What Did the IRS Propose?

On August 11, 2026, the Internal Revenue Service (IRS) published a notice of proposed rulemaking (REG-101355-26) implementing new Internal Revenue Code (IRC) section 128, which governs employer contributions to Trump accounts.[1] The proposed regulations provide the first comprehensive regulatory framework for Trump account contribution programs — a key mechanism through which employers can assist employees in funding Trump accounts for their eligible children (or other eligible dependents).[2]

What Are Trump Accounts?

A Trump account is a type of individual retirement account (IRA) established for the exclusive benefit of a child and designated as a “Trump account” at inception. Created by the One Big Beautiful Bill Act (the OBBBA), the account is governed by new Internal Revenue Code (IRC) provisions, including §530A and §128.[1] Trump accounts operate under special rules intended to seed and simplify long-horizon investing for children through the year before they turn 18 — referred to in the rules as the “growth period.” After the growth period, most special Trump account rules fall away, and thereafter the account largely functions like a standard traditional IRA under §408(a).

The Internal Revenue Service announced the 2025 cost-of-living adjustments to the dollar limitations for qualified retirement plans and other benefits, and the Social Security Administration announced its own cost-of-living adjustments for 2025. Most of the dollar limits, including the elective deferral contribution limit for 401(k), 403(b) and 457(b) plans, the…

In Revenue Procedure 2022-40, the IRS recently expanded the determination letter program to allow applications by individually-designed 403(b) plans. This expansion will allow 403(b) plan sponsors to request a determination letter that expresses the IRS’ opinion that the plan’s terms (as stated in the plan document) meet the requirements…

The Internal Revenue Service announced the 2023 cost-of-living adjustments to the dollar limitations for qualified retirement plans and other benefits, and the Social Security Administration announced its own cost-of-living adjustments for 2023.  All of the dollar limits, including the elective deferral contribution limit for 401(k), 403(b) and 457(b) plans, the…

On September 26, 2022, the Internal Revenue Service issued IRS Notice 2022-45, which extends the deadline for amending retirement plans to reflect certain optional and required changes under the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) and section 302 of Title III of the Taxpayer Certainty and Disaster…

On August 3, 2022, the Internal Revenue Service issued IRS Notice 2022-33, which extends the deadline for amending certain plans with the applicable requirements of the Setting Every Community Up for Retirement Enhancement Act of 2019 (SECURE Act), the Bipartisan American Miners Act of 2019 (Miners Act), and one provision…