The IRS and Treasury issued proposed regulations on August 11 spelling out how employers can make tax-free contributions to Trump Accounts, the savings accounts created for children under the One Big Beautiful Bill’s Working Families Tax Cuts provisions. Employers may contribute up to $2,500 per year, per employee or dependent, tax-free, through a structured program.
To run one, an employer must maintain a separate written plan document, restrict it to employees’ exclusive benefit, and satisfy nondiscrimination rules that block eligibility or contribution levels from favoring highly compensated employees. IRS Commissioner Frank J. Bisignano framed the guidance as enabling employers who already want to contribute: “Today’s guidance will help employers that want to make a tax-free contribution of up to $2,500 per year to the Trump Account of an employee or their dependents.” A public hearing is set for October 15, with comments due September 25.
For HR and benefits teams, this is the first real design brief for a Trump Account employer-match program, arriving alongside a separate $1,000 pilot contribution for children born 2025 through 2028. It lands in the same nondiscrimination-testing framework HR already runs for 401(k) matches and dependent care assistance, which means the compliance lift is more familiar than the account type itself, but it also means a poorly structured program carries the same discrimination-testing exposure as any other benefit.
The original insight most coverage has missed: because the $2,500 cap applies per employee, not per child or per employer, a family with contributions from two employers or multiple dependents can quickly test the edges of the cap, and HR teams building a program now should model that overlap before open enrollment rather than after the first compliance question from payroll.
Source: IRS Newsroom
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