(2) QUALIFIED ROLLOVERS.— 
(A) IN GENERAL.—Under regulations pre-
scribed by the Secretary of the Treasury in con-
sultation with the Executive Director, after an 
account holder of a KIDS Account attains the 
age of 18, such account holder may elect to 
make a rollover contribution from such account 
holder’s account to— 
(i) a Roth IRA, or 
(ii) a qualified tuition program (within 
the meaning of section 529 of the Internal 
Revenue Code of 1986). 
(B) LIMITATION.—No rollover contribution 
may be made under this paragraph to the ex-
tent that such rollover contribution would cause 
the balance of such account holder’s account to 
be less than the amount of the contribution 
transferred to such account under section 
2(d)(1)(A) before such account holder— 
(i) attains age 59 1⁄2, 
(ii) dies, or 
(iii) becomes disabled (within the 
meaning of section 72(m)(7). 
(c) 100 PERCENT TAX ON GOVERNMENT CONTRIBU-
TIONS.—
(1) KIDS ACCOUNTS.— 
(A) IN
GENERAL.—In the case of any 
amount distributed from a KIDS Account 
which is attributable to contributions made 
under section 2(d) and which would be includ-
ible in gross income (but for this paragraph)— 
(i) such amount shall not be includible 
in gross income, and 
(ii) the tax imposed under chapter 1 
of the Internal Revenue Code of 1986 on 
the distributee for the taxable year in 
which such amount is distributed shall be 
increased by 100 percent of such amount. 
(B) ORDERING RULES.—For purposes of 
this paragraph, distributions from KIDS Ac-
counts shall be treated as made from amounts 
attributable to contributions made under sec-
tion 3(f) and from earnings before made from 
amounts attributable to contributions made 
under section 2(d). 
(2) ROTH IRAS.—Section 408A(d) of the Inter-
nal Revenue Code of 1986 (relating to distribution 
rules) is amended by adding at the end the following 
new paragraph:
‘‘(8) 100 PERCENT TAX ON DISTRIBUTIONS RE-
LATED
TO
CERTAIN
GOVERNMENT
CONTRIBU-
TIONS.— 
‘‘(A) IN GENERAL.—In the case of any dis-
tribution which is attributable to contributions 
made under section 2(d)of the America Saving 
for Personal Investment, Retirement, and Edu-
cation Act of 2005 and which would be includ-
ible in gross income (but for this paragraph)— 
‘‘(i) such amount shall not be includ-
ible in gross income, and 
‘‘(ii) the tax imposed under chapter 1 
on the distributee for the taxable year in 
which such amount is distributed shall be 
increased by 100 percent of such amount. 
‘‘(B) ORDERING RULES.—For purposes of 
this paragraph, distributions shall be treated as 
made from amounts attributable to other con-
tributions and from earnings before made from 
amounts attributable to contributions made 
under section 2(d) of the America Saving for 
Personal Investment, Retirement, and Edu-
cation Act of 2005.’’. 
(3) QUALIFIED
TUITION
PROGRAMS.—Section 
529(c)(3) of the Internal Revenue Code of 1986 (re-
lating to distributions) is amended by adding at the 
end the following new subparagraph: 
‘‘(E) 100 PERCENT
TAX
ON
DISTRIBU-
TIONS
RELATED
TO
CERTAIN
GOVERNMENT 
CONTRIBUTIONS.— 
‘‘(i) IN GENERAL.—In the case of any 
distribution which is attributable to con-
tributions made under section 2(d) of the 
America Saving for Personal Investment, 
Retirement, and Education Act of 2005 
and which would be includible in gross in-
come (but for this subparagraph)— 
‘‘(I) such amount shall not be in-
cludible in gross income, and 
‘‘(II) the tax imposed under 
chapter 1 on the distributee for the 
taxable year in which such amount is 
distributed shall be increased by 100 
percent of such amount. 
‘‘(ii) ORDERING
RULES.—For pur-
poses of this paragraph, distributions shall 
be treated as made from amounts attrib-
utable to other contributions and from 
earnings before made from amounts attrib-
utable to contributions made under section