With the July 4th launch of Trump accounts just a few months away, guidance cannot come soon enough.  

On March 6th, IRS released two sets of proposed regulations on Trump accounts. This wave of guidance follows Notice 2025-68 and is focused on:

• Procedures for setting up Trump accounts, including who can open the initial Trump account, how the account is opened, and the roles of the parties responsible for the account.  Notably, there is an ordering rule for who can open a Trump account, and an affirmative election is required (no auto-enrollment by the Treasury).

• Rules for claiming the $1,000 starter contribution under the IRS Pilot Program regulations including who is eligible for the contribution, who can elect the contribution, how (Form 4547 or https://www.trumpaccounts.gov) and when the election can be made, and its treatment as a tax overpayment that is refunded to the Trump account.   

  More guidance is pending - these regulations do not address employer contributions to Trump accounts under Code section 128, how employers can allow employees to make pre-tax contributions for their children, or details on the specific requirements for these Trump accounts (following the initial look under Notice 2025-68).

This is just the beginning – stay tuned for our client alert!