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New Tax-Advantaged Savings Accounts for Children: Trump Accounts Expected to Go Live in 2026

By Sasha Rousseau (Law Clerk for the Employee Benefits and Executive Compensation Practice Group) & Kellie M. Thomas on December 10, 2025
Posted in Big Beautiful Bill, COLA Cost of living Adjustment, IRA, IRS Guidance, OBBBA, One Big Beautiful Bill, Trump, Trump Account

Takeaways

A provision of the One Big Beautiful Bill Act created “Trump Accounts,” a new type of individual retirement account (IRA) for children. Starting in 2026, a Trump Account may be opened for any child who is a U.S. citizen, has a Social Security number, and who will still be under age 18 by the end of the calendar year.

Related Links

IRS and Treasury Guidance

  • Final regulations are not yet available, but Notice 2025-68 summarizes how Trump Accounts will work.
  • The IRS website directs taxpayers to a new website, trumpaccounts.gov (not yet active), for further information about the accounts.

Jackson Lewis Resources

  • New Tax-Favored Benefit for Employees with Children – Jackson Lewis

Article

Creating a Trump Account

To create a Trump Account, an authorized person, such as a parent or guardian, must make an election by filing a Form 4547 Trump Account Election, which may be filed with the authorized person’s 1040. Once the election is filed, the Treasury Department will create a Trump Account for the child. The form 4547 is not yet finalized or available on the Internal Revenue Service website, but is expected to be available for filing with tax returns due in 2026. Money can be contributed to Trump Accounts starting on July 4, 2026.

Special “Growth Period” Opportunities and Restrictions

The growth period for the account is from January 1 of the year the child is born, or from the year the account is created, until December 31 of the year before the child turns 18. Special restrictions apply during the growth period:

  • Funds in a Trump Account can be invested only in eligible investments. Generally, an “eligible investment” is a mutual fund or exchange-traded fund that tracks an index of primarily U.S. companies, does not leverage, and has annual fees and expenses of less than 0.1% of the fund balance.
  • Trump Accounts have an aggregate annual contribution limit of $5,000 (indexed after 2027) per account/child. This limit is separate from the limits for any other retirement account.
  • Trump Accounts are not allowed to make distributions during the growth period.
  • Individuals may not take tax deductions for Trump Account contributions.
  • The trustees of Trump Accounts have similar but not identical reporting requirements to the trustees of other IRAs.

After the growth period ends, these special restrictions no longer apply, and generally, the rules under Internal Revenue Code Section 408 governing traditional IRAs apply instead.

Making Contributions to a Trump Account

During the growth period, five types of contributions can be made to a Trump Account:

  •  Under a pilot program, the federal government will deposit $1,000 into the Trump Accounts of children born between January 1, 2025, and December 31, 2028. (This $1,000 will not count towards the account’s annual contribution limit.)
  • Individuals, such as the beneficiary, parents, or other people, may contribute with after-tax dollars up to the annual limit per account/child. A parent or guardian may also make pre-tax contributions through a Section 125 plan to their dependent’s account(s), if their employer offers it.
  • Employers may contribute up to $2,500 annually (indexed after 2027) to an employee’s or the employee’s dependent’s Trump Account, if they formally establish an employer-sponsored plan. These contributions count toward the yearly limit but are not considered taxable income for the employee. The notice clarifies that if an employee has multiple children with Trump Accounts, the employer’s total contribution remains capped at $2,500.
  • Governmental entities and charities may make Qualified General Contributions to a qualified class of beneficiaries’ accounts. Classes are either those born in specified years, who live in specified states, or all beneficiaries in the growth period.
  • Qualified rollover contributions are allowed.

The Jackson Lewis Employee Benefits Practice Group members can assist if you have questions or need assistance. Please contact a Jackson Lewis employee benefits team member or the Jackson Lewis attorney with whom you regularly work. Subscribe to the Benefits Law Advisor Blog.

Tags: IRS, One Big Beautiful Bill, Trump Account
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Photo of Kellie M. Thomas Kellie M. Thomas

Kellie M. Thomas is co-leader of the firm’s Employee Benefits practice group. Her goal with every client is to provide practical and straightforward advice that breaks down and makes accessible the myriad issues and considerations arising under ERISA, the Internal Revenue Code (including…

Kellie M. Thomas is co-leader of the firm’s Employee Benefits practice group. Her goal with every client is to provide practical and straightforward advice that breaks down and makes accessible the myriad issues and considerations arising under ERISA, the Internal Revenue Code (including Sections 280G, 401(k), 403(b), 409A and 457(b) and (f)), the Affordable Care Act, COBRA, HIPAA, and the various other federal and state laws and regulations affecting benefit plans.

As part of her day to day advice and counsel work, Kellie regularly reviews, drafts and amends self- and fully-insured health and welfare plans; cafeteria plans; qualified and non-qualified retirement plans; employment, consulting, severance and change in control agreements; and stock option and other equity-based compensation plans. She drafts and prepares submissions under the Internal Revenue Service’s Employee Plans Compliance Resolution System and the Department of Labor’s Voluntary Fiduciary Correction Program, and reviews and qualifies proposed Qualified Domestic Relations Orders and Qualified Medical Child Support Orders. Kellie also counsels on corporate governance and fiduciary matters, including the structure and duties of retirement and benefit plan committees.

Kellie also has extensive experience advising on all benefits-related aspects of corporate transactions, from due diligence and transaction document negotiations to benefits integration following a closing. She particularly enjoys building relationships during the transaction process that continue after the deal is done.

Read more about Kellie M. Thomas
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