Page:United States Statutes at Large Volume 120.djvu/396

 PUBLIC LAW 109–222—MAY 17, 2006

120 STAT. 365

‘‘(F) made pursuant to a classified or confidential contract described in section 6050M(e)(3), ‘‘(G) made by a political subdivision of a State (or any instrumentality thereof) which makes less than $100,000,000 of such payments annually, ‘‘(H) which is in connection with a public assistance or public welfare program for which eligibility is determined by a needs or income test, and ‘‘(I) to any government employee not otherwise excludable with respect to their services as an employee. ‘‘(3) COORDINATION WITH OTHER SECTIONS.—For purposes of sections 3403 and 3404 and for purposes of so much of subtitle F (except section 7205) as relates to this chapter, payments to any person for property or services which are subject to withholding shall be treated as if such payments were wages paid by an employer to an employee.’’. (b) EFFECTIVE DATE.—The amendment made by this section shall apply to payments made after December 31, 2010.

26 USC 3402 note.

SEC. 512. CONVERSIONS TO ROTH IRAS.

(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

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26 USC 408A.

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