“ Amendment of ERISA.—Subsection (h) of section 204 of the Employee Retirement Income Security Act of 1974 (29 U.S.C. 1054) is amended to read as follows: `` (h) (1) An applicable pension plan may not be amended so as to provide for a significant reduction in the rate of future benefit accrual unless the plan administrator provides the notice described in paragraph (2) to each applicable individual (and to each employee organization representing applicable individuals) . ”

“ Subparagraph (A) shall apply to plan mergers and other transactions having the effect of a direct transfer, including consolidations of benefits attributable to different employers within a multiple employer plan. `` (5) Except to the extent provided in regulations promulgated by the Secretary of the Treasury, a defined contribution plan shall not be treated as failing to meet the requirements of this subsection merely because of the elimination of a form of distribution previously available thereunder. ”

“ Synthetic equity.—The term `synthetic equity' means any stock option, warrant, restricted stock, deferred issuance stock right, or similar interest or right that gives the holder the right to acquire or receive stock of the S corporation in the future. ”

“ Synthetic equity.—The amount involved with respect to any tax imposed by reason of subsection (a) (4) is the value of the shares on which the synthetic equity is based. `` (C) Special rule during first nonallocation year.—For purposes of subparagraph (A) , the amount involved for the first nonallocation year of any employee stock ownership plan shall be determined by taking into account the total value of all the deemed-owned shares of all disqualified persons with respect to such plan. ”

“ The per share loss adjustment factor shall be the aggregate of all contributions to all electing Settlement Trusts sponsored by such Native Corporation made on or after the first day each trust is treated as an electing Settlement Trust expressed on a per share basis and determined as of the day of each such contribution. ”

“ In general.—If— `` (I) a distribution is made from an individual retirement plan, and `` (II) a rollover contribution is made to an eligible retirement plan described in section 402 (c) (8) (B) (iii) , (iv) , (v) , or (vi) with respect to all or part of such distribution, ``then, notwithstanding paragraph (2) , the rules of clause (ii) shall apply for purposes of applying section 72. ”