Rev. Proc. 2026-25 provides a gift tax filing safe harbor for certain cash contributions by individual donors to Trump accounts. The IRS is addressing a potential filing burden created by distribution restrictions during the account’s growth period, which otherwise could have raised future-interest concerns and required gift tax reporting for many donors who owe no transfer tax.

As background, Trump accounts are new §530A savings vehicles created by the OBBBA for children under age 18. During the growth period (before the child turns 18), Trump accounts are subject to their own contribution, investment, and distribution rules. In general, an annual $5,000 limit on non-exempt contributions applies, indexed for inflation after 2027. Children born in 2025 through 2028 may also receive a $1,000 federal pilot program contribution. After the child turns 18, traditional IRA rules generally apply.

Safe Harbor Provided

Under Rev. Proc. 2026-25, qualifying contributions to Trump accounts are treated as completed gifts and not future interests, allowing the §2503(b) annual exclusion to apply. Donors who meet the safe harbor do not need to file a Form 709 gift tax return solely for these contributions.

Safe Harbor Requirements

• The donor must be an individual.
• The donor’s only taxable gifts for the year are cash contributions to one or more Trump accounts, made before the beneficiary turns 18.
• Total gifts to each beneficiary, including the Trump account contribution, do not exceed the annual exclusion amount ($19,000 for 2026).
• The contributions generate no gift or GST tax after applying the donor’s remaining applicable credit or GST exemption.
• No Form 709 is otherwise required or filed for the year, including for GST allocation, portability, or other reasons.

What to Watch

No election or filing is required to take advantage of the safe harbor, but donors should retain contribution records.

If gifts to any beneficiary exceed the annual exclusion, the safe harbor is unavailable for that year and all gifts must be reported, with Trump account contributions reported as future interests. Additionally, a donor filing Form 709 for another reason cannot rely on the safe harbor for that year’s Trump account contributions.

More information on Trump accounts can be found HERE. Please reach out with any questions or concerns on how you may be impacted.

Published: 07/01/2026

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