Treasury and the IRS issued Revenue Procedure 2026-25 on June 29, 2026, providing a gift tax reporting safe harbor for certain contributions to Trump Accounts. Trump Accounts are the new statutory savings vehicle created under the Working Families Tax Cuts provisions of the One, Big, Beautiful Bill. The safe harbor removes a real friction point that had been stalling family contribution decisions: if the requirements of the revenue procedure are satisfied, an individual donor’s contribution to a Trump Account will not trigger gift tax reporting for that year.
Counsel advising families on Trump Account funding strategy should read Revenue Procedure 2026-25 in full before advising on a specific contribution, because the safe harbor is conditioned on meeting requirements the revenue procedure sets. The news release identifies the relief without listing the specific conditions, so the operative document is the Rev. Proc. itself.
Why this safe harbor exists
A Trump Account is funded by contributions from the parent or guardian who opens the account and, in most family structures, from other adults in the child’s life. Any transfer of property to another person (including to a savings vehicle owned by another person) is potentially a gift for federal gift tax purposes under IRC Section 2501. If the transfer exceeds the annual exclusion amount, or if it otherwise falls outside a statutory exception, the donor is generally required to report the gift on Form 709.
Before this guidance, a grandmother, an uncle, or a family friend who wanted to contribute to a child’s Trump Account faced the same threshold question as any other family gift: does this transfer need to be reported, and if so, how does it interact with the donor’s lifetime exemption? IRS CEO Frank J. Bisignano’s stated concern in the release, that potential donors “worried such donations would trigger the gift tax reporting rules,” reflects a real planning obstacle. The safe harbor addresses that obstacle for contributions that fit within its conditions.
How the account and the elections work
The pathway to open and fund a Trump Account runs through Form 4547, Trump Account Election(s). A parent, guardian, or other authorized individual completes Form 4547 through the IRS Individual Online Account. The election to open the initial Trump Account must be made before the calendar year in which the child turns 18.
For a U.S. citizen child born in 2025 through 2028, the parent or other qualified individual may check a box on Form 4547 to elect a $1,000 pilot program contribution to the account. This $1,000 pilot contribution is a distinct election. Counsel should treat it as a use it or lose it planning item for eligible birth years.
Additional information for account holders and prospective donors is at trumpaccounts.gov. General information on Working Families Tax Cuts provisions is on IRS.gov.
Why this matters for tax pros
Three practice level takeaways for practitioners advising families with young children or grandchildren.
First, revisit the family gifting conversation. If you have clients who use annual exclusion gifting as part of a broader estate plan (grandparents making the annual gifts, for example, or high net worth families layering contributions across 529 plans and other vehicles), Trump Account contributions belong on the same worksheet. The safe harbor changes the reporting analysis, not the underlying gift analysis. Contributions still involve a transfer of value. Counsel should confirm that the safe harbor’s requirements are met before advising a client to skip Form 709 for the year.
Second, coordinate the funding sources. Trump Account contributions from multiple donors in the same year raise the same coordination issue as coordinated 529 gifting. Counsel should confirm which donors are contributing, in what amounts, and whether each contribution independently qualifies for the safe harbor or whether one or more donors will need to file Form 709 for other unrelated gifts made in the same year. The safe harbor addresses the Trump Account contribution; it does not sweep in every gift the donor made that year.
Third, document the pilot contribution eligibility. The $1,000 pilot program contribution requires a U.S. citizen child born 2025 through 2028 and an eligible electing individual. That documentation (birth certificate, citizenship confirmation, and the identity of the individual making the election) should live in the client’s engagement file. If eligibility is later questioned, the contemporaneous record is what supports the position.
A note on the underlying statutory framework. Trump Accounts are new. The gift tax reporting safe harbor announced here is guidance from Treasury and the IRS interpreting how existing gift tax rules apply to a new vehicle. That interpretive posture matters for reliance purposes. Rev. Proc. 2026-25 is authoritative guidance; counsel may rely on it when its terms are met. But the underlying Section 2501 gift tax analysis remains what it is, and counsel should not confuse a reporting safe harbor with a substantive exclusion from gift tax treatment.
Finally, watch for follow up guidance. Trump Accounts as a vehicle will generate additional guidance across investment, distribution, and coordination with other tax favored accounts. Practitioners advising on family savings strategy should treat this Rev. Proc. as the first substantive guidance on the vehicle, not the last.
THE TTR TAKE
The IRS just made it materially easier for grandparents, aunts, uncles, and family friends to fund a child’s Trump Account without the Form 709 conversation getting in the way. If you advise families on gifting strategy, put Rev. Proc. 2026-25 on your desk before contribution season and confirm every donor’s contribution actually fits inside the safe harbor’s conditions.
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Direct link to the official Internal Revenue Service announcement.