in section 530A(c)(1)) and who elects the application of this paragraph for a taxable year, gross income of the individual for the taxable year does not include a qualified Medisave account funding distribution to the extent such distribution is otherwise includible in gross income. (B) Qualified Medisave account funding distribution For purposes of this paragraph, the term qualified Medisave account funding distribution means a distribution from an individual retirement plan (other than a plan described in subsection (k) or (p)) of the employee to the extent that— (i) such distribution is contributed to the Medisave account of the individual in a direct trustee-to-trustee transfer, and (ii) such distribution— (I) when added to previous contributions to the Medisave account for the calendar year does not exceed the limitation amount specified in section 530A(b)(1), and (II) when added to the balance of the Medisave account, exceeds the limitation amount specified in section 530A(b)(2). (C) One-time transfer An individual may make an election under subparagraph (A) only for one qualified Medisave account funding distribution during the lifetime of the individual. Such an election, once made, shall be irrevocable. (D) Application of section 72 Notwithstanding section 72, in determining the extent to which an amount is treated as otherwise includible in gross income for purposes of subparagraph (A), the aggregate amount distributed from an individual retirement plan shall be treated as includible in gross income to the extent that such amount does not exceed the aggregate amount which would have been so includible if all amounts from all individual retirement plans were distributed. Proper adjustments shall be made in applying section 72 to other distributions in such taxable year and subsequent taxable years. . (5) Failure of employer to make comparable contributions (A) Section 4980G(a) of such Code is amended by striking health savings account and inserting Medisave account . (B) Section 4980G(c) of such Code is