Trump Accounts

Issuing agencies

Abstract

This document contains temporary regulations regarding general requirements for Trump accounts, the establishment of an initial Trump account (including automatic enrollment by the Secretary of the Treasury), and qualified general contributions (including qualified stock contributions), which are a special type of contribution made to Trump accounts. These temporary regulations affect trustees of Trump accounts, account beneficiaries of Trump accounts, responsible parties of Trump accounts, and eligible donors who fund qualified general contributions.

Full Text

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<title>Federal Register, Volume 91 Issue 188 (Wednesday, September 30, 2026)</title>
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[Federal Register Volume 91, Number 188 (Wednesday, September 30, 2026)]
[Rules and Regulations]
[Pages 61705-61727]
From the Federal Register Online via the Government Publishing Office [<a href="http://www.gpo.gov">www.gpo.gov</a>]
[FR Doc No: 2026-20026]


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DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 1

[TD 10056]
RIN 1545-BS27


Trump Accounts

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Temporary regulations.

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SUMMARY: This document contains temporary regulations regarding general 
requirements for Trump accounts, the establishment of an initial Trump 
account (including automatic enrollment by the Secretary of the 
Treasury), and qualified general contributions (including qualified 
stock contributions), which are a special type of contribution made to 
Trump accounts. These temporary regulations affect trustees of Trump 
accounts, account beneficiaries of Trump accounts, responsible parties 
of Trump accounts, and eligible donors who fund qualified general 
contributions.

DATES: 
    Effective date: These temporary regulations are effective on 
September 30, 2026.
    Applicability date: For applicability and expiration dates, see 
Sec. Sec.  1.530A-1T(g) and 1.530A-7T(f).

FOR FURTHER INFORMATION CONTACT: Concerning these temporary 
regulations, Isaac Stein at the Office of Associate Chief Counsel 
(Employee Benefits, Exempt Organizations, and Employment Taxes) at 
(202) 317-6320 (not a toll-free number).

SUPPLEMENTARY INFORMATION:

Authority

    This document contains temporary amendments to the Income Tax 
Regulations (26 CFR part 1) to implement section 530A of the Internal 
Revenue Code (the Code). Section 530A(a) authorizes the Secretary of 
the Treasury or the Secretary's delegate

[[Page 61706]]

(Secretary) to prescribe exceptions to the general rule that a Trump 
account shall be treated for purposes of the Code in the same manner as 
an individual retirement account (IRA) under section 408(a). Section 
530A(b)(1)(A)(i) provides that an individual's first Trump account 
(initial Trump account) is to be created or organized by the Secretary. 
Section 530A(b)(1)(B) provides that a Trump account must be designated 
(in such manner as the Secretary shall prescribe) at the time of the 
establishment of the account as a Trump account. Section 
530A(b)(2)(C)(i) authorizes the Secretary to make an election to 
establish an initial Trump account for an eligible individual. Section 
530A(b)(2)(C)(ii) authorizes the Secretary to prescribe rules regarding 
the time and manner for a person other than the Secretary to make an 
election to establish an initial Trump account for an eligible 
individual. Section 530A(f)(1)(A) defines a qualified general 
contribution as a contribution made by the Secretary pursuant to a 
general funding contribution. Section 530A(f)(3)(B) provides that a 
`qualified geographic area' is any geographic area in which not less 
than 5,000 account beneficiaries reside and which is designated by the 
Secretary as a qualified geographic area. Section 530A(i)(1) provides, 
in relevant part, that the trustee of a Trump account will make reports 
to the Secretary and to the beneficiary, at such time and in such 
manner as may be required by the Secretary, with respect to such 
matters as the Secretary may require. Section 408(a)(2) authorizes the 
Secretary to approve as a nonbank trustee for an IRA a person who 
demonstrates to the satisfaction of the Secretary that the manner in 
which such other person will administer the trust will be consistent 
with the requirements of section 408. Section 7805(a) authorizes the 
Secretary to prescribe all needful rules and regulations for the 
enforcement of the Code, including all rules and regulations as may be 
necessary by reason of any alteration of law in relation to internal 
revenue.

Background

I. Overview

    Section 70204 of Public Law 119-21, 139 Stat. 72 (July 4, 2025), 
commonly referred to as the One, Big, Beautiful Bill Act (OBBBA), added 
new sections 530A, 128, 139J, and 6434 to the Code. Section 530A 
provides for the establishment of a Trump account for an eligible 
individual and rules regarding Trump accounts.
    In accordance with section 7805(e)(1), concurrent with the 
publication of this Treasury Decision, the Department of the Treasury 
(Treasury Department) and the IRS are publishing in the Proposed Rules 
section of this issue of the Federal Register a notice of proposed 
rulemaking (CC-00226466-26) containing proposed regulations under 
section 530A at proposed Sec. Sec.  1.530A-1 and 1.530A-7 (the proposed 
regulations), the text of which, except for the applicability 
provisions, is the same as the text of Sec. Sec.  1.530A-1T and 1.530A-
7T of the temporary regulations.
    Interested persons are directed to the ADDRESSES and Comments and 
Requests for a Public Hearing sections of the preamble to CC-00226466-
26 for information on submitting public comments or requesting a public 
hearing on the proposed regulations.

II. Trump Accounts--General Requirements and Election To Establish an 
Initial Trump Account

    A Trump account is a type of traditional IRA established under 
section 530A for the exclusive benefit of an eligible individual or 
such eligible individual's beneficiaries. An eligible individual is any 
individual (i) who has not attained age 18 before the close of the 
calendar year in which an election to establish an initial Trump 
account is made, (ii) for whom a social security number (within the 
meaning of section 24(h)(7)) has been issued before the date on which 
the election is made, and (iii) for whom an election is made either by 
the Secretary or, if the Secretary has not made an election, by a 
person other than the Secretary at the time and in the manner 
prescribed by the Secretary.
    After an election is made, an initial Trump account is created or 
organized by the Secretary for the eligible individual. After an 
initial Trump account has been established, a subsequent Trump account 
(rollover Trump account) may be established for the account beneficiary 
during the period that begins when such initial Trump account is 
established and ends on December 31 of the calendar year in which the 
account beneficiary \1\ of the initial Trump account attains age 17 
(growth period). A rollover Trump account must be funded by a qualified 
rollover contribution, which is a trustee-to-trustee transfer of the 
entire account balance from the account beneficiary's existing Trump 
account.\2\
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    \1\ After an initial Trump account has been established for an 
eligible individual, the individual is referred to as the account 
beneficiary pursuant to section 530A(b)(4).
    \2\ A qualified rollover contribution for a Trump account under 
section 530A(e) may be made only during the growth period and is 
different from and unrelated to a qualified rollover contribution 
for a Roth IRA under section 408A(e).
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    Section 530A(a) generally treats Trump accounts in the same manner 
as traditional IRAs under section 408(a), except as otherwise provided 
in section 530A or under regulations or guidance provided by the 
Secretary. Special rules contained in section 530A that do not apply to 
other traditional IRAs include rules regarding contributions, 
investments, distributions, and reporting. After the growth period, 
most of the special rules no longer apply and the rules under section 
408 governing traditional IRAs generally apply.

III. Qualified General Contributions

    One type of contribution permitted during the growth period is a 
qualified general contribution, which is a contribution made by the 
Secretary and funded by a general funding contribution from a State (or 
political subdivision thereof), the United States, the District of 
Columbia, an Indian Tribal government, or a section 501(c)(3) tax-
exempt organization. The contribution is distributed to the Trump 
accounts of account beneficiaries who are members of a qualified class. 
Under section 530A(f), a qualified general contribution must be made 
pursuant to a general funding contribution, must be made to each 
account beneficiary in the qualified class, and must be made in an 
equal amount for each account beneficiary in that class. The statute 
provides broad, objective criteria to describe the qualified classes of 
account beneficiaries whose Trump accounts can receive the qualified 
general contribution.
    Section 139J provides that qualified general contributions to a 
Trump account are not includible in the gross income of the account 
beneficiary when made.

IV. Prior Guidance

    On December 2, 2025, the Treasury Department and the IRS issued 
Notice 2025-68, 2025-52 IRB 856, which informed taxpayers that the 
Treasury Department and the IRS intend to propose regulations under 
section 530A and related provisions. The notice addressed initial 
questions regarding Trump accounts, including elections to establish 
initial Trump accounts, anticipated annual reporting, qualified 
rollover contribution reporting, trustee-to-trustee information, and 
account beneficiary disclosures. The notice also requested comments.
    On March 9, 2026, the Treasury Department and the IRS published a

[[Page 61707]]

notice of proposed rulemaking (NPRM) (REG-117270-25) in the Federal 
Register (91 FR 11194) containing proposed regulations (Sec. Sec.  
1.530A-1 through 1.530A-6) that would provide guidance on making an 
election to establish a Trump account and reserve additional sections 
for further guidance on Trump accounts (prior Sec.  1.530A-1 NPRM). The 
NPRM published in the Proposed Rules section of this issue of the 
Federal Register withdraws the prior Sec.  1.530A-1 NPRM.
    On March 9, 2026, the Treasury Department and the IRS also 
published a notice of proposed rulemaking (REG-117002-25) in the 
Federal Register (91 FR 11203) containing a proposed regulation (Sec.  
301.6434-1) that would provide guidance on the Trump accounts 
contribution pilot program under section 6434 under which the Trump 
accounts of eligible children can receive $1,000 pilot program 
contributions.
    On July 13, 2026, the Treasury Department and the IRS published 
Rev. Proc. 2026-25, 2026-29 IRB 45, which provides a transfer tax safe 
harbor for certain individual donors who make one or more contributions 
to Trump accounts established under section 530A.
    On August 11, 2026, the Treasury Department and the IRS published a 
notice of proposed rulemaking (REG-101355-26) in the Federal Register 
(91 FR 51611) containing proposed regulations (Sec. Sec.  1.128-1 
through 1.128-3, 1.129-1 and 1.129-2) that would provide guidance on 
employer contributions to Trump accounts under section 128, including 
applicable nondiscrimination rules, and the nondiscrimination rules for 
dependent care assistance programs under section 129.
    On August 21, 2026, the Treasury Department and the IRS published a 
notice of proposed rulemaking (CC-00349938-26) in the Federal Register 
(91 FR 54280) containing a proposed regulation (Sec.  1.530A-3) that 
would provide guidance on eligible investments, which are the only 
assets in which Trump account funds may be invested during the growth 
period.

Explanation of Provisions

    These temporary regulations provide rules regarding the 
establishment of an initial Trump account and qualified general 
contributions. Section 1.530A-1T provides general requirements for 
Trump accounts and rules for the establishment of an initial Trump 
account, including automatic enrollment by the Secretary, and for the 
administration and claiming of auto accounts. The prior Sec.  1.530A-1 
NPRM, which is being withdrawn, did not provide for broad automatic 
enrollment by the Secretary. After considering public comments and 
further addressing the legal and operational issues associated with 
automatic enrollment, the Treasury Department and the IRS have 
identified an administrable structure that permits broad automatic 
enrollment while protecting return information. See Section I.D.2 of 
this Explanation of Provisions. Section 1.530A-7T provides rules 
regarding qualified general contributions, including qualified general 
contributions that consist of qualified stock or that use an approved 
class.

I. Section 1.530A-1T--Trump Accounts; General Requirements; 
Establishment of an Initial Trump Account; Auto Enrollment and Auto 
Accounts

A. Overview
    Section 1.530A-1T provides definitions related to Trump accounts, 
general requirements for Trump accounts, rules for establishment of an 
initial Trump account, including auto enrollment by the Secretary, and 
rules for auto accounts and claiming an auto account.
B. Definitions
    Section 1.530A-1T(b) includes definitions of the terms account 
beneficiary, eligible individual, qualified ABLE rollover contribution, 
qualified general contribution, qualified rollover contribution, Trump 
account, and Secretary that are consistent with sections 530A(b)(4), 
530A(b)(2), 530A(d)(4)(B), 530A(f), 530A(e), 530A(b)(1), and 
7701(a)(11)(B), respectively.
    Section 1.530A-1T(b)(3) defines the term growth period as the 
period that begins when the account beneficiary's initial Trump account 
described in Sec.  1.530A-1T(b)(5)(i) or (ii) is established and ends 
on December 31 of the calendar year in which the account beneficiary 
attains age 17. This definition is provided for ease of reference and 
reflects the statutory concept of the period before the first day of 
the calendar year in which the account beneficiary attains age 18.
    Section 1.530A-1T(b)(4) defines the term IRA as an individual 
retirement account under section 408(a), including a custodial account 
treated as a trust under section 408(h) but, consistently with section 
530A(b)(1), does not include an individual retirement annuity under 
section 408(b).
    Section 1.530A-1T(b)(5) defines the terms initial Trump account, 
auto account, and claimed initial Trump account. An initial Trump 
account is a Trump account created or organized by the Secretary 
pursuant to section 530A(b)(1)(A)(i) and maintained by a trustee 
selected by the Secretary pursuant to section 530A(g). The definition 
of initial Trump account covers three types of initial Trump accounts. 
The first type of initial Trump account is any Trump account that is 
established when a person other than the Secretary makes an election 
(using Form 4547, Trump Account Election(s), or successor form, or 
through an electronic application or web page) and activates the 
account before auto enrollment by the Secretary. The second type of 
initial Trump account is an auto account, which is an initial Trump 
account created or organized pursuant to an election made by the 
Secretary under Sec.  1.530A-1T(d)(2). The third type of initial Trump 
account is a claimed initial Trump account, which is an initial Trump 
account created or organized by the Secretary to receive a qualified 
rollover contribution from an auto account. These definitions identify 
the different ways in which a taxpayer can establish a Trump account 
created or organized by the Secretary, and also distinguish an initial 
Trump account from a rollover Trump account established under section 
530A(b)(1)(A)(ii).
    Section 1.530A-1T(b)(6) defines the term master group trust as a 
trust established by the Secretary for the exclusive benefit of account 
beneficiaries of auto accounts for the purpose of holding investments 
of auto accounts that meets the applicable requirements of Rev. Rul. 
81-100, 1981-1 C.B. 326, as modified, and is exempt from taxation under 
section 408(e).\3\
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    \3\ Although these regulations do not address State or local tax 
treatment, the Treasury Department and the IRS anticipate that, in a 
jurisdiction that conforms to section 408(e) and applies 
corresponding treatment to a group trust described in Rev. Rul. 81-
100, a Trump account and the portion of the master group trust 
equitably attributable to that account generally would receive 
corresponding treatment for State income tax purposes. However, 
treatment under any particular State or local law depends on that 
law and is not determined by these regulations.
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    Section 1.530A-1T(b)(10) provides that the term qualified stock 
contribution, which is a type of qualified general contribution, is 
defined in Sec.  1.530A-7T(b)(9).
    Section 1.530A-1T(b)(11) defines the term responsible party as the 
person who is authorized under the terms of the written governing 
instrument for a Trump account to act on behalf of the account 
beneficiary. A person's status as a responsible party under the written

