The IRS has issued Notice 2025-68 (Notice) to provide preliminary guidance regarding Trump Accounts in anticipation of proposed regulations that will be issued in the presumably near future.

Trump Accounts in general

Established as part of the One Big Beautiful Bill Act, Trump Accounts are traditional IRAs established for individuals who have not attained age 18 and who have a Social Security number. Trump Accounts are intended to promote tax-favorable savings and investment beginning in childhood.

During the period that ends before Jan. 1 of the calendar year in which the individual attains age 18 (Growth Period), at which point the regular traditional IRA rules will apply, the following special rules will be applicable:

• Contributions - The earliest a contribution can be made to a Trump Account will be July 4, 2026. There will be a $5,000 (subject to COLA increases after 2027) maximum contribution per year, including both contributions made by parents and/or relatives, and new IRS Section 128 employer contributions (limited to $2,500 per employee per year (COLA adjusted after 2027), and non-taxable to the employee). The election for a $1,000 one-time Pilot Program contribution to be made by the government will not count toward the annual limit. No earned income requirement will apply for contributions, the individual for whom the Trump Account is established will generally not be taxable on contributions made to their Trump Account, and contributions made by individuals to Trump Accounts will not be tax-deductible. Under the Pilot Program, the government will establish and fund a Trump Account for children born after 2024 and before 2029 who are U.S. citizens with a Social Security Number. A Trump Account established under the Pilot Program can be rolled over in a trustee-to-trustee transfer to a rollover Trump Account to which other contributions can be made by family members and employers under Internal Revenue Code (IRC) Section 128.
• Investments - Trump Accounts will only be permitted to be invested in a mutual fund or exchange traded fund that tracks an index of primarily U.S. companies (e.g., an S&P fund), does not utilize leverage, and does not have annual fees and expenses in excess of 0.1% of the amount invested.
• Distributions - Generally, non-rollover distributions from Trump Accounts will not be permitted during the Growth Period. When permissibly made, distributions in excess of basis (i.e., contribution amounts) will be taxable; however, Pilot Program contributions and employer contributions under IRC Section 128 will not generate basis. Trump Accounts will not be combined with non-Trump Account IRAs for taxation of distributions purposes.

The Notice provides guidance in Q&A format under the following headings:

• Establishment
• Pilot Program
• Contributions
• Eligible Investments
• Distributions
• Reporting
• Coordination with IRA Rules
• Qualified General Contributions

The Notice specifies that proposed regulations will follow, and requests comments from the public.

What does CohnReznick think?

In light of the tight timetable, the Notice provides useful guidance, and goes as far as to request public comments, not only in general, but specifically with respect to a number of the particular Q&As. In this regard, the Notice specifies that the proposed regulations are anticipated to be consistent with the guidance provided in the Notice. The public comment period will end on Feb. 20, 2026. Thus, the IRS will be looking to public comments in attempting to issue timely proposed and ultimately final regulations governing the operation of and requirements for Trump Accounts. The Notice further advises that the IRS is in the process of developing Form 4547 (Trump Account Elections).