the distributions out of the accounts with respect to which additional tax was imposed under section 224(f)(2), and (B) the excess (if any) of— (i) the maximum amount allowable as a deduction under section 224(b) for the taxable year, over (ii) the amount contributed to the accounts for the taxable year. For purposes of this subsection, any contribution which is distributed out of the FRAME account in a distribution to which section 224(f)(3) applies shall be treated as an amount not contributed. . (d) Tax on prohibited transactions (1) Section 4975(c) of such Code is amended by adding at the end the following new paragraph: (7) Special rule for FRAME accounts An individual for whose benefit a FRAME account (within the meaning of section 224(d)) is established shall be exempt from the tax imposed by this section with respect to any transaction concerning such account (which would otherwise be taxable under this section) if, with respect to such transaction, the account ceases to be a FRAME account by reason of the application of section 224(e)(2) to such account. . (2) Section 4975(e)(1) of such Code is amended by redesignating subparagraphs (F) and (G) as subparagraphs (G) and (H), respectively, and by inserting after subparagraph (E) the following new subparagraph: (F) a FRAME account described in section 224(d), . (e) Failure To provide reports on FRAME accounts Section 6693(a)(2) of such Code is amended by redesignating subparagraphs (D) and (E) as subparagraphs (E) and (F), respectively, and by inserting after subparagraph (C) the following new subparagraph: (D) section 224(g) (relating to FRAME accounts), . (f) Clerical amendment The table of sections for part VII of subchapter B of chapter 1 of such Code is amended by striking the last item and inserting the following: Sec. 224. FRAME accounts. Sec. 225. Cross reference. . (g) Effective date The amendments made by this section shall apply to taxable years beginning after the date of the enactment of this Act. 3. FRAME contribution credit (a) In general