(5) EFFECTIVE
DATE.—This subsection shall 
take effect on the date of the enactment of this Act. 
(d) ALLOW CERTAIN PLAN TRANSFERS AND MERG-
ERS.— 
(1) IN GENERAL.—Section 414 of the Internal 
Revenue Code of 1986 is amended by adding at the 
end the following new subsection: 
‘‘(z) CERTAIN PLAN TRANSFERS AND MERGERS.— 
‘‘(1) IN GENERAL.—Under rules prescribed by 
the Secretary, except as provided in paragraph (2), 
no amount shall be includible in gross income by 
reason of— 
‘‘(A) a transfer of all or a portion of the 
accrued benefit of a participant or beneficiary, 
whether or not vested, from a church plan that 
is a plan described in section 401(a) or an an-
nuity contract described in section 403(b) to an 
annuity contract described in section 403(b), if 
such plan and annuity contract are both main-
tained by the same church or convention or as-
sociation of churches, 
‘‘(B) a transfer of all or a portion of the 
accrued benefit of a participant or beneficiary 
from an annuity contract described in section 
403(b) to a church plan that is a plan described 
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in section 401(a) or an annuity contract de-
scribed in section 403(b), if such plan and an-
nuity contract are both maintained by the same 
church or convention or association of churches, 
or 
‘‘(C) a merger of a church plan that is a 
plan described in section 401(a), or an annuity 
contract described in section 403(b) with an an-
nuity contract described in section 403(b), if 
such plan and annuity contract are both main-
tained by the same church or convention or as-
sociation of churches. 
‘‘(2) LIMITATION.—Paragraph (1) shall not 
apply to a transfer or merger unless the partici-
pant’s or beneficiary’s total accrued benefit imme-
diately after the transfer or merger is equal to or 
greater than the participant’s or beneficiary’s total 
accrued benefit immediately before the transfer or 
merger, and such total accrued benefit is nonforfeit-
able after the transfer or merger. 
‘‘(3) QUALIFICATION.—A plan or annuity con-
tract shall not fail to be considered to be described 
in sections 401(a) or 403(b) merely because such 
plan or annuity contract engages in a transfer or 
merger described in this subsection. 
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‘‘(4) DEFINITIONS.—For purposes of this sub-
section: 
‘‘(A) CHURCH OR CONVENTION OR ASSO-
CIATION OF CHURCHES.—The term ‘church or 
convention or association of churches’ includes 
an organization described in subparagraph (A) 
or (B)(ii) of subsection (e)(3). 
‘‘(B) ANNUITY CONTRACT.—The term ‘an-
nuity contract’ includes a custodial account de-
scribed in section 403(b)(7) and a retirement 
income account described in section 403(b)(9). 
‘‘(C) ACCRUED BENEFIT.—The term ‘ac-
crued benefit’ means— 
‘‘(i) in the case of a defined benefit 
plan, the employee’s accrued benefit deter-
mined under the plan, and 
‘‘(ii) in the case of a plan other than 
a defined benefit plan, the balance of the 
employee’s account under the plan.’’. 
(2) EFFECTIVE DATE.—The amendment made 
by this subsection shall apply to transfers or merg-
ers occurring after the date of the enactment of this 
Act. 
(e) INVESTMENTS BY CHURCH PLANS IN COLLEC-
TIVE TRUSTS.— 
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(1) IN GENERAL.—In the case of— 
(A) a church plan (as defined in section 
414(e) of the Internal Revenue Code of 1986), 
including a plan described in section 401(a) of 
such Code and a retirement income account de-
scribed in section 403(b)(9) of such Code, and 
(B) an organization described in section 
414(e)(3)(A) of such Code the principal pur-
pose or function of which is the administration 
of such a plan or account, 
the assets of such plan, account, or organization (in-
cluding any assets otherwise permitted to be com-
mingled for investment purposes with the assets of 
such a plan, account, or organization) may be in-
vested in a group trust otherwise described in Inter-
nal Revenue Service Revenue Ruling 81–100 (as 
modified by Internal Revenue Service Revenue Rul-
ings 2004–67, 2011–1, and 2014–24), or any subse-
quent revenue ruling that supersedes or modifies 
such revenue ruling, without adversely affecting the 
tax status of the group trust, such plan, account, or 
organization, or any other plan or trust that invests 
in the group trust. 
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(2) EFFECTIVE
DATE.—This subsection shall 
apply to investments made after the date of the en-
actment of this Act. 
Æ 
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