[[Page 61708]]

governing instrument does not, by itself, establish that the person is 
entitled under section 6103 to inspect or receive the account 
beneficiary's returns or return information.
    Section 1.530A-1T(b)(12) defines the term rollover Trump account as 
a Trump account that is not an initial Trump account and that is 
created or organized in the United States and established for the 
account beneficiary during his or her growth period pursuant to section 
530A(b)(1)(A)(ii). A rollover Trump account must first be funded by a 
qualified rollover contribution from the account beneficiary's existing 
Trump account before receiving any other contribution. Because a 
qualified rollover contribution is a direct trustee-to-trustee transfer 
of the entire Trump account balance, an account beneficiary may have 
only one funded Trump account at a time.
    Section 1.530A-1T(b)(14) defines the term traditional IRA as an IRA 
that is not a Roth IRA under section 408A.
C. General Requirements for a Trump Account
    Section 1.530A-1T(c)(1) provides that a Trump account is a type of 
traditional IRA described in section 530A(b)(1) for the exclusive 
benefit of an eligible individual and, after the death of the 
individual, his or her beneficiaries. A Trump account can be either an 
initial Trump account or a rollover Trump account.
    Section 1.530A-1T(c)(2) provides rules for the written governing 
instrument of a Trump account. Except as otherwise provided, the 
written governing instrument must satisfy the requirements of section 
408(a)(1) through (6), which apply to other IRAs, and the requirements 
of section 530A(b)(1)(C)(i) through (iii), which apply only to Trump 
accounts. The written governing instrument must reflect both the rules 
that apply during the growth period and the rules that apply after the 
growth period.
    Section 1.530A-1T(c)(2)(ii) also requires the written governing 
instrument to clearly designate the account as a Trump account at the 
time of its establishment. Accordingly, an existing account, such as an 
IRA that is not a Trump account, may not be amended to become a Trump 
account. In addition, the account must be titled to clearly identify 
the account as a Trump account for the benefit of the account 
beneficiary.
    With respect to the growth period, the written governing instrument 
generally must restrict the timing and annual amount of contributions 
in accordance with section 530A(b)(1)(C)(i) and prohibit contributions 
under a Simplified Employee Pension (SEP) arrangement under section 
408(k) or a Savings Incentive Match Plan for Employees (SIMPLE) IRA 
plan under section 408(p) in accordance with section 530A(h)(1). 
Additionally, the written governing instrument must prohibit 
distributions in accordance with section 530A(b)(1)(C)(ii), and require 
the funds in the account to be invested only in eligible investments in 
accordance with section 530A(b)(1)(C)(iii), as applied under Sec.  
1.530A-7T(d). A Trump account satisfies the cash contribution 
requirement in section 408(a)(1) if, except in the case of a qualified 
rollover contribution, the written governing instrument provides that 
no contribution will be accepted unless it is in cash or is qualified 
stock received in a qualified stock contribution described in Sec.  
1.530A-7T(d).
    With respect to the period after the growth period, the written 
governing instrument must satisfy the requirements of section 408(a)(1) 
through (6) and the prohibition in section 530A(h)(1) against receiving 
contributions under a SEP arrangement under section 408(k) or a SIMPLE 
IRA plan under section 408(p), which continues to apply after the 
growth period.\4\
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    \4\ Notice 2025-68, Q&A A-10 addresses a contractual (not tax 
law requirement) provision in a written governing instrument for an 
automatic transfer of the account to a traditional IRA immediately 
after the growth period. In such instance, the written governing 
instrument does not need to reflect rules that would apply after the 
growth period because the Trump account would not remain open after 
the growth period. However, if the account remains a Trump account 
for any period of time after the growth period, including if there 
is a provision in the written governing instrument for an automatic 
transfer of the account to a traditional IRA when the account 
beneficiary turns 18 rather than at the end of the growth period, 
the written governing instrument must reflect the post-growth period 
requirements applicable to Trump accounts.
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    Section 1.530A-1T(c)(3) provides, under the authority of section 
408(a)(2), that any person approved by the IRS as of December 31, 2025, 
to be a nonbank trustee of an IRA is automatically approved to be a 
nonbank trustee of a Trump account.
    Section 1.530A-1T(c)(4) provides that a Trump account is subject to 
special rules that differ from the rules for other traditional IRAs, 
including rules relating to contributions, investments, distributions, 
and reporting. After the growth period, the rules under section 408 
that apply to other traditional IRAs generally apply to Trump accounts, 
except as provided in section 530A(h).
    For the avoidance of doubt, Sec.  1.530A-1T(c)(5) provides that for 
purposes of section 530A, an individual attains an age on the 
individual's birthday, and not the day before the individual's 
birthday. For example, a child born on January 1, 2009, attains age 18 
on January 1, 2027.
    Section 1.530A-1T(c)(6) provides that a funded Trump account may 
not be closed during the growth period unless all assets have first 
been distributed in a distribution permissible under section 
530A(b)(1)(C)(ii). The distribution restrictions of section 
530A(b)(1)(C)(ii) do not apply after the growth period and therefore 
those restrictions do not prevent closing a Trump account after the 
growth period, whether funded or unfunded. It also provides that an 
unfunded Trump account that is not an auto account may be closed by the 
trustee after the growth period if provided by the terms of the written 
governing instrument.
D. Establishment of Initial Trump Accounts
1. Methods To Establish an Initial Trump Account
    Section 1.530A-1T(d)(1) explains the three methods by which an 
initial Trump account may be established. Under the first method 
provided in Sec.  1.530A-1T(d)(1)(i), an auto account is established 
pursuant to an election by the Secretary to establish an auto account 
in accordance with section 530A(b)(2)(C)(i).
    Under the second method provided in Sec.  1.530A-1T(d)(1)(ii), an 
initial Trump account is established pursuant to an irrevocable 
election by a person other than the Secretary (such as by using Form 
4547 or the electronic application or web page made available by the 
Secretary) in accordance with section 530A(b)(2)(C)(ii). It is 
anticipated that elections under the first method will generally 
eliminate the need for any election by a person other than the 
Secretary; however, this second method is available for any rare 
exceptions. Section 1.530A-1T(d)(1)(iii) includes a deemed election to 
address situations where an election was made to establish an initial 
Trump account and the account was activated, but the election was not 
made by a person authorized to make the election under the applicable 
instructions. Under this provision, the Secretary is deemed to have 
made the election to establish the initial Trump account. Thus, the 
account does not cease to be a Trump account solely because the 
individual who submitted the election was not authorized to do so. Such 
an account is not an auto account.

[[Page 61709]]

    Under the third method provided in Sec.  1.530A-1T(d)(1)(iv), 
claiming an auto account pursuant to Sec.  1.530A-1T(f) can result in 
the establishment of a claimed initial Trump account to receive the 
funds from the auto account. See section I.F. of this Explanation of 
Provisions regarding other methods to claim an auto account. The 
claimed initial Trump account is an entirely different account from the 
auto account. For example, an auto account can only receive qualified 
general contributions and the $1,000 pilot program contribution (if a 
pilot program election has been made by a pilot program-electing 
individual pursuant to section 6434) while a claimed initial Trump 
account can receive any contribution that is permitted to be made to a 
Trump account (such as a contribution from the family of the account 
beneficiary or from an employer).
2. Auto Enrollment
    Under the prior Sec.  1.530A-1 NPRM (91 FR at 11196), elections to 
establish an initial Trump account generally would be made by persons 
other than the Secretary pursuant to section 530A(b)(2)(C)(ii). 
Although the prior Sec.  1.530A-1 NPRM acknowledged that section 
530A(b)(2)(C)(i) authorizes the Secretary to make an election to 
establish an initial Trump account, those proposed regulations 
contemplated that the Secretary's exercise of that authority would be 
limited to instances in which the Secretary is deemed to have made an 
election when an election was submitted by a person who was not 
authorized to make the election (91 FR at 11197). That proposed 
approach reflected the need to issue the proposed regulations promptly 
in order to implement Trump accounts by the July 4, 2026, date on which 
contributions could first be made. Given the limited time available, 
the Treasury Department and the IRS were unable to fully resolve the 
legal and administrative issues associated with implementing broad 
automatic enrollment, including the need to prevent the unauthorized 
disclosure of return information.
    Many commenters expressed strong support for auto enrollment of 
initial Trump accounts. Commenters urged the Secretary to make an 
election for each individual who satisfies the statutory age and social 
security number requirements, using information available from tax 
returns, Social Security Administration records, and other authorized 
sources. Commenters stated that requiring an affirmative election by a 
person other than the Secretary would reduce participation, 
particularly among nonfilers, families unfamiliar with tax procedures, 
and families with limited time or resources to complete a separate 
enrollment process. Commenters also stated that an eligible individual 
should not lose the opportunity to receive contributions or investment 
growth merely because no adult completed an election.
    Following the publication of the prior Sec.  1.530A-1 NPRM, and 
after considering the public comments supporting automatic enrollment, 
the Treasury Department and the IRS further considered how to address 
the legal and operational issues identified in that NPRM. In 
coordination with the Treasury Department's financial agent and other 
governmental agencies, the Treasury Department and the IRS have 
identified an administrable structure under which the Secretary can 
make elections for eligible individuals while preserving separate IRA 
ownership and protecting return information from disclosure. This 
change in approach therefore reflects the development of a different 
administrative structure, rather than a change in the Treasury 
Department and the IRS's interpretation of the authority conferred by 
section 530A(b)(2)(C)(i).
    Under this structure, a separate initial Trump account is 
established for each eligible individual pursuant to a separate written 
governing instrument, and separate account-level records are maintained 
for each account, which are referred to as auto accounts. Contributions 
are received and recorded by the individual auto account, and the 
assets attributable to auto accounts are invested collectively through 
a master group trust that is intended to satisfy the applicable 
requirements of Rev. Rul. 81-100, as modified. Each auto account holds 
an undivided proportionate beneficial interest in the investments held 
through the master group trust that are attributable to contributions 
allocated to qualified classes of which the account beneficiary was a 
member and any $1,000 pilot program contribution (if a pilot program 
election has been made by a pilot program-electing individual pursuant 
to section 6434) made to that account, and records maintained for the 
Trump accounts program identify the assets attributable to each auto 
account. The structure thus combines separate account ownership and 
account-level recordkeeping with collective investment and 
administration.
    The master group trust addresses the concerns reflected in the 
prior Sec.  1.530A-1 NPRM about disclosure of return information 
because investments are held and administered at the master-group-trust 
level.\5\ Thus, the trustee of the master group trust can execute 
transactions for the trust without receiving or disclosing account-
identifying return information for each account beneficiary in 
connection with each transaction. Return information used to identify 
eligible individuals and establish auto accounts is retained in a 
safeguarded environment by the Secretary and his financial agent 
authorized to receive that information on the Secretary's behalf.
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    \5\ In connection with its establishment of auto accounts and 
the master group trust, Treasury has determined the eligible 
investment(s) and other assets to be held by the master group trust; 
at Treasury's direction, the trustee of the master group trust 
effects any transactions by the master group trust.
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    In addition, a person seeking to claim an auto account must 
independently submit the information required by the Secretary, 
authenticate the person's identity, establish the person's legal 
authority to act with respect to the account and to receive the account 
beneficiary's return information, and execute any consent required for 
disclosures necessary to process the claim and transfer the account 
balance. This process permits an authorized person to claim and control 
the account without disclosing protected account information before the 
person's legal authority to that information has been established.
    Accordingly, after considering the comments and developing this new 
administrable structure, Sec.  1.530A-1T(d)(2)(i) provides for auto 
enrollment through the Secretary making the election to establish an 
initial Trump account. Section 1.530A-1T(d)(2)(ii) provides that any 
account established after auto enrollment has begun pursuant to an 
election under Sec.  1.530A-1T(d)(1)(i) through (iii) will be an auto 
account. To effectuate auto enrollment, on or about October 1, 2026, 
the Secretary will make an election to establish an auto account for 
each individual who the Secretary has determined satisfies the age and 
social security number requirements and for whom no prior election has 
been made by a person other than the Secretary. An auto account shall 
be established for each such individual. Thereafter, the Secretary will 
make subsequent periodic elections to establish auto accounts for 
individuals who the Secretary determines satisfy those requirements and 
for whom no prior election has been made by a person other than the 
Secretary, and will establish auto accounts for eligible individuals 
for whom a Trump account has not been established. It is anticipated 
that such

