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Gift and GST Reporting for Trump Accounts

Last week, we posted an article about Trump Accounts and the use of Form 4547 to establish a Trump Account. The article can be viewed here: A long-time attendee of our programs asked an interesting question that we wanted to share with you. The person asked if, at least until such time that Congress enacts a technical correction, an individual who made a contribution to a Trump Account for the benefit of the account beneficiary is required to file Form 709, United States Gift (and Generation-Skipping Transfer) Tax Return. The answer is yes – at least until a technical correction is passed by Congress for the reason discussed below.

The statutory language that governs Trump Accounts does not include a provision that characterizes contributions as gifts of a present interest. This results in contributions to Trump Accounts not qualifying for the annual gift exclusion and requiring the donor to file a federal gift tax return. In contrast, when Congress enacted “529 accounts,” a provision was added to the statutory language describing the gift tax consequences of a gift to a 529 account stating that the contribution “shall be treated as a completed gift to such beneficiary which is not a future interest in property,” thereby, qualifying the contribution to the 529 account for the annual exclusion from the gift tax and the GST tax.

Failure to include such language in the Trump Account statute was likely an oversight. The American College of Trust and Estate Counsel (“ACTEC”) submitted comments to the IRS on November 10, 2025 (while reiterating its concerns on January 12, 2026, when comments were again submitted), with respect to Notice 2025-68, which provides notice of the intent to issue regulations with respect to the establishment, operation and reporting of Trump Accounts. More specifically, ACTEC expressed its concern about the gift and GST tax treatment of individual contributions to Trump Accounts and recommended a technical correction that, for purposes of chapters 12 (gift tax) and 13 (GST tax), would treat the contribution to a Trump Account as a present interest in property.

Register now for the May & June “Fundamentals of Flow-Through” programs, as well as our complimentary webinar on April 29, 2026. Brush up on your skills in partnership, LLC and S corporation taxation with one of our two virtual 3-day sessions of our newly enhanced Fundamentals of Flow-Through® program. They’re scheduled for May 19-21 and June 23-25; Early-Bird registration now available!

None of the authors is rendering legal, accounting or other professional advice. If such advice is required, it is strongly recommended that a professional advisor be engaged.

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