As the Trump account go-live date approaches, regulatory guidance is arriving on several fronts. On June 29, the IRS issued Revenue Procedure 2026-25, providing welcome relief from gift and generation-skipping transfer (GST) tax filing requirements for individuals who contribute to Trump accounts.
Practitioners had been concerned that contributions to a Trump account would trigger the gift tax reporting rules. Unlike Section 529 plans, the Trump account statutory framework does not address how contributions are treated for gift tax, GST tax, or gift tax reporting purposes.
Revenue Procedure 2026-25 resolves that uncertainty with a safe harbor: qualifying contributions are treated as gifts eligible for the annual gift tax exclusion. Under the safe harbor, an individual donor is not required to file a gift tax return if all of the following are met:
- The donor’s only taxable gifts are cash contributions to Trump accounts for beneficiaries under age 18;
- The donor’s total gifts to each beneficiary for the calendar year, including the contribution to that beneficiary’s Trump account, do not exceed the annual gift tax exclusion ($19,000 for 2026) or the lifetime gift, estate, and GST tax exemption (currently $15 million, indexed annually); and
- No gift tax return is otherwise required or filed by the donor for that year.
If all three conditions are met, each contribution is treated as a completed gift to the beneficiary rather than a future interest in property that would require a return. If any condition is not met (for example, if contributions to a single beneficiary exceed the annual exclusion), the donor must file gift tax returns for every Trump account beneficiary who received a contribution from the donor that year.
This guidance is great news to donors and also a necessary reprieve for the government. The IRS received roughly 300,000 gift tax returns for the 2025 fiscal year versus nearly 6 million elections to open Trump accounts as of June 4, 2026. Great work IRS!
If each of the requirements specified in section 4.02 of this revenue procedure is met for a calendar year in which a taxpayer makes contributions to one or more Trump accounts, each Trump account contribution made by the taxpayer during that calendar year will be treated as a completed gift to the account beneficiary that is not a future interest in property and to which the annual exclusion applies for purposes of gift tax, GST tax and gift tax reporting. As a result, taxpayers within the scope of section 4 of this revenue procedure will not be required to file a gift tax return reporting such contributions.