[[Page 61710]]

periodic elections will be frequent enough to generally eliminate the 
need for any election by a person other than the Secretary.
3. Account Activation Is Required To Establish the Initial Trump 
Account
    Section 1.530A-1T(d)(3) clarifies that an election under Sec.  
1.530A-1T(d)(1)(ii) (for example, using Form 4547) does not by itself 
establish an initial Trump account (and contributions cannot be made 
until the account is established). In order to establish an initial 
Trump account that is not an auto account, the account must be 
activated by the person making the election or claim pursuant to 
instructions from the trustee after the election is made. Account 
activation (which includes signing the account agreement for the 
initial Trump account) is generally the last step in the establishment 
of an initial Trump account.
    The Secretary, as the responsible party, is deemed to have 
activated each auto account with the trustee selected by the Secretary 
pursuant to section 530A(g), and no separate action by anyone is 
required for the auto account to be established.
    Making a claim with respect to an auto account pursuant to Sec.  
1.530A-1T(f) (for example, using the electronic app) does not by itself 
establish a claimed initial Trump account. The qualified rollover 
contribution from the auto account or other contributions to the 
account cannot be made until the account is established. In order to 
establish a claimed initial Trump account, the account must be 
activated pursuant to instructions from the trustee after the claim is 
made. See section I.F. of this Explanation of Provisions regarding 
making a claim with respect to an auto account.
E. Administration of Auto Accounts
    Section 1.530A-1T(e) provides rules regarding the administration of 
auto accounts.
    During the growth period, an auto account may accept only qualified 
general contributions under section 530A(f), including qualified stock 
contributions, and a $1,000 pilot program contribution (if a pilot 
program election has been made by a pilot program-electing individual 
pursuant to section 6434). While the Secretary cannot make a pilot 
program election for the $1,000 pilot program contribution under 
section 6434, in limited circumstances where a pilot program election 
has been made by a pilot program-electing individual pursuant to 
section 6434, but an account was not activated, the auto account will 
be able to receive the $1,000 pilot program contribution. After the 
growth period, an auto account generally may not accept contributions. 
This limitation permits auto accounts to receive Treasury-administered 
contributions while the Secretary remains the responsible party and 
while account-identifying information is maintained in a safeguarded 
environment. It also avoids requiring disclosure of account information 
to a person seeking to act for the account beneficiary before that 
person's identity, legal authority to act for the beneficiary, and 
entitlement under section 6103 to receive the beneficiary's return 
information have been established.
    Section 1.530A-1T(e)(3) provides that an auto account's sole 
investment is its equitable interest in the master group trust, and the 
written governing instrument for the auto account must provide that the 
auto account adopts the provisions of the master group trust.\6\ The 
master group trust may hold only eligible investments described in 
section 530A(b)(3), cash to the extent permitted under section 
530A(b)(1)(C)(iii), and qualified stock contributed pursuant to a 
qualified stock contribution described in Sec.  1.530A-7T(d), including 
successor qualified stock. See section II.D. of this Explanation of 
Provisions regarding qualified stock contributions. With respect to the 
eligible investment requirement in section 530A(b)(1)(C)(iii), each 
auto account's interest in the master group trust consists of its 
undivided proportionate beneficial interest in those investments of the 
master group trust that are attributable to contributions allocated to 
qualified classes of which the account beneficiary was a member and any 
$1,000 pilot program contribution (if a pilot program election has been 
made by a pilot program-electing individual pursuant to section 6434) 
made to that account.
---------------------------------------------------------------------------

    \6\ Rev. Rul. 81-100 permits IRAs (including Trump accounts) and 
other eligible retirement arrangements to pool assets in a group 
trust if specific requirements are satisfied. If those requirements 
are satisfied, the Federal tax status of the group trust is derived 
from the tax status of the participating entities to the extent of 
their equitable interests in the group trust. Thus, the master group 
trust would be exempt from taxation under section 408(e) with 
respect to funds that equitably belong to auto accounts.
---------------------------------------------------------------------------

    It is anticipated neither the trustee of the master group trust nor 
the Secretary, acting in the Secretary's capacity as responsible party, 
has discretion with respect to voting or other corporate actions 
involving those assets. This approach permits those matters to be 
administered on a uniform basis for all affected auto accounts without 
requiring individualized directions with respect to each account. The 
treatment of stock, cash, or other property received by reason of 
owning qualified stock is governed by Sec.  1.530A-7T(d). See section 
II.D. of this Explanation of Provisions.
    Section 1.530A-1T(e)(3)(ii) requires the trustee of the master 
group trust to sell qualified stock within a reasonable period after 
the end of the applicable minimum holding period described in Sec.  
1.530A-7T(d)(3) and promptly invest the proceeds in an eligible 
investment described in section 530A(b)(3). Providing a reasonable 
period for the sale, rather than requiring a sale on a specified date, 
permits the trustee to conduct an orderly disposition and reduces the 
potential market effects of predictable, concentrated sales. Investment 
of the proceeds is treated as prompt if it occurs within 30 calendar 
days after the sale.
    Section 1.530A-1T(e)(4) provides rules for closing an unfunded auto 
account after its growth period or once the auto account has been 
claimed and funds have been transferred out (as in a trustee-to-trustee 
transfer). See Sec.  1.530A-1T(c)(6) for rules regarding closing a 
Trump account that is not an auto account.
    Section 1.530A-1T(e)(5) also provides that, if an account 
beneficiary dies during the growth period before the account 
beneficiary's funded auto account has been claimed, the account will 
cease to be a Trump account on the day that the account beneficiary 
dies but will remain an IRA, which still may be claimed pursuant to 
Sec.  1.530A-1T(f). The fact that the account remains an IRA even after 
the account ceases to be a Trump account is a special rule limited to 
the situation in which an account beneficiary of a funded auto account 
dies during the growth period. The estate of the account beneficiary 
will be the beneficiary of the auto account. However, if the auto 
account is unfunded when the account beneficiary dies, the account will 
be closed pursuant to Sec.  1.530A-1T(e)(4).
    The Treasury Department and the IRS anticipate that reporting rules 
for Trump accounts, including reporting rules relevant to auto 
accounts, will be addressed in future guidance.
F. Claiming an Auto Account
1. In General
    Section 1.530A-1T(f) provides rules for claiming an auto account. A 
guardian or legal custodian having authority under applicable law to 
manage the account beneficiary's property or financial affairs, or an

[[Page 61711]]

account beneficiary with legal capacity (for example, having attained 
the age of majority, or become emancipated, under applicable State 
law), may claim an auto account through an electronic application or 
web page made available by the Secretary, in accordance with applicable 
instructions.
    Claiming an auto account is the process by which a person 
establishes legal authority under applicable law to act with respect to 
an auto account and, before receiving protected account information, 
establishes authority under section 6103 to receive the account 
beneficiary's return information. The information required to establish 
authority under section 6103 is more extensive than what is required by 
Form 4547. Because the existence of an auto account and account-
identifying information maintained by the Secretary or an authorized 
agent in connection with administration of the account constitutes 
return information protected by section 6103, a person claiming an auto 
account must independently provide the information required by the 
Secretary, authenticate the person's identity, establish the required 
legal authority under section 6103, and separately execute any consent 
required under section 6103(c) for disclosure of specified return 
information needed to process the claim and transfer the account 
balance to the receiving trustee.
    During the growth period, claiming an auto account results in the 
entire balance of the auto account being transferred in a qualified 
rollover contribution to either a claimed initial Trump account of the 
account beneficiary (which is maintained by a trustee selected by the 
Secretary pursuant to section 530A(g)) or a rollover Trump account of 
the account beneficiary (which is maintained by a trustee other than 
the trustee(s) selected by the Secretary). After the growth period, 
claiming an auto account results in the entire balance of the auto 
account being transferred to an IRA of the account beneficiary.
    As explained in section I.D.3. of this Explanation of Provisions, 
making a claim with respect to an auto account pursuant to Sec.  
1.530A-1T(f) does not by itself establish a claimed initial Trump 
account, and a qualified rollover contribution from the auto account or 
other contributions cannot be made until the account is established. In 
order to establish a claimed initial Trump account, the account must be 
activated (pursuant to instructions from the trustee to the person 
making the claim) after the claim is made.
    If a claim is made under Sec.  1.530A-1T(f)(1) but a receiving 
account is not yet established in accordance with applicable 
instructions (for example, if the claimed initial Trump account is not 
established because the account is not activated (that is, the account 
agreement is not signed pursuant to the trustee's instructions)), the 
auto account balance will remain in the auto account until a receiving 
account is established and the transfer can be completed. Until a 
receiving account is established, another claim may be made under Sec.  
1.530A-1T(f)(1). In that case, the transfer will be made pursuant to 
the claim for which a receiving account is first established and ready 
to receive the transfer.
    Section 1.530A-1T(f)(2) provides that, until there has been a 
transfer of funds from the auto account into a receiving account, 
another claim may be filed. If multiple claims are filed with respect 
to an auto account, the responsible party for the claimed initial Trump 
account will be the first person who activates the account.
    Section 1.530A-1T(f)(3) provides a special rule for unfunded auto 
accounts that permits the claiming process to establish a claimed 
initial Trump account or rollover Trump account even if no contribution 
has yet been made to the auto account.
    Section 1.530A-1T(f)(4) provides that, if a guardian or legal 
custodian having authority under applicable law to manage the account 
beneficiary's property or financial affairs makes a claim for the auto 
account, that person generally will be the initial responsible party of 
the receiving Trump account when that account is established. To the 
extent provided under the written governing instrument and applicable 
law, the responsible party will have authority, while the account 
beneficiary does not have legal capacity, to select among eligible 
investments if more than one eligible investment is offered, direct a 
transfer for a qualified rollover contribution, direct a transfer for a 
qualified ABLE \7\ rollover contribution under section 530A(d)(4), and 
select a successor responsible party for the account.
---------------------------------------------------------------------------

    \7\ Section 529A was enacted by the Stephen Beck, Jr., Achieving 
a Better Life Experience Act of 2014, which was enacted as part of 
the Tax Increase Prevention Act of 2014, Public Law 113-295 (128 
Stat. 4010).
---------------------------------------------------------------------------

    Section 1.530A-1T(f)(5) provides that, if the account beneficiary 
dies before the auto account has been claimed, a person authorized 
under applicable law to act with respect to the account beneficiary's 
estate or property may claim the funds through an electronic 
application or web page made available by the Secretary, in accordance 
with applicable instructions, provided that the person also establishes 
entitlement under section 6103(e)(3) and (7), or other applicable 
authority, to receive the decedent's return information.

II. Section 1.530A-7T--Qualified General Contributions and Qualified 
Stock Contributions

A. Overview
    Section 1.530A-7T provides definitions related to qualified general 
contributions, rules for qualified general contributions (including 
qualified general contributions that use an approved class or that 
consist of qualified stock), and rules for determining whether a 
general funding contribution furthers an exempt purpose.
B. Definitions
    Section 1.530A-7T(b)(1) defines the term approved class as a class 
consisting of not less than 5,000 account beneficiaries that includes 
all account beneficiaries who are still in their growth period when the 
contribution is made, reside in one or more States or other qualified 
geographic areas specified by the terms of and on the record date(s) 
provided in the Treasury acceptance agreement, and were born in one or 
more calendar years specified in the Treasury acceptance agreement.
    Section 1.530A-7T(b)(2) defines the term eligible donor 
consistently with section 530A(f)(2)(A) as an entity described in 
section 170(c)(1) (other than a possession of the United States or a 
political subdivision of a possession), an Indian Tribal government, or 
an organization described in section 501(c)(3) and exempt from tax 
under section 501(a).
    Section 1.530A-7T(b)(3) defines the term general funding 
contribution consistently with section 530A(f)(2), and treats an 
approved class as a qualified class for purposes of this definition. 
See section II.C. of this Explanation of Provisions regarding treatment 
of an approved class as a qualified class.
    Section 1.530A-7T(b)(4) provides that the term minimum holding 
period requirement is the period of time described in Sec.  1.530A-
7T(d)(3) during which the qualified stock may not be sold or otherwise 
disposed of.
    Section 1.530A-7T(b)(5) defines the term qualified class 
consistently with section 530A(f)(3), clarifying that a contribution is 
made when it is made to the Trump account. A contribution is made to 
the Trump account when it is received by the Trump account, and not 
when the contribution is announced by the eligible donor or when the 
general

[[Page 61712]]

