)-(7), (9) of Pub. L. 105-206
effective, except as otherwise provided, as if included in the
provisions of the Taxpayer Relief Act of 1997, Pub. L. 105-34, to
which such amendment relates, see section 6024 of Pub. L. 105-206,
set out as a note under section 1 of this title.
Pub. L. 105-206, title VII, Sec. 7004(b), July 22, 1998, 112
Stat. 833, provided that: ''The amendment made by this section
(amending this section) shall apply to taxable years beginning
after December 31, 2004.''
EFFECTIVE DATE
Section applicable to taxable years beginning after Dec. 31,
1997, see section 302(f) of Pub. L. 105-34, set out as an Effective
Date of 1997 Amendment note under section 219 of this title.
References
SECTION REFERRED TO IN OTHER SECTIONS
This section is referred to in sections 25B, 219, 402A, 408, 4973
of this title.
