OBBBA enacted a new type of §408(a) traditional IRA known as a “Trump Account.” Briefly, a Trump Account is established for the exclusive benefit of an “eligible individual,” who is an individual (i) for whom an election is made to establish a Trump Account, (ii) who has not attained age 18 before the close of the calendar year in which the election is made and (iii) for whom a social security number has been issued before the date of the election. An “authorized individual” (a parent, legal guardian, adult sibling or grandparent of an eligible individual) must elect to establish an initial Trump Account for an eligible individual. Contributions can be made to the Trump Account on or after July 4, 2026, subject to specific investment requirements that are not discussed in this email blast.
On December 2, 2025, the IRS issued Notice 2025-68, stating its intent to issue proposed regulations with respect to Trump Accounts. For purposes of this email blast, we will focus on guidance pertaining to the establishment of and contributions to a Trump Account. (Notice 2025-68 also provides guidance with respect to eligible investments and other issues.) Also posted on the IRS website on January 8, 2026, (and briefly discussed in Notice 2025-68) is a new IRS form. Perhaps someone in the IRS is a history buff with a sense of humor who left an “Easter egg” by mashing ‘45’ and ‘47’ together (the historical significance of which just happens to be the presidencies of Donald Trump) to create new Form 4547, Trump Account Election(s), as the IRS form that an authorized individual must use to establish a Trump Account for an eligible individual. Alternatively, an authorized individual can establish a Trump Account online at www.trumpaccounts.gov.
An authorized individual who is establishing a Trump Account for the benefit of an eligible individual can file Form 4547 at any time, including at the same time the 2025 income tax return for the authorized individual is filed. In fact, the instructions to Form 4547 state that the “fastest, safest, and easiest way to make the election(s) is to file Form 4547 with your current-year e-filed return.” Form 4547 requires the authorized individual to provide the eligible individual’s first and last name, social security number, date of birth, relationship and address.
Trump Accounts offer significant funding flexibility, accepting contributions from individuals (including the eligible individual, the eligible individual’s parents, or any other person), employers, the United States, the District of Columbia, Indian tribal governments, §501(c)(3) organizations for members of a qualified class of account beneficiaries, or as qualified rollover contributions (which are transfers to a rollover Trump Account of the entire amount of the child’s prior Trump Account). The aggregate limitation for individual and employer contributions is $5,000 per year (subject to inflation adjustments after 2027). For eligible individuals who are U.S. citizens with a social security number and born after December 31, 2024, but before January 1, 2029, Treasury will deposit $1,000 into the Trump Account under a “Pilot Program,” if the authorized individual so elects by checking the box on Part III of Form 4547. The Pilot Program is intended to seed the account without the necessity of there being contributions from other sources.
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