funding contribution is received by the Treasury Department.
    Section 1.530A-7T(b)(6) defines the term qualified general 
contribution consistently with section 530A(f)(1) and Sec.  1.530A-
7T(c). In accordance with Sec.  1.530A-7T(c)(3)(ii) and (iii) and 
(c)(4)(ii), it provides that a qualified general contribution includes 
an approved class contribution, which is a qualified general 
contribution that uses an approved class, and that a qualified general 
contribution includes a qualified stock contribution.
    Section 1.530A-7T(b)(7) defines the term qualified geographic area 
as provided in section 530A(f)(3)(B).
    Section 1.530A-7T(b)(8) defines the term qualified stock as stock 
that is publicly traded, issued by a domestic corporation, and not 
subject to any pre-existing transfer restrictions, such as being a 
restricted security as defined in 17 CFR 230.144(a)(3), in each case as 
determined when it is contributed to the Treasury Department as part of 
a general funding contribution.
    Section 1.530A-7T(b)(9) defines the term qualified stock 
contribution as a qualified general contribution of qualified stock 
that satisfies the requirements of Sec.  1.530A-7T(c) and (d).
    Section 1.530A-7T(b)(10) defines the term record date as one or 
more dates specified in a Treasury acceptance agreement as of which the 
Secretary determines the account beneficiaries whose Trump accounts are 
eligible to receive a qualified general contribution.
    Section 1.530A-7T(b)(11) defines the term Treasury acceptance 
agreement as the written agreement or other documentation pursuant to 
which the Secretary accepts a general funding contribution.
C. Qualified General Contributions
    Section 1.530A-7T(c)(1) provides that a contribution is a qualified 
general contribution only if it satisfies the requirements in Sec.  
1.530A-7T(c)(2) through (4). These requirements track the requirements 
of section 530A(f)(1)(A) through (C) that the contribution be made by 
the Secretary pursuant to a general funding contribution, be made to 
the Trump accounts of account beneficiaries in a qualified class, and 
be made in an equal amount for each account beneficiary in that class.
    In accordance with section 530A(f)(1)(A), Sec.  1.530A-7T(c)(2) 
provides rules for the Secretary's acceptance of a general funding 
contribution and the Secretary's subsequent making of qualified general 
contributions to Trump accounts. First, an eligible donor seeking to 
make a general funding contribution submits a request on the form 
prescribed by the Secretary or through an electronic application or web 
page made available by the Secretary. Second, the Secretary reviews the 
request and may, in the Secretary's sole discretion, approve the 
request after determining that the request satisfies the requirements 
of Sec.  1.530A-7T and considering objective criteria, including the 
cost of implementation, the operational feasibility of the 
contribution, and the potential impact of other Federal laws (such as 
securities laws). Third, if the Secretary approves the request, the 
Secretary and the donor will enter into a Treasury acceptance agreement 
that contains information required by the Secretary, including the 
aggregate amount of funding, the qualified class, the record date, and, 
if applicable, information about the qualified stock.
    Because the eligible donor makes a general funding contribution to 
the Secretary, and the Secretary then makes a qualified general 
contribution only to certain Trump accounts, there must be a clear 
process for acceptance, allocation, transfer, and overall 
administration. Section 1.530A-7T(c)(2) provides clear and 
administrable rules to implement these aspects of the two-step 
contribution structure contemplated by section 530A(f). These rules 
provide eligible donors and the Treasury Department with certainty and 
ensure consistent treatment of all members of the qualified class. The 
Treasury Department anticipates releasing more information about the 
request form.
    In accordance with section 530A(f)(1)(B), Sec.  1.530A-7T(c)(3)(i) 
provides that qualified general contributions can only be made to Trump 
accounts of account beneficiaries in a qualified class. The section 
clarifies that the qualified class must be the qualified class that is 
set forth in the Treasury acceptance agreement, even if the donor 
request form identified a different group of account beneficiaries.
    Section 1.530A-7T(c)(3)(ii) and (c)(4)(ii) provides that, for 
purposes of section 530A(f)(1)(B) and (C), respectively, an approved 
class is treated as a qualified class. Section 530A(f) is designed to 
permit broad-based contributions to Trump accounts rather than 
contributions selected on an account-by-account basis. The approved-
class rule implements that design by permitting only classes that are 
defined using a combination of objective criteria consisting of the 
qualified class-based criteria used in section 530A(f)(3): the account 
beneficiary must be in the growth period, must reside in one or more 
States or other qualified geographic areas specified in the Treasury 
acceptance agreement, and must have been born in one or more specified 
calendar years. The rule also requires the class to consist of not less 
than 5,000 account beneficiaries in order to be consistent with the 
same minimum class size requirement reflected in the qualified 
geographic area requirement of section 530A(f)(3)(B).
    The Treasury Department and the IRS have determined that treating 
an approved class as a qualified class is consistent with section 
530A(f) because the rule furthers the statutory objective of broad, 
equal-per-beneficiary funding while allowing contributions to be 
administered using objective criteria that can be verified from 
Treasury Department records. For example, a contribution for all 
account beneficiaries born in specified years and residing in a 
specified State or qualified geographic area may serve a broad class of 
account beneficiaries while permitting the eligible donor and the 
Secretary to define the class with enough specificity for administrable 
funding and allocation.
    Section 1.530A-7T(c)(3)(iii) provides that a qualified general 
contribution generally must be made in cash to a Trump account. An 
exception applies for qualified stock contributed as part of a 
qualified stock contribution that satisfies Sec.  1.530A-7T(d).
    Section 1.530A-7T(c)(4) provides that a qualified general 
contribution must be made in an equal amount to the Trump account of 
each account beneficiary in the qualified class. Details regarding the 
form and amount of the qualified general contributions will be 
addressed in the Treasury acceptance agreement. The equal-amount 
requirement applies to all account beneficiaries in the qualified class 
as of the applicable record date and, if multiple record dates are 
used, across all applicable record dates. The account beneficiaries 
included in the qualified class are determined based on information 
obtained during the election process under Sec.  1.530A-1T(d)(1)(i) and 
(ii), as updated by information reported to the Secretary under section 
530A(i).
D. Qualified Stock Contributions
1. In General
    To facilitate certain stock donations from eligible donors, the 
temporary regulations provide rules for qualified stock contributions. 
A qualified stock contribution is a contribution of qualified stock. 
Qualified stock is publicly traded stock that is issued by

[[Page 61713]]

a domestic corporation and meets the other requirements set forth in 
Sec.  1.530A-7T(b)(8).
    Section 530A(b)(1)(C)(iii) provides that, during the growth period, 
the funds in a Trump account may be invested only in eligible 
investments described in section 530A(b)(3). Holding qualified stock 
received pursuant to a qualified stock contribution does not violate 
this restriction because no funds in the account are used to acquire 
the contributed stock. Rather, the stock is contributed directly into 
the individual Trump accounts for the beneficiaries in the designated 
qualified class.
    Pursuant to the regulatory authority conferred in section 530A(a) 
to provide exceptions to the rules of section 408(a), the temporary 
regulations also provide an exception from the section 408(a)(1) 
requirement that non-rollover contributions to an IRA must be in cash 
for a qualified stock contribution. The Treasury Department and the IRS 
have determined that these limited exceptions for qualified stock 
contributions will facilitate more donations from eligible donors, and 
will help create a practical pathway for large-scale private giving to 
support the Trump account program and the account beneficiaries with 
Trump accounts.
    Qualified stock that is contributed to a Trump account is subject 
to a minimum holding period requirement in Sec.  1.530A-7T(d)(3). 
Pursuant to the minimum holding period requirement, the stock may not 
be sold before the earlier of (i) the date that is 5 years after the 
qualified stock contribution to the account, and (ii) the end of the 
growth period for the account beneficiary of that account. If the 
qualified stock is disposed of in violation of the minimum holding 
period requirement, the trustee must repurchase the same number of 
shares of the same class of qualified stock that were sold or otherwise 
disposed of as soon as practicable. However, the qualified stock may be 
disposed of during the required minimum holding period to effectuate a 
qualified ABLE rollover contribution, to effectuate a qualified 
rollover contribution when fractional shares cannot be transferred in 
kind (for example, if fractional shares cannot be transferred as part 
of a qualified rollover contribution, the transferring trustee may sell 
the fractional shares and transfer cash as part of the qualified 
rollover contribution instead), to accept a tender offer for the 
qualified stock at the direction of the responsible party, or if the 
issuer of the qualified stock is acquired for cash (by merger, 
purchase, or otherwise). See Sec.  1.530A-7T(d)(3)(iv).
    Section 1.530A-7T(d)(4) provides qualified stock treatment for 
certain stock received by the Trump account by reason of owning 
qualified stock (successor qualified stock).
    Section 1.530A-7T(d)(5) and (d)(6) provides specific rules on the 
consequences of the qualified stock being delisted from a national 
securities exchange and the receipt of property from corporate 
distributions on the qualified stock, generally requiring that the 
trustee must promptly sell or dispose of the qualified stock or the 
property that was distributed, invest the net proceeds and any 
distributed cash in eligible investments described in section 
530A(b)(3), and disclose how the proceeds were invested to the account 
beneficiary.
    Section 1.530A-7T(d)(7) provides that an auto account's equitable 
interest in qualified stock in the master group trust is treated as 
qualified stock.
E. Tax Implications of Contributions
    A general funding contribution, by definition, is made to the 
Secretary for distribution to a broad class that is defined by 
objective criteria pursuant to the terms of a Treasury acceptance 
agreement meant to advance the Trump account program. Thus, Sec.  
1.530A-7T(e)(1) provides that with regard to a person making a 
contribution to an eligible donor that is an organization described in 
section 501(c)(3) and exempt from tax under section 501(a) to fund a 
general funding contribution satisfying the requirements of Sec.  
1.530A-7T, that person's contribution is deductible under section 170, 
subject to the other requirements of that section. Similarly, Sec.  
1.530A-7T(e)(1) provides that, with regard to individuals making a gift 
to any organization qualifying as an eligible donor for purposes of 
section 530A, whether or not that eligible donor subsequently makes a 
general funding contribution, the gift is to an organization described 
in section 2522.
    Section 1.530A-7T(e)(2)(i) provides that an organization described 
in section 501(c)(3) and exempt from tax under section 501(a) furthers 
one or more of its purposes described in section 501(c)(3) by providing 
a general funding contribution. These rules apply whether the 
organization provides the amount directly or provides the amount 
through a distribution from a donor advised fund. These rules provide 
certainty for eligible donors that funding contributions distributed to 
the qualified class or approved class outlined in the Treasury 
acceptance agreement will not affect that charity's exempt purpose. The 
use of a qualified class or an approved class furthers this purpose 
because the class is broad, is defined using objective statutory 
criteria, and includes every account beneficiary satisfying those 
objective criteria.
    Section 1.530A-7T(e)(2)(ii) provides that an eligible donor making 
a general funding contribution is making an expenditure for a purpose 
specified in section 170(c)(2)(B). Section 1.530A-7T(e)(2)(ii) also 
provides that a general funding contribution is neither a grant to an 
individual for purposes of section 4945 nor a distribution to a natural 
person for purposes of section 4966. Section 4945(d)(4) generally 
requires a private foundation to exercise expenditure responsibility 
with respect to certain grants. Similarly, section 4966(c)(1)(B)(ii) 
generally requires a sponsoring organization to exercise expenditure 
responsibility with respect to certain distributions from a donor 
advised fund. To provide certainty to eligible donors, Sec.  1.530A-
7T(e)(2)(ii) also provides that, to the extent that an obligation to 
exercise expenditure responsibility arises under sections 4945 or 4966, 
an eligible donor that makes a general funding contribution that 
satisfies the requirements of that section is treated, for purposes of 
sections 4945 and 4966, as exercising expenditure responsibility in 
accordance with section 4945(h). This treatment is based on the 
safeguards applicable to general funding contributions, including the 
requirements governing the Treasury acceptance agreement; the 
requirement that the contribution be made exclusively for one or more 
purposes specified in section 170(c)(2)(B) and further one or more 
exempt purposes described in section 501(c)(3); and the reporting 
requirements under sections 530A(i) and 4945(h)(3). These rules apply 
whether the donor makes the contribution directly or through a donor 
advised fund.

Applicability Dates

    The temporary regulations under Sec. Sec.  1.530A-1T and 1.530A-7T 
apply to taxable years beginning on or after January 1, 2026, and 
expire on September 30, 2029.

Special Analyses

I. Good Cause

    Section 553(b)(3)(B) of the Administrative Procedure Act (APA) (5 
U.S.C. 553(b)(3)(B)) provides that advance notice and the opportunity 
for public comment are not required with respect to a rulemaking when 
an ``agency for good cause finds (and incorporates the finding and a 
brief

[[Page 61714]]

statement of reasons therefor in the rules issued) that notice and 
public procedure thereon are impracticable, unnecessary, or contrary to 
the public interest.'' The Treasury Department and the IRS find that 
good cause exists for issuing these temporary regulations without prior 
notice-and-comment because following notice-and-comment procedures 
before these regulations take effect would be impracticable and 
contrary to the public interest.
    OBBBA added section 530A to the Code. Section 70204 of OBBBA 
generally applies to taxable years beginning after December 31, 2025. 
Although contributions to Trump accounts were prohibited before July 4, 
2026, contributions may now be made to Trump accounts.
    OBBBA created a new statutory account structure for eligible 
individuals. The rules in Sec.  1.530A-1T are necessary to implement 
that structure immediately. Section 530A provides that an initial Trump 
account must be created or organized by the Secretary and designated as 
a Trump account, and permits the Secretary to make the election to 
establish an initial Trump account. Section 1.530A-1T provides the 
procedures needed for the Secretary to exercise that authority, for 
trustees to identify whether an account is an initial Trump account or 
a rollover Trump account, for auto accounts to be established and 
administered, and for a guardian or legal custodian having authority 
under applicable law to manage the account beneficiary's property or 
financial affairs, or an account beneficiary, if the account 
beneficiary has legal capacity, to claim an auto account and direct a 
permitted transfer. Without immediately effective rules, there would be 
no uniform framework for determining when an initial Trump account has 
been established, which account is the account beneficiary's initial 
Trump account, how auto enrollment by the Secretary would work, how a 
responsible party is identified, or how an auto account may be claimed 
and transferred. Those issues must be resolved before trustees and the 
Secretary can administer Trump accounts as required by section 530A and 
before contributions can be accepted and properly directed.
    Immediate effectiveness is particularly important for the auto 
account rules in Sec.  1.530A-1T. After publication of the prior Sec.  
1.530A-1 NPRM, commenters urged the Treasury Department and the IRS to 
provide for broader auto enrollment of initial Trump accounts. 
Following the publication of the prior Sec.  1.530A-1 NPRM, and after 
considering the public comments supporting automatic enrollment, the 
Treasury Department and the IRS identified an administrable structure 
under which the Secretary can make elections for eligible individuals 
while preserving separate IRA ownership and protecting return 
information from disclosure.
    Under this structure, a separate initial Trump account is 
established for each eligible individual pursuant to a separate written 
governing instrument, and separate account-level records are maintained 
for each account, which are referred to as auto accounts. Contributions 
are received and recorded by the individual auto account, and the 
assets attributable to auto accounts are invested collectively through 
a master group trust that is intended to satisfy the applicable 
requirements of Rev. Rul. 81-100, as modified. Each auto account holds 
an undivided proportionate beneficial interest in the investments held 
through the master group trust that are attributable to contributions 
allocated to qualified classes of which the account beneficiary was a 
member and any $1,000 pilot program contribution (if a pilot program 
election has been made by a pilot program-electing individual pursuant 
to section 6434) made to that account, and records maintained for the 
Trump accounts program identify the assets attributable to each auto 
account. The structure thus combines separate account ownership and 
account-level recordkeeping with collective investment and 
administration.
    The ability to use that structure depends on having a regulatory 
regime in effect governing Secretary elections, account establishment, 
trustee administration, the master group trust, responsible-party 
authority, claiming procedures, and transition rules for accounts and 
elections that predate auto enrollment. If the effective date of the 
regulations was delayed until after notice-and-comment procedures were 
completed, the Secretary would be unable to begin administering auto 
elections and auto accounts on a uniform basis, and eligible 
individuals may not have an account in which to receive qualified 
general contributions or a $1,000 pilot program contribution (if a 
pilot program election has been made by a pilot program-electing 
individual pursuant to section 6434). That result would be contrary to 
the public interest because it would delay making the accounts 
available for eligible individuals at the earliest practicable time, 
which in turn would shorten the growth period of such accounts.
    The rules in Sec.  1.530A-7T are also needed immediately. Section 
530A(f) permits eligible donors to make general funding contributions 
for qualified classes of account beneficiaries, and section 530A 
contemplates that contributions may be made during the growth period. 
Section 1.530A-7T provides the procedures and standards needed for the 
Secretary to accept a general funding contribution, enter into a 
Treasury acceptance agreement, identify account beneficiaries, and 
determine the amount payable to each account. Until those rules are 
effective, eligible donors, trustees, and the Treasury Department would 
lack the operative framework for determining whether a proposed broad-
based contribution qualifies under section 530A(f), which account 
beneficiaries are included, and the amount to be contributed to each 
account. Delaying these rules would prevent or significantly delay 
broad-based contributions, require donors and trustees to defer 
implementation or proceed under uncertain and potentially inconsistent 
terms, and could deprive account beneficiaries of contributions and 
associated investment returns during the first period in which Trump 
accounts are being established and funded.
    The qualified stock contribution rules in Sec.  1.530A-7T present 
an additional need for immediate guidance. Because section 408(a)(1) 
generally contemplates cash contributions to IRAs and section 
530A(b)(1)(C)(iii) restricts investments during the growth period to 
eligible investments while section 530A(a) allows the Secretary to 
provide exceptions in guidance for a Trump account from treatment as an 
IRA, trustees and donors need rules before a stock contribution is 
accepted to determine whether stock may be transferred, what stock 
qualifies, how the minimum holding period applies, how corporate 
actions and successor stock are handled, and when cash proceeds or 
other property must be invested in eligible investments. Without 
immediate rules, an eligible donor seeking to make a qualified stock 
contribution could not reliably complete the contribution, and trustees 
could not accept and hold the stock without risking inconsistent 
treatment under the IRA and Trump account rules. Because these issues 
must be resolved before stock is accepted and allocated to accounts, 
post-hoc guidance issued only after completion of notice-and-comment 
procedures would not ensure that stock contributions can be made or 
that such contributions were treated equally.

