The Internal Revenue Service (IRS) and Treasury Department have issued proposed regulations (REG-101355-26) outlining the requirements for making employer contributions to Trump Accounts under Code section 128. The guidance provides the first comprehensive framework for employers interested in offering Trump Account contributions to benefit employees and clarifies several issues that practitioners have been debating since enactment of the One Big Beautiful Bill Act (OBBBA). The proposed regulations also modernize and clarify the nondiscrimination rules applicable…
Overview Under the One Big Beautiful Bill Act (Pub. L. 119‑21), §530A of the Internal Revenue Code (IRC) has introduced Trump accounts—a new, narrowly tailored savings vehicle for children under age 18, generally structured as a modified traditional individual retirement account (IRA). While much of the early discussion and guidance, including the new proposed regulations issued by the IRS on March 6, 2026, has focused on Trump accounts themselves, as well as family and federal…