Trump Accounts and Contribution Pilot Program Guidance

 

The IRS provides interim guidance on the Trump Accounts, which are a new type of individual retirement account for eligible children. Certain definitions relating to Trump Accounts, election rules to open an initial Trump Account by an authorized individual for an eligible individual, and rules for who is the responsible party for the initial Trump Account once the account has been opened. Trump Accounts and the Trump Account Pilot Program were established under the One Big Beautiful Bill Act (OBBB Act) enacted on July 4, 2025. The regulations are proposed to apply on or after January 1, 2026.

Background

The OBBB Act enacted provisions that created a Trump account for an eligible individual. A Trump account is subject to certain special rules that do not apply to other types of individual retirement accounts during the growth period, which is the period that begins when an initial Trump account is established and ends on December 31st of the year in which the account beneficiary of the initial Trump account reaches the age of 17.

In addition, the Trump account pilot program provides for a one-time $1,000 pilot program contribution to the Trump account of an eligible child with respect to whom an election is made. The qualifications to be an eligible child are less restrictive than those to be an eligible individual. Finally, a Trump account contribution program allows employers to contribute to a Trump account for an employee or an employee's dependent.

 

General Requirements and Election to Open an Account

A Trump account is either (1) an initial Trump account, created or organized by the Treasury Secretary for an eligible individual or (2) a rollover Trump account, which is an account created during the growth period and funded by a qualified rollover contribution from the account beneficiary's existing Trump account. An individual can have only one Trump account containing funds at any given time. The election to open an initial Trump Account must be made by an authorized individual on Form 4547, Trump Account Election(s), or through the online Form 4547, Trump Account Election Form. Additionally, the election form also provides an opportunity for the authorized individual to request the $1,000 pilot program contribution from the Secretary for an eligible child.

 

Contribution Pilot Program

A pilot program election with respect to an eligible child must be made by a pilot program-electing individual so that the Secretary can make the $1,000 pilot program contribution into the Trump account of an eligible child. An eligible child must:

· be born in calendar year 2025, 2026, 2027, or 2028,
· be a United States citizen,
· have been issued a Social Security Number, and
· be someone for whom no prior pilot program election has been made by any individual and processed by the Secretary of the Treasury.

An election may be made on the day that a child becomes eligible, and the last day to make the election is December 31st of the calendar year in which the eligible child attains age 17. In addition, only the first pilot program contribution election processed by the IRS will result in a $1,000 contribution to the eligible child's Trump account.