[[Page 61715]]

    The temporary regulations also reduce the risk of inconsistent 
account treatment and misdirected contributions during the transition 
to auto enrollment. The regulations specify how accounts established 
before auto enrollment are treated, how elections made before auto 
enrollment that have not resulted in established accounts are handled, 
and how an auto account may be claimed and transferred. Without 
immediately effective rules addressing the transition, the Secretary 
and trustees could receive overlapping elections, claims, funding 
requests, and transfer instructions for the same account beneficiaries 
without a uniform rule for how to resolve them. That uncertainty would 
impair orderly administration and could require corrective transfers or 
duplicative administrative actions.
    The Treasury Department and the IRS have taken steps to provide 
advance information and opportunities for public input. Notice 2025-68 
informed taxpayers that guidance would be issued under section 530A and 
requested comments. The Treasury Department and the IRS also published 
the prior Sec.  1.530A-1 NPRM regarding elections to establish initial 
Trump accounts and considered comments on auto enrollment and account 
administration. In accordance with section 7805(e) of the Code, a 
cross-referenced notice of proposed rulemaking is being published 
concurrently with these temporary regulations, and the Treasury 
Department and the IRS will consider all timely comments before issuing 
final regulations.
    For these reasons, the Treasury Department and the IRS find that 
delaying the effectiveness of Sec. Sec.  1.530A-1T and 1.530A-7T to 
complete notice-and-comment procedures would be impracticable and 
contrary to the public interest. Accordingly, the Treasury Department 
and the IRS find good cause under 5 U.S.C. 553(b)(3)(B) to issue these 
temporary regulations without prior notice and comment.
    The Treasury Department and the IRS also find good cause under 5 
U.S.C. 553(d)(3) for these temporary regulations to become effective 
upon publication in the Federal Register. A 30-day delayed effective 
date would create the same problems described above: auto enrollment 
and auto accounts could not be administered on a uniform basis; claims 
and transfers could be delayed; and qualified general contributions or 
qualified stock contributions could be postponed or made under 
uncertain terms. Immediate effectiveness is therefore necessary to 
permit the Secretary, trustees, eligible donors, responsible parties, 
and account beneficiaries to apply the rules as Trump accounts are 
established, claimed, funded, and transferred.

II. Regulatory Planning and Review

    Executive Orders 12866 and 13563 direct agencies to assess costs 
and benefits of available regulatory alternatives and, if regulation is 
necessary, to select regulatory approaches that maximize net benefits 
(including potential economic, environmental, public health and safety 
effects, distributive impacts, and equity). Executive Order 13563 
emphasizes the importance of quantifying both costs and benefits, 
reducing costs, harmonizing rules, and promoting flexibility.
    The temporary regulations have been designated by the Office of 
Management and Budget's (OMB's) Office of Information and Regulatory 
Affairs (OIRA) as subject to review under Executive Order 12866 
pursuant to the Memorandum of Agreement (MOA, July 4, 2025) between the 
Treasury Department and the OMB regarding review of tax regulations. 
OIRA has determined that the rulemaking is economically significant and 
subject to review under section 3(f)(1) of Executive Order 12866 and 
section 1(c) of the MOA. Accordingly, the temporary regulations have 
been reviewed by OMB.
Need for Regulation
    The temporary regulations define terms for the purpose of 
implementing section 530A and clarify how initial accounts will be 
created and claimed. The temporary regulations define terms and 
establish rules for general funding contributions and qualified general 
contributions.
The Statute and the Temporary Regulations
    Public Law 119-21, commonly referred to as the One, Big, Beautiful 
Bill Act, added new sections 530A, 128, and 6434 to the Code. Section 
530A describes Trump accounts, section 128 describes certain employer 
contributions to Trump accounts, and section 6434 describes the Trump 
accounts contribution pilot program. The temporary regulations 
implement rules under section 530A concerning account creation and 
contributions to a qualified class.
    Section 530A defines a Trump account as a traditional individual 
retirement account (IRA) with some special rules. Most special rules 
that distinguish Trump accounts from other IRAs apply only during the 
growth period. The first day of the growth period is the day the 
account is established, and the final day of the growth period is 
December 31 of the calendar year in which the account beneficiary 
attains age 17. The rules for traditional IRAs generally apply after 
the growth period. A Trump account may be established for the benefit 
of a child prior to the calendar year in which the child attains age 18 
if the child has been issued a social security number.
    In general, distributions from Trump accounts are not permitted 
during the growth period. The entire balance of a Trump account may be 
rolled over in a direct trustee-to-trustee transfer to a new Trump 
account of the account beneficiary. The entire balance of a Trump 
account may be rolled over in a direct trustee-to-trustee transfer to 
an ABLE account of the account beneficiary in the calendar year the 
account beneficiary attains age 17.
    During the growth period, cash in a Trump account must generally be 
invested in funds that track the returns of a broad index of equities 
in primarily U.S. companies for which regulated futures contracts are 
traded, do not use leverage, and do not have annual fees and expenses 
above 0.1%.
    Trump accounts may receive contributions from nonprofits, 
governments, employers, and individuals. During the growth period, 
contributions to a Trump account generally are subject to an annual 
limit of $5,000, adjusted for inflation for taxable years after 2027.
    Governments and nonprofits may fund contributions in equal amounts 
to the Trump accounts of every account beneficiary in a qualified 
class. A qualified class consists of all account beneficiaries in the 
growth period or all such account beneficiaries who meet specified 
geographic or birth year criteria. Contributions to a qualified class 
funded by governments and nonprofits are facilitated by the Treasury 
Department. A payment from a government or nonprofit to the Treasury 
Department for the purpose of funding contributions to a qualified 
class is defined by section 530A(f)(2) as a general funding 
contribution. A payment from the Treasury Department to the Trump 
account of an account beneficiary in a qualified class is defined by 
section 530A(f)(1) as a qualified general contribution. Contributions 
to a qualified class facilitated by the Treasury Department and funded 
by a government or nonprofit do not count towards the $5,000 annual 
contribution limit.
    Section 128 sets rules for certain employer contributions to Trump 
accounts. Employers may contribute to

[[Page 61716]]

the Trump account of an employee or an employee's dependent. Section 
128 employer contributions to a Trump account are excluded from the 
employee's income, up to an annual limit of $2,500, adjusted for 
inflation for taxable years after 2027. Section 128 employer 
contributions count towards the $5,000 annual contribution limit.
    Section 6434 describes the Trump accounts contribution pilot 
program. In the pilot program, the Secretary of the Treasury 
(Secretary) will pay $1,000 to the Trump accounts of eligible children. 
A U.S. citizen born in 2025, 2026, 2027, or 2028 who has been issued a 
social security number, for whom no request for a pilot program 
contribution has previously been processed, and for whom the pilot 
program-electing individual anticipates will be that individual's 
qualifying child under section 152(c) for the year in which the 
election is made is eligible for a pilot program contribution. Pilot 
program contributions do not count towards the $5,000 annual 
contribution limit.
    Other contributions to a Trump account during the growth period 
(other than qualified rollover contributions), including contributions 
from friends or family members, contributions from governments and 
nonprofits that are not facilitated by the Treasury Department, and 
employer contributions that are not Section 128 employer contributions, 
are contributions for which no deduction is allowed under section 219 
(they create investment in the contract (basis) for purposes of 
applying section 72) and count towards the $5,000 annual contribution 
limit.
    The temporary regulations (Sec. Sec.  1.530A-1T and 1.530A-7T) are 
just one piece of the implementation of section 530A; prior proposed 
regulations addressed eligible investments (Sec.  1.530A-3), and future 
guidance will address other issues (Sec. Sec.  1.530A-2, 1.530A-4, 
1.530A-5, and 1.530A-6).
    Under the temporary regulations, the following terms are defined 
for the purpose of implementing section 530A: IRA, traditional IRA, 
growth period, responsible party, initial Trump account, auto account, 
claimed initial Trump account, qualified rollover contribution, 
rollover Trump account, and master group trust. An IRA is an individual 
retirement account. A traditional IRA is an individual retirement 
account that is not a Roth IRA. Growth period is a concise term for the 
period described repeatedly by the statute as ``the period before the 
first day of the calendar year in which the account beneficiary attains 
age 18.'' A responsible party is the person authorized under the 
written governing instrument to act on behalf of the account 
beneficiary. An initial Trump account is an account that is created or 
organized by the Secretary. An auto account is an initial Trump account 
that is created following an election made by the Secretary. A claimed 
initial Trump account is an initial Trump account that receives a 
qualified rollover contribution from an auto account. A qualified 
rollover contribution is a direct trustee-to-trustee transfer of an 
account beneficiary's entire Trump account balance to a different Trump 
account for the same account beneficiary. A rollover Trump account is a 
Trump account that is not an initial Trump account. A master group 
trust is a trust established by the Secretary to hold investments for 
the exclusive benefit of account beneficiaries of auto accounts.
    Under the temporary regulations, these additional terms are defined 
for the purpose of implementing section 530A: Treasury acceptance 
agreement, eligible donor, approved class, record date, qualified 
stock, and qualified stock contribution. A Treasury acceptance 
agreement is a document that specifies the terms under which the 
Secretary accepts a general funding contribution. An eligible donor is 
a government or nonprofit that is eligible to make a general funding 
contribution. An approved class is a group of at least 5,000 account 
beneficiaries in the growth period who meet geographic and birth year 
criteria specified by a Treasury acceptance agreement. A record date is 
the date (or dates) when membership in a qualified class is determined 
as specified in a Treasury acceptance agreement. Qualified stock is 
publicly traded stock of a domestic corporation with no pre-existing 
transfer restrictions, such as being a restricted security as defined 
in 17 CFR 230.144(a)(3). A qualified stock contribution is a qualified 
general contribution of qualified stock.
    Under the temporary regulations, the Secretary will create auto 
accounts for eligible children who do not have Trump accounts on or 
about October 1, 2026, and periodically thereafter. The Secretary is 
the responsible party for an auto account. An auto account may receive 
qualified general contributions and the $1,000 pilot program 
contribution. A person with legal authority to view the account 
beneficiary's tax information, including a guardian or legal custodian 
or the account beneficiary after attaining age 18, may ``claim'' an 
auto account. When an auto account is claimed during the growth period, 
there is a qualified rollover contribution to a claimed initial Trump 
account or to a rollover account, and the individual claiming the 
account becomes the responsible party. When an auto account is claimed 
after the growth period, there is a trustee-to-trustee transfer to a 
traditional IRA for the benefit of the account beneficiary.
    Under the temporary regulations, the terms of a general funding 
contribution must be specified in a Treasury acceptance agreement. A 
Treasury acceptance agreement must identify the donor, aggregate 
funding amount or commitment, geographic criteria of the qualified 
class (if any), age criteria of the qualified class (if any), record 
dates, donor-identity reporting, and other required information. An 
approved class will receive the same tax treatment and Treasury 
facilitation as a qualified class. The regulations clarify that a 
501(c)(3) organization furthers exempt purposes by making a general 
funding contribution, including through a donor advised fund, and that 
a general funding contribution is neither a section 4945 grant to an 
individual nor a section 4966 distribution to a natural person.
    Under the temporary regulations, a general funding contribution may 
consist of qualified stock. For a qualified stock contribution, the 
Treasury acceptance agreement must include the name and employee 
identification number (EIN) of the stock issuer, the number of shares, 
and other required information. Qualified stock that is contributed to 
a Trump account in a qualified general contribution must generally be 
held for five years, but there are exceptions to liquidate the stock at 
the end of the growth period, to initiate a qualified ABLE rollover, to 
permit cash in lieu of fractional shares that cannot be transferred in 
kind as part of a qualified rollover contribution, in the case of a 
tender offer, or if the issuer of the qualified stock is acquired (by 
merger, purchase, or otherwise). If qualified stock is disposed of 
improperly without an exception, equivalent stock must be repurchased.
Baseline
    The Treasury Department and the IRS have assessed the benefits and 
costs of the temporary regulations relative to a no-action baseline 
reflecting anticipated Federal income tax-related behavior in the 
absence of these temporary regulations.
Affected Entities and Taxpayers
    The temporary regulations are expected to affect 73 million 
children in 44 million families.

[[Page 61717]]

Economic Effects of the Temporary Regulations
    The temporary regulations make several choices that increase the 
appeal of making general funding contributions. As a consequence, more 
eligible donors will make general funding contributions, more children 
will receive qualified general contributions, and the total value of 
class contributions will be larger.
    The class contribution feature of Trump accounts is unprecedented 
in the domain of child savings accounts. This will be the first time 
the federal government facilitates private contributions for the 
benefit of individual American children. Because class contributions 
are charting new territory in charitable giving, there is no obvious 
basis for estimating the incremental impact of the temporary 
regulations.
    One very instructive data point is the pledged contribution from 
the Michael & Susan Dell Foundation (MSDF). MSDF has been at the 
forefront of class contributions since Trump accounts were enacted into 
law. MSDF pledged $6.25 billion to children born between 2016 and 2024 
who live in ZIP codes where household median income is below $150,000. 
Some individuals have announced similar donations with smaller regional 
footprints, and other individuals have expressed interest in similar 
donations. It is unclear whether this level of giving can be sustained 
in the long run or whether it is concentrated as Trump accounts are 
launching. The choices in the temporary regulations position class 
contributions to Trump accounts for sustained participation by 
nonprofits and governments, both large and small.
    The temporary regulations are expected to increase the number of 
children who have Trump accounts in 2026 by more than 60 million. The 
future impact is more uncertain, but the temporary regulations are 
estimated to result in approximately two million additional accounts 
per birth year cohort into the future.
    As a result of the temporary regulations, the incremental value of 
class contributions is expected to be billions of dollars per year, 
allocated across the Trump accounts of tens of millions of children.

Account Creation

    The temporary regulations prescribe that the Secretary will create 
Trump accounts that are able to receive qualified general contributions 
on behalf of eligible children without any action required from parents 
or guardians. An alternative would be to require a parent or guardian 
to take some action to open a Trump account before an eligible child is 
able to receive a qualified general contribution. The Treasury 
Department and the IRS decided to create Trump accounts for eligible 
children because the benefit to Trump account beneficiaries of 
incremental general funding contributions was expected to exceed the 
cost to the Treasury Department and the IRS of incremental 
administrative burdens.
    A previous version of these regulations, which was proposed and is 
being withdrawn, explained that the Treasury Department and IRS 
believed at the time it was published that it was not possible for the 
Secretary to create Trump accounts for eligible children due to legal 
and administrative constraints. The Treasury Department and IRS, in 
consultation with the financial agent, the initial trustee, and 
appropriate federal regulators, have found a path to overcome those 
constraints. A major innovation for overcoming those constraints is 
using a master group trust. Trump accounts, which are individual 
accounts, are able to hold eligible investments, indirectly through 
their interests in the master group trust, without disclosing taxpayer 
information.
    The most informative precedent for estimating the impact of the 
Secretary creating Trump accounts, relative to requiring action from a 
parent or guardian, is the Alfond Grant program, which began offering 
$500 to every newborn in Maine starting in 2013. The Alfond Grant 
program initially had an opt-in structure where a parent or guardian 
was required to check a box on their state tax return, and enrollment 
during that period was around 40% of eligible families. Trump accounts 
have some advantages over the Alfond Grant program for opt-in 
enrollment: the initial grant is larger, Trump accounts are capable of 
accepting other employer, nonprofit and government contributions, and 
Trump accounts are more salient than the Alfond Grant program. 
Nevertheless, if the Treasury Department and the IRS had chosen to 
require a parent or guardian to take some action to open a Trump 
account, then ongoing enrollment would likely have been close to 50% of 
eligible families. Administrative data from early Trump account 
elections so far in 2026 support this inference from the Alfond Grant 
program. In contrast, when the Secretary begins creating Trump 
accounts, nearly 100% of eligible children will have Trump accounts.
    In addition to the direct impact, which will be the creation of 
more than 60 million Trump accounts, the choice to have the Secretary 
create accounts will increase the appeal of funding contributions to 
classes of Trump account beneficiaries. Stakeholders have expressed 
that eligible donors prefer that their contributions reach all 
children, not just children whose parents have the awareness to opt in. 
Both nonprofits and governments will be more likely to make general 
funding contributions with the confidence that the Secretary creates 
Trump accounts for all eligible children.
    Table 1 shows the approximate number of electronic Forms 4547 
processed prior to July 30, 2026, and the estimated number of eligible 
children in 2026, by adjusted gross income. Proportionately, children 
in lower income groups are the biggest beneficiaries of the regulation 
requiring the Secretary to establish a Trump account for eligible 
children.

                                                     Table 1
----------------------------------------------------------------------------------------------------------------
                                                                 Electronic Forms 4547       Number of eligible
                   Adjusted gross income                       processed prior to July 30     children in 2026
                                                                      (thousands)                (thousands)
----------------------------------------------------------------------------------------------------------------
No adjusted gross income or missing........................                             10                 8,610
$1 under $15,000...........................................                            390                 4,070
$15,000 under $30,000......................................                            710                10,340
$30,000 under $50,000......................................                            840                11,070
$50,000 under $75,000......................................                            780                 8,770
$75,000 under $100,000.....................................                            620                 6,320
$100,000 under $200,000....................................                          1,480                14,570
$200,000 under $500,000....................................                            660                 7,540

[[Page 61718]]

 
$500,000 or more...........................................                            100                 2,070
                                                            ----------------------------------------------------
    Total..................................................                          5,600                73,370
----------------------------------------------------------------------------------------------------------------

    Table 2 shows the approximate number of electronic Forms 4547 
processed prior to July 30, 2026, and the estimated number of eligible 
children in 2026, by state. In most states, the number of processed 
electronic Forms 4547 was less than 10% of the estimated number of 
eligible children as of July 30.

                                                     Table 2
----------------------------------------------------------------------------------------------------------------
                                                                 Electronic Forms 4547       Number of eligible
                           State                               processed prior to July 30     children in 2026
                                                                      (thousands)                (thousands)
----------------------------------------------------------------------------------------------------------------
Alabama....................................................                             80                 1,000
Alaska.....................................................                             20                   150
Arizona....................................................                            130                 1,410
Arkansas...................................................                             60                   630
California.................................................                            450                 7,210
Colorado...................................................                            110                 1,090
Connecticut................................................                             50                   640
Delaware...................................................                             20                   190
District of Columbia.......................................                             10                   100
Florida....................................................                            330                 4,060
Georgia....................................................                            180                 2,230
Hawaii.....................................................                             20                   250
Idaho......................................................                             50                   430
Illinois...................................................                            180                 2,390
Indiana....................................................                            150                 1,440
Iowa.......................................................                             70                   660
Kansas.....................................................                             70                   620
Kentucky...................................................                            100                   910
Louisiana..................................................                             70                   940
Maine......................................................                             20                   220
Maryland...................................................                             90                 1,200
Massachusetts..............................................                             90                 1,170
Michigan...................................................                            170                 1,870
Minnesota..................................................                            110                 1,180
Mississippi................................................                             50                   610
Missouri...................................................                            130                 1,230
Montana....................................................                             30                   210
Nebraska...................................................                             40                   440
Nevada.....................................................                             50                   610
New Hampshire..............................................                             30                   220
New Jersey.................................................                            130                 1,780
New Mexico.................................................                             40                   400
New York...................................................                            250                 3,510
North Carolina.............................................                            200                 2,100
North Dakota...............................................                             20                   170
Ohio.......................................................                            230                 2,310
Oklahoma...................................................                             90                   850
Oregon.....................................................                             70                   720
Pennsylvania...............................................                            220                 2,360
Rhode Island...............................................                             20                   180
South Carolina.............................................                            100                 1,050
South Dakota...............................................                             20                   200
Tennessee..................................................                            160                 1,410
Texas......................................................                            540                 6,780
Utah.......................................................                             80                   840
Vermont....................................................                             10                   100
Virginia...................................................                            160                 1,680
Washington.................................................                            160                 1,460
West Virginia..............................................                             40                   310
Wisconsin..................................................                            110                 1,110
Wyoming....................................................                             20                   120
Other or missing...........................................                             10                 8,630
                                                            ----------------------------------------------------
    Total..................................................                          5,600                73,370
----------------------------------------------------------------------------------------------------------------


[[Page 61719]]

Approved Classes

    The temporary regulations allow contributions to approved classes, 
which are defined by both age and geographic criteria, to receive the 
same tax treatment and facilitation by the Treasury Department and the 
IRS as contributions to qualified classes, which are defined by either 
age or geographic criteria. An alternative would be not to allow 
contributions to approved classes to receive the same tax treatment and 
facilitation by the Treasury Department and the IRS as contributions to 
qualified classes.
    Stakeholders have expressed that eligible donors value the 
flexibility of using both age and geographic criteria. Notably, the 
eligibility criteria announced by the MSDF included both age and 
geographic criteria. This choice and several others increase the appeal 
of funding contributions to classes of Trump account beneficiaries.
    The Treasury Department and the IRS used historical returns for a 
broad index of U.S. equities for birth cohorts ranging from 1926 to 
2006 to quantify the benefit at age 18 of returns on investments made 
at various ages.\8\ Table 3 shows that while an earlier investment 
allows for more growth, there are still typically benefits at age 18 
from making an investment even at age 17.
---------------------------------------------------------------------------

    \8\ Kenneth R. French Data Library. <a href="https://mba.tuck.dartmouth.edu/pages/faculty/ken.french/data_library.html">https://mba.tuck.dartmouth.edu/pages/faculty/ken.french/data_library.html</a>.

                                                     Table 3
----------------------------------------------------------------------------------------------------------------
                                                         Value at age 18 of investment in broad index of U.S.
                                                                               equities
                 Investment scenario                 -----------------------------------------------------------
                                                        10th percentile     50th percentile     90th percentile
----------------------------------------------------------------------------------------------------------------
$1,000 at birth.....................................               2,980               6,180              13,800
$1,000 at age 1.....................................               2,860               5,690              11,990
$1,000 at age 2.....................................               2,680               4,920              10,040
$1,000 at age 3.....................................               2,400               4,750               9,030
$1,000 at age 4.....................................               2,150               4,260               8,040
$1,000 at age 5.....................................               2,020               3,990               7,110
$1,000 at age 6.....................................               1,770               3,620               6,350
$1,000 at age 7.....................................               1,660               3,280               5,380
$1,000 at age 8.....................................               1,680               3,150               4,670
$1,000 at age 9.....................................               1,480               2,740               4,110
$1,000 at age 10....................................               1,350               2,460               3,560
$1,000 at age 11....................................               1,340               2,350               3,040
$1,000 at age 12....................................               1,180               2,050               2,720
$1,000 at age 13....................................               1,050               1,890               2,390
$1,000 at age 14....................................               1,020               1,630               2,060
$1,000 at age 15....................................                 990               1,400               1,810
$1,000 at age 16....................................                 970               1,240               1,590
$1,000 at age 17....................................                 900               1,160               1,330
----------------------------------------------------------------------------------------------------------------
Notes: Percentiles at age 18 are calculated based on birth cohorts 1926 through 2006. For a particular birth
  cohort, the value at age 18 of one dollar invested at birth is calculated as the gross 18-year market return
  for a broad index of U.S. equities.

Stock Contributions

    The temporary regulations allow general funding contributions to be 
made with stock of publicly traded domestic corporations, which will be 
allocated by the Treasury Department to beneficiaries in the specified 
class and generally must be retained for at least five years. An 
alternative would be to require general funding contributions to be 
made with cash only. The Treasury Department and the IRS have concluded 
that qualified general contributions of publicly traded stock benefit 
Trump account beneficiaries because the benefit to Trump account 
beneficiaries of incremental general funding contributions was expected 
to exceed the cost to beneficiaries of riskier returns for general 
funding contributions that would have been received anyway but arrive 
as stock rather than cash.
    For most ordinary investors comparing a diversified portfolio to a 
concentrated portfolio, the diversified portfolio will generally have 
the same expected return at lower risk. Reducing risk is generally 
beneficial for an investor, holding fixed expected returns. To the 
extent that general funding contributions would have been made in cash 
and will instead be made as stock, Trump account beneficiaries will 
bear some additional risk in the form of increased portfolio 
concentration.
    On the other hand, Trump account beneficiaries are likely to 
receive more total contributions than they would if stock contributions 
were prohibited. The Treasury Department and the IRS have been informed 
that several eligible donors who would not otherwise make cash 
contributions are prepared to facilitate contributions of appreciated 
stock similar in magnitude to the general funding contribution of the 
MSDF. Donors are attracted by the hope that a stock contribution with a 
five-year holding period may lead recipients and their families to feel 
that they have a stake in the fate of the corporation to a greater 
extent than if the child's holdings of the corporation were only 
through an index fund. This choice and several others increase the 
appeal of funding contributions to classes of Trump account 
beneficiaries.
    The Treasury Department and the IRS have reviewed claims that 
allowing stock contributions is a method of facilitating tax deductions 
of appreciated stock for individuals funding those contributions. 
However, an individual who wants to fund a general funding contribution 
must act through an eligible donor, which would generally be a 
501(c)(3) organization. The temporary rules have no impact on the 
deductibility of contributions of cash or appreciated stock to 
501(c)(3) organizations. It might be more efficient for Trump account 
trustees to manage the orderly liquidation of donated stock after the 
five-year holding period, but 501(c)(3) organizations are also capable 
of managing orderly liquidations prior

[[Page 61720]]

to a general funding contribution made in cash.

Summary

    The major areas of discretion in the temporary regulations require 
the Secretary to create Trump accounts for eligible children, allow 
contributions to approved classes to receive the same treatment as 
contributions to qualified classes, and allow general funding 
contributions to be made with stock of publicly traded domestic 
corporations. All of these decisions increase the appeal of funding 
contributions to classes of Trump account beneficiaries and are 
expected to result in billions of additional dollars per year in 
general funding contributions, which will be allocated across the Trump 
accounts of tens of millions of children.

III. Paperwork Reduction Act

    The Paperwork Reduction Act of 1995 (44 U.S.C. 3501-3520) generally 
requires that a Federal agency obtain the approval of the OMB before 
collecting information from the public, whether such collection of 
information is mandatory, voluntary, or required to obtain or retain a 
benefit. An agency may not conduct or sponsor, and a person is not 
required to respond to, a collection of information unless the 
collection of information displays a valid control number.
    The collections of information in these temporary regulations 
contain reporting, third-party disclosure and recordkeeping 
requirements that are necessary for Trump account enrollment. These 
collections of information generally would be used by the Secretary to 
automatically enroll beneficiaries into Trump accounts.
    The temporary regulations mention reporting requirements for making 
elections for Trump accounts by a person other than the Secretary, as 
detailed in 26 CFR 1.530A-1T(d)(1)(ii). This reporting requirement is 
already approved by the OMB under OMB Control Number 1545-2336 and is 
not being revised by this temporary regulation.
    The temporary regulations mention reporting requirements for filing 
a general funding contribution request and entering into a Treasury 
acceptance agreement, as detailed in 26 CFR 1.530A-7T(c)(2). This 
reporting requirement is already approved by the OMB under OMB Control 
Number 1505-0285 and is not being revised by this temporary regulation.
    The temporary regulations include reporting by account 
beneficiaries or responsible parties and third-party disclosures and 
associated recordkeeping requirements from trustees to account 
beneficiaries or responsible parties. These collections of information 
are necessary to allow account beneficiaries or responsible parties to 
claim accounts and to inform account beneficiaries or responsible 
parties of any required sales and investments related to qualified 
stock. IRS anticipates that the likely respondents are individuals, 
responsible parties, businesses, and for-profit organizations 
(trustees).
    Table 1 provides a high-level description of the collection 
requirements created or changed within this regulation, and the 
regulatory sections that detail these requirements. Table 2 provides 
the estimated burden placed on respondents for each collection 
requirement. These collection requirements and their associated burdens 
will be approved by the OMB under OMB Control Number 1545-2336 under 
the emergency procedures in 5 CFR 1320.13 and will be renewed under the 
PRA procedures in 5 CFR 1320.10.

                                       Table 1--Description of Collections
----------------------------------------------------------------------------------------------------------------
                                                                                             Regulatory section
   OMB control No.        Collection type         New or revised           Description         with additional
                                                    collection                                     details
----------------------------------------------------------------------------------------------------------------
1545-2336............  Third-party           New....................  Claiming an auto      26 CFR 1.530A-1T(f).
                        Disclosure and                                 account.
                        Recordkeeping.
1545-2336............  Third-party           New....................  Beneficiary           26 CFR 1.530A-
                        Disclosure and                                 disclosure when       7T(d)(5), (d)(6).
                        Recordkeeping.                                 stock held in a
                                                                       Trump account is
                                                                       either de-listed
                                                                       from a national
                                                                       securities exchange
                                                                       or generates
                                                                       property that is
                                                                       not successor
                                                                       qualified stock.
----------------------------------------------------------------------------------------------------------------


                                            Table 2--Estimated Burden
----------------------------------------------------------------------------------------------------------------
                                      Estimated       Estimated                                      Estimated
            Collection                number of     frequency of      Estimated average annual     total annual
                                     respondents      responses         burden per response        burden hours
----------------------------------------------------------------------------------------------------------------
26 CFR 1.530A-1T(f)..............      63,360,000               1  6 minutes....................       6,336,000
26 CFR 1.530A-7T(d)(5), (d)(6)...               5          27,717  1 minute.....................           2,310
----------------------------------------------------------------------------------------------------------------

IV. Regulatory Flexibility Act

    For applicability of the Regulatory Flexibility Act, please refer 
to the cross-referenced notice of proposed rulemaking (CC-00226466-26) 
published elsewhere in this issue of the Federal Register.

V. Unfunded Mandates Reform Act

    Section 202 of the Unfunded Mandates Reform Act of 1995 (UMRA) 
requires that agencies assess anticipated costs and benefits and take 
certain other actions before issuing a final rule that includes any 
Federal mandate that may result in expenditures in any one year by a 
State, local, or Tribal government, in the aggregate, or by the private 
sector, of $100 million in 1995 dollars, updated annually for 
inflation. These temporary regulations do not include any Federal 
mandate that may result in expenditures by State, local, or Tribal 
governments, or by the private sector in excess of that threshold.

VI. Executive Order 13132: Federalism

    Executive Order 13132 (Federalism) prohibits an agency from 
publishing any rule that has federalism implications if the rule either 
imposes substantial, direct compliance costs on State and local 
governments, and is not required by statute, or preempts State law, 
unless the agency meets the consultation and funding requirements of 
section 6 of the Executive order. These temporary regulations do not 
have federalism

[[Page 61721]]

implications and do not impose substantial direct compliance costs on 
State and local governments or preempt State law within the meaning of 
the Executive order.

VII. Small Business Administration

    Pursuant to section 7805(f) of the Code, these temporary 
regulations have been submitted to the Chief Counsel for Advocacy of 
the Small Business Administration for comment on their impact on small 
business.

VIII. Congressional Review Act

    Pursuant to the Congressional Review Act (5 U.S.C. 801 et seq.), 
the Office of Information and Regulatory Affairs designated this rule 
as a major rule as defined by 5 U.S.C. 804(2). For the reasons stated 
in the Good Cause section of this preamble, the Treasury Department and 
the IRS find good cause under 5 U.S.C. 808(2) for these temporary 
regulations to take effect upon publication, notwithstanding the 
delayed effective date otherwise applicable to a major rule under 5 
U.S.C. 801(a)(3).

Statement of Availability of IRS Documents

    Revenue Rulings, Revenue Procedures, Notices, and other guidance 
cited in this document are published in the Internal Revenue Bulletin 
(or Cumulative Bulletin) and are available from the Superintendent of 
Documents, U.S. Government Publishing Office, Washington, DC 20402, or 
by visiting the IRS website at <a href="https://www.irs.gov">https://www.irs.gov</a>.

Drafting Information

    The principal author of these temporary regulations is Isaac Stein 
of the Office of Associate Chief Counsel (Employee Benefits, Exempt 
Organizations, and Employment Taxes). Other personnel from the Treasury 
Department and the IRS participated in their development.

List of Subjects in 26 CFR Part 1

    Income taxes and reporting and recordkeeping requirements.

Adoption of Amendments to the Regulations

    Accordingly, the Treasury Department and the IRS amend 26 CFR part 
1 as follows:

PART 1--INCOME TAXES

0
Paragraph 1. The authority citation for part 1 is amended by adding 
entries for Sec. Sec.  1.530A-1T and 1.530A-7T in numerical order to 
read, in part, as follows:

    Authority:  26 U.S.C. 7805 * * *
* * * * *
    Section 1.530A-1T is also issued under 26 U.S.C. 408(a)(2), 
530A(a), (b)(1)(A)(i), (b)(1)(B), (b)(2)(C)(i), (b)(2)(C)(ii), and 
(i)(1).
    Section 1.530A-7T is also issued under 26 U.S.C. 530A(a), 
(f)(1)(A), and (f)(3)(B).
* * * * *

0
Par. 2. Section 1.530A-1T is added to read as follows:


Sec.  1.530A-1T  Trump accounts; general requirements; establishment of 
an initial Trump account; auto enrollment and auto accounts.

    (a) Overview. This section provides rules regarding the general 
requirements for Trump accounts, the establishment of an initial Trump 
account, auto enrollment, and auto accounts. Paragraph (b) of this 
section provides definitions related to Trump accounts. Paragraph (c) 
of this section provides general requirements for Trump accounts, 
including rules on initial Trump accounts and the written governing 
instrument. Paragraph (d) of this section provides rules for the 
establishment of an initial Trump account, including auto enrollment by 
the Secretary of the Treasury or the Secretary's delegate. Paragraph 
(e) of this section provides rules for auto accounts. Paragraph (f) of 
this section provides rules for claiming auto accounts. Paragraph (g) 
of this section provides the applicability and expiration dates of this 
section.
    (b) Definitions. For purposes of section 530A and the regulations 
thereunder, the following definitions apply--
    (1) Account beneficiary. The term account beneficiary means the 
individual for whose benefit a Trump account was established.
    (2) Eligible individual. The term eligible individual means any 
individual--
    (i) Who has not attained age 18 before the end of the calendar year 
in which an election under paragraph (d) of this section is made;
    (ii) For whom a social security number, within the meaning of 
section 24(h)(7), has been issued before the date on which an election 
under paragraph (d) of this section is made; and
    (iii) For whom an election is made under paragraph (d) of this 
section.
    (3) Growth period. The term growth period means, with respect to an 
account beneficiary, the period that begins when the initial Trump 
account under paragraph (b)(5)(i) or (ii) of this section is 
established and ends on December 31 of the calendar year in which the 
account beneficiary attains age 17. For example, a child born on 
October 1, 2025, would attain age 17 on October 1, 2042, and therefore 
the last day of the growth period with respect to the child would be 
December 31, 2042.
    (4) IRA. The term IRA means an individual retirement account under 
section 408(a) and includes a custodial account that is treated as a 
trust pursuant to section 408(h). Accordingly, solely for purposes of 
section 530A and the regulations thereunder, the term IRA does not 
include an individual retirement annuity under section 408(b).
    (5) Initial Trump account. The term initial Trump account means a 
Trump account created or organized by the Secretary pursuant to section 
530A(b)(1)(A)(i) and maintained by a trustee selected by the Secretary 
pursuant to section 530A(g). An initial Trump account includes--
    (i) An initial Trump account established pursuant to an election 
made by a person other than the Secretary (such as by using Form 4547, 
Trump Account Election(s), or successor form prescribed by the 
Secretary, or through an electronic application or web page made 
available by the Secretary) as described in paragraph (d)(1)(ii) of 
this section;
    (ii) An auto account, which is an initial Trump account created or 
organized by the Secretary as described in paragraph (d)(2) of this 
section and maintained by a trustee selected by the Secretary pursuant 
to section 530A(g). An auto account does not include an initial Trump 
account established pursuant to an election that the Secretary is 
deemed to have made as described in paragraph (d)(1)(iii) of this 
section if the account was established before auto enrollment began (as 
described in paragraph (d)(2)(i) of this section); and
    (iii) A claimed initial Trump account, which is an initial Trump 
account created or organized by the Secretary to receive a qualified 
rollover contribution from an auto account as described in paragraph 
(f) of this section and maintained by a trustee selected by the 
Secretary pursuant to section 530A(g).
    (6) Master group trust. The term master group trust means a trust 
that the Secretary establishes for the exclusive benefit of account 
beneficiaries of auto accounts for the purpose of holding investments 
of those auto accounts and that meets the applicable requirements of 
Revenue Ruling 81-100, 1981-1 C.B. 326, as modified from time to time, 
and is exempt from taxation under section 408(e).
    (7) Qualified ABLE rollover contribution. The term qualified ABLE 
rollover contribution means a trustee-to-trustee transfer of the entire 
balance of

[[Page 61722]]

a Trump account, made during the calendar year in which an account 
beneficiary attains age 17 to an ABLE account of that account 
beneficiary.
    (8) Qualified general contribution. The term qualified general 
contribution is defined in section 530A(f) and Sec.  1.530A-7T(b)(6).
    (9) Qualified rollover contribution. The term qualified rollover 
contribution means a direct trustee-to-trustee transfer of an account 
beneficiary's entire Trump account balance to a Trump account for the 
same account beneficiary. A qualified rollover contribution may be 
either--
    (i) A transfer from an auto account to a claimed initial Trump 
account; or
    (ii) A transfer from any Trump account to a rollover Trump account.
    (10) Qualified stock contribution. The term qualified stock 
contribution is defined in Sec.  1.530A-7T(b)(9).
    (11) Responsible party. The term responsible party means the person 
who is authorized under the terms of the written governing instrument 
for a Trump account to act on behalf of the account beneficiary. A 
person's status as a responsible party under the written governing 
instrument does not, by itself, establish that the person is entitled 
under section 6103 to inspect or receive the account beneficiary's 
returns or return information.
    (12) Rollover Trump account. The term rollover Trump account means 
a Trump account that is not an initial Trump account but is created or 
organized in the United States and established for the account 
beneficiary during his or her growth period pursuant to section 
530A(b)(1)(A)(ii). A rollover Trump account must first be funded by a 
qualified rollover contribution from the account beneficiary's existing 
Trump account before receiving any other contribution. However, see 
paragraph (f)(3) of this section for a special rule regarding a 
qualified rollover contribution from an unfunded auto account. An 
individual may have only one Trump account containing funds at a time.
    (13) Secretary. The term Secretary means the Secretary of the 
Treasury or the Secretary's delegate.
    (14) Traditional IRA. The term traditional IRA means an IRA that is 
not a Roth IRA under section 408A.
    (15) Trump account. The term Trump account means an account 
described in paragraph (c) of this section.
    (c) Trump accounts--(1) In general. A Trump account is a type of 
traditional IRA described in section 530A(b)(1) for the exclusive 
benefit of an eligible individual and, after the death of the 
individual, his or her beneficiaries. A Trump account is subject to the 
same rules as other traditional IRAs, except as provided by section 
530A or the regulations thereunder. For example, a Trump account is 
exempt from tax under section 408(e)(1) and subject to the prohibited 
transaction restrictions of section 408(e)(2). A Trump account can be 
either an initial Trump account or a rollover Trump account.
    (2) Written governing instrument--(i) In general. Except as 
provided in this paragraph (c)(2) or in guidance published in the 
Internal Revenue Bulletin, the written governing instrument 
establishing a Trump account must meet the requirements of section 
408(a)(1) through (6), which apply to other IRAs, as well as the 
requirements of section 530A(b)(1)(C)(i) through (iii), which apply 
only to Trump accounts. The written governing instrument generally must 
reflect both the rules that apply during the growth period and the 
rules that apply after the growth period.
    (ii) Designation as a Trump account. The written governing 
instrument establishing a Trump account must clearly designate the 
account as a Trump account at the time of establishment. Accordingly, 
an existing account (such as an IRA that is not a Trump account) cannot 
be amended to become a Trump account. In addition, a Trump account must 
be titled to clearly identify the account as a Trump account for the 
benefit of the account beneficiary.
    (iii) Growth period. With respect to the growth period, a written 
governing instrument establishing a Trump account must generally 
restrict the timing and annual amount of contributions to the Trump 
account in accordance with section 530A(b)(1)(C)(i) (and prohibit 
contributions under a Simplified Employee Pension (SEP) arrangement 
under section 408(k) or a Savings Incentive Match Plan for Employees 
(SIMPLE) IRA plan under section 408(p) in accordance with section 
530A(h)(1)), prohibit distributions from the Trump account in 
accordance with section 530A(b)(1)(C)(ii), and require that the funds 
in the Trump account be invested only in an eligible investment in 
accordance with section 530A(b)(1)(C)(iii), as applied under Sec.  
1.530A-7T(d). Additionally, with respect to the growth period, the 
written governing instrument establishing a Trump account must meet the 
requirements of section 408(a)(1) through (6), except that a Trump 
account satisfies the cash contribution requirement in section 
408(a)(1) if the written governing instrument establishing the Trump 
account meets the requirement that, except in the case of a qualified 
rollover contribution, no contribution will be accepted unless it is in 
cash or is qualified stock received in a qualified stock contribution 
described in Sec.  1.530A-7T(d).
    (iv) Post growth period. With respect to the period after the 
growth period, a written governing instrument establishing a Trump 
account must meet the requirements of section 408(a)(1) through (6), 
except that the section 530A(h)(1) prohibition against a Trump account 
receiving contributions under a SEP arrangement under section 408(k) or 
a SIMPLE IRA plan under section 408(p) continues to apply to a Trump 
account after the growth period.
    (3) Automatic approval for certain nonbank trustees. Any person 
approved by the IRS as of December 31, 2025, to be a nonbank trustee of 
an IRA is automatically approved to be a nonbank trustee of a Trump 
account.
    (4) Differences from other traditional IRAs--(i) During the growth 
period. During the growth period, there are special rules for Trump 
accounts with respect to--
    (A) Contributions (see section 530A(c));
    (B) Investments (see section 530A(b)(3));
    (C) Distributions (see section 530A(d), including a qualified ABLE 
rollover contribution);
    (D) Reporting (see section 530A(i));
    (E) Coordination with IRA rules (see section 530A(h)); and
    (F) Qualified general contributions (see section 530A(f)).
    (ii) After the growth period. After the growth period (that is, 
starting January 1 of the year in which the account beneficiary attains 
age 18), the rules under section 408 that apply to other traditional 
IRAs are generally applicable to Trump accounts, except as provided in 
section 530A(h).
    (5) Application of the birthday rule. For purposes of section 530A, 
an individual attains an age on his or her birthday. For example, a 
child who is born on January 1, 2009, attains age 18 on January 1, 
2027.
    (6) Closing a Trump account. A funded Trump account may not be 
closed during the growth period unless all funds in the account have 
first been distributed in a distribution permitted under section 
530A(b)(1)(C)(ii). After the growth period, the distribution 
restrictions under section 530A(b)(1)(C)(ii) do not apply. 
Additionally, after the growth period, an unfunded Trump account that 
is not an auto account may be closed by the trustee if provided by the 
terms of the

[[Page 61723]]

written governing instrument. See paragraph (e)(4) of this section for 
a trustee closing an unfunded auto account at the end of the growth 
period or upon death of the account beneficiary.
    (d) Establishment of initial Trump accounts; auto enrollment--(1) 
Methods to establish an initial Trump account--(i) Election by the 
Secretary to establish an auto account. Pursuant to section 
530A(b)(2)(C)(i), the Secretary may make an election to establish an 
auto account, if the Secretary determines, based on information 
available to the Secretary, that the individual for whom the account is 
to be established has met the requirements of paragraphs (b)(2)(i) and 
(ii) of this section to be an eligible individual, and no prior 
election has been made under paragraph (d)(1)(ii) of this section.
    (ii) Election by a person other than the Secretary to establish an 
initial Trump account. Pursuant to section 530A(b)(2)(C)(ii), a person 
other than the Secretary may elect to establish an initial Trump 
account, as defined in paragraph (b)(5)(i) of this section, for an 
individual who has met the requirements of paragraphs (b)(2)(i) and 
(ii) of this section to be an eligible individual if the person files a 
completed Form 4547, Trump Account Election(s), or successor form 
prescribed by the Secretary, or otherwise provides required information 
through an electronic application or web page made available by the 
Secretary, in accordance with applicable instructions, and no prior 
election to establish an initial Trump account has been made for such 
individual by another person or the Secretary. Once the election is 
made, such election is irrevocable.
    (iii) Deemed election. If an initial Trump account was established 
pursuant to an election under paragraph (d)(1)(ii) of this section, but 
the election was made by an individual who, under the applicable 
instructions, was not authorized to make the election at the time that 
the election was made, then the Secretary is deemed to have made the 
election to establish the initial Trump account pursuant to section 
530A(b)(2)(C)(i) and the Trump account that was already established 
will not cease to be a Trump account. This deemed-election rule 
concerns the validity of the Trump account and does not itself 
establish that the person who submitted the original election was 
entitled under section 6103 to receive the account beneficiary's return 
information or was authorized to execute a consent to disclosure on the 
beneficiary's behalf.
    (iv) Establishment of a claimed initial Trump account. A person may 
irrevocably claim an auto account pursuant to paragraph (f) of this 
section and the account may be activated pursuant to paragraph (d)(3) 
of this section. One way to claim an auto account is by establishing a 
claimed initial Trump account (which is a separate account from the 
auto account) and having the funds in the auto account transferred to 
the claimed initial Trump account. See paragraph (f) of this section 
for other ways to claim an auto account.
    (2) Auto enrollment; establishment of an auto account--(i) In 
general. On or about October 1, 2026, the Secretary shall make an 
election under paragraph (d)(1)(i) of this section to establish an auto 
account for each individual who the Secretary has determined has met 
the requirements of paragraphs (b)(2)(i) and (ii) of this section to be 
an eligible individual, and for whom no prior election has been made 
under paragraph (d)(1)(ii) of this section. An auto account shall be 
established for each such individual. Thereafter, the Secretary shall 
make subsequent periodic elections under paragraph (d)(1)(i) of this 
section to establish auto accounts for individuals who the Secretary 
determines meet the requirements of paragraphs (b)(2)(i) and (ii) of 
this section to be an eligible individual and for whom no prior 
election has been made under paragraph (d)(1)(ii) of this section, and 
shall establish auto accounts for eligible individuals for whom a Trump 
account has not been established.
    (ii) Account established after auto enrollment has begun. Any 
initial Trump account established after auto enrollment has begun 
pursuant to an election under paragraph (d)(1)(i), (ii), or (iii) of 
this section is an auto account, regardless of whether the election was 
made before, on, or after October 1, 2026. If an election under 
paragraph (d)(1)(ii) of this section was made before October 1, 2026, 
but an initial Trump account was not established pursuant to that 
election on or before September 30, 2026 (for example, because the 
account agreement was not signed and thus the account was not 
activated, as described in paragraph (d)(3) of this section), an auto 
account shall be established pursuant to that election.
    (3) Account activation is required to establish the initial Trump 
account. An election under paragraph (d)(1)(ii) of this section (for 
example, using Form 4547) does not by itself establish an initial Trump 
account (and contributions cannot be made until the account is 
established). To establish an initial Trump account that is not an auto 
account, the account must be activated (which includes signing the 
account agreement for the initial Trump account), pursuant to 
instructions from the trustee, after the election is made. For any auto 
account, the Secretary (as the responsible party) is deemed to have 
activated the account. Making a claim with respect to an auto account 
pursuant to paragraph (f) of this section (for example, using the 
electronic app) also does not by itself establish a claimed initial 
Trump account (and the qualified rollover contribution from the auto 
account or other contributions cannot be made until the claimed initial 
Trump account is established). To establish a claimed initial Trump 
account, the account must be activated (pursuant to instructions from 
the trustee) after the claim is made, as described in paragraphs 
(d)(1)(iv) and (f)(2) of this section.
    (e) Administration of auto accounts--(1) Responsible party. The 
Secretary is the responsible party for an auto account.
    (2) Contributions. During the growth period, an auto account may 
only accept qualified general contributions under section 530A(f) and a 
$1,000 pilot program contribution, if a pilot program election has been 
made by a pilot program-electing individual pursuant to section 6434. 
After the growth period, the auto account generally may not accept 
contributions.
    (3) Investment--(i) In general. An auto account's sole investment 
must be its equitable interest in the master group trust, and the 
written governing instrument for the auto account must provide that the 
account adopts the provisions of the master group trust. The master 
group trust may hold only eligible investments described in section 
530A(b)(3), cash to the extent permitted under section 
530A(b)(1)(C)(iii), and qualified stock contributed pursuant to a 
qualified stock contribution described in Sec.  1.530A-7T(d), including 
successor qualified stock. With respect to the eligible investment 
requirement under section 530A(b)(1)(C)(iii), each auto account's 
interest in the master group trust consists of its undivided 
proportionate beneficial interest in those investments of the master 
group trust that are attributable to contributions allocated to 
qualified classes of which the account beneficiary was a member and any 
$1,000 pilot program contribution (if a pilot program election has been 
made by a pilot program-electing individual pursuant to section 6434) 
made to that account.

[[Page 61724]]

    (ii) End of the minimum holding period for qualified stock. The 
trustee of the master group trust must sell any qualified stock as 
described in Sec.  1.530A-7T(d) within a reasonable period of time 
after the end of the minimum holding period applicable to the auto 
account's interest in that stock (as described in Sec.  1.530A-
7T(d)(3)). The proceeds of such sale must be promptly invested in an 
eligible investment, as described in section 530A(b)(3), pursuant to 
the requirement of section 530A(b)(1)(C)(iii). An investment under this 
paragraph (e)(3)(ii) will be considered prompt if it occurs within 30 
calendar days after the sale of the qualified stock.
    (4) Closing an auto account. When an auto account is claimed 
pursuant to paragraph (f) of this section, the trustee will close the 
auto account as soon as practicable after a claim and transfer of all 
account funds described in paragraph (f) of this section has been 
completed. At the end of the growth period of the account beneficiary 
or, if earlier, when the trustee has knowledge of the death of the 
account beneficiary, an unfunded auto account will be closed by the 
trustee as soon as practicable thereafter.
    (5) Death of account beneficiary of a funded auto account during 
growth period. The account beneficiary's estate is the beneficiary of 
the account beneficiary's auto account. If an account beneficiary dies 
during the growth period before the account beneficiary's funded auto 
account has been claimed pursuant to paragraph (f) of this section, the 
account will cease to be a Trump account on the day that the account 
beneficiary dies but will remain an IRA, which may be claimed pursuant 
to paragraph (f) of this section. However, if the auto account is 
unfunded when the account beneficiary dies, the account will be closed 
pursuant to paragraph (e)(4) of this section.
    (f) Claiming an auto account--(1) In general. A guardian or legal 
custodian having authority under applicable law to manage the account 
beneficiary's property or financial affairs or the account beneficiary, 
if the account beneficiary has legal capacity, may file a claim for an 
auto account by providing required information through an electronic 
application or web page made available by the Secretary, in accordance 
with applicable instructions. A guardian or legal custodian making the 
claim must authenticate their identity and establish entitlement to the 
account beneficiary's return information to inspect or receive the 
account beneficiary's return information. The guardian or legal 
custodian must also execute any consent required under section 6103(c) 
for disclosures necessary to process the claim and transfer the account 
balance. During the growth period, claiming an auto account results in 
the entire balance of the auto account being transferred in a qualified 
rollover contribution either to a claimed initial Trump account with a 
trustee selected by the Secretary pursuant to section 530A(g) or to a 
rollover Trump account with a trustee other than a trustee selected by 
the Secretary pursuant to section 530A(g) that has been established for 
the account beneficiary. The qualified rollover contribution will only 
occur once the receiving account is established (which, in the case of 
a claimed initial Trump account, will require activation of the account 
for the account to be established, see paragraph (d)(3) of this 
section). After the growth period, claiming an auto account results in 
the entire balance of the auto account being transferred into an IRA 
that is not a Trump account that has been established for the account 
beneficiary.
    (2) Activation of claimed initial Trump account if there are 
multiple claims. Until there has been a transfer of funds from the auto 
account into a receiving account, another claim may be filed under 
paragraph (f)(1) of this section. If multiple claims are filed under 
paragraph (f)(1) of this section with respect to an auto account, the 
responsible party for the claimed initial Trump account will be the 
first person who is authorized under paragraph (f)(1) of this section 
to claim the auto account and activates the receiving account (see 
paragraph (d)(3) of this section).
    (3) Claiming an unfunded auto account. If an unfunded auto account 
is claimed pursuant to paragraph (f)(1) of this section, a claimed 
initial Trump account or rollover Trump account may be created and 
treated as being first funded by a qualified rollover contribution from 
the auto account for purposes of section 530A(b)(1)(A)(ii)(II).
    (4) Responsible party. In general, if a guardian or legal custodian 
having authority under applicable law to manage the account 
beneficiary's property or financial affairs makes a claim for the auto 
account, that person will be the initial responsible party of the 
claimed initial Trump account or rollover Trump account that receives 
the qualified rollover contribution from the auto account when the 
account is established.
    (5) Death of account beneficiary. If the account beneficiary dies 
before the auto account has been claimed, a person authorized under 
applicable law to act with respect to the account beneficiary's estate 
or property may claim the funds in the account through an electronic 
application or web page made available by the Secretary, in accordance 
with applicable instructions, provided that the person also establishes 
entitlement under section 6103(e)(3) and (e)(7), or other applicable 
authority, to receive the decedent's return information.
    (g) Applicability and expiration dates. This section applies to 
taxable years beginning on or after January 1, 2026. This section 
expires on September 30, 2029.

0
Par. 3. Section 1.530A-7T is added to read as follows:


Sec.  1.530A-7T   Qualified general contributions and qualified stock 
contributions.

    (a) Overview. This section provides rules for qualified general 
contributions and qualified stock contributions. Paragraph (b) of this 
section provides definitions related to qualified general contributions 
and qualified stock contributions. Paragraph (c) of this section 
provides rules specific to qualified general contributions. Paragraph 
(d) of this section provides rules specific to qualified stock 
contributions. Paragraph (e) of this section provides rules for 
determining whether a general funding contribution made by a section 
501(c)(3) organization will further a charitable purpose. Paragraph (f) 
of this section provides the applicability and expiration dates of this 
section.
    (b) Definitions. For purposes of section 530A and the regulations 
thereunder, the following definitions apply--
