The U.S. Department of the Treasury and the IRS have issued proposed regulations, announced in IR-2026-90, providing additional guidance for employers that make contributions to Trump Accounts for employees or their dependents.

The proposal, which is not yet final, addresses several aspects of employer Trump Account contribution programs, including the $2,500 annual exclusion, plan requirements, and nondiscrimination rules.

What Are Trump Accounts?

Trump Accounts are tax-advantaged individual retirement accounts established for eligible individuals under age 18. While several types of contributions may be made to the accounts, employers can contribute to an employee’s Trump Account or the Trump Account of an employee’s dependent, subject to applicable limits and requirements.

Clarifying the $2,500 Limit

Under the proposed regulations, qualifying employer contributions to Trump Accounts generally may be excluded from an employee’s gross income up to $2,500 per calendar year, with the amount indexed for inflation after 2027.

Importantly, the $2,500 limit applies per employee, not per dependent. An employee with multiple eligible dependents may allocate contributions among their Trump Accounts, but the employee’s total annual exclusion remains limited to $2,500. The same overall exclusion applies regardless of how many employers an individual has. Importantly, the exclusion only applies to income tax withholding – the contributions would still be subject to Federal Insurance Contribution Act (FICA) tax withholding and employer contribution rules. Contributions exceeding the limit generally must be included in the employee’s gross income.

Other Considerations

The proposal also provides guidance for employers establishing Trump Account contribution programs, including written plan requirements, employee notifications and reporting, whether and how an employee may make elective contributions through a cafeteria plan, and applicable nondiscrimination requirements.

What Happens Next?

These regulations remain proposed and are subject to change before being finalized. Treasury and the IRS are accepting public comments through September 25, 2026, and a public hearing is scheduled for October 15, 2026.

The proposed regulations would generally apply to plan years beginning on or after the date the final regulations are published. However, taxpayers may rely on the proposed rules for earlier plan years.

Preparing for Final Regulations

Employers considering Trump Account contributions should continue monitoring the rulemaking process as Treasury and the IRS consider public feedback and work toward final regulations.

Contact your CRI advisor to discuss how the proposed Trump Account contribution rules could affect your organization and employee benefit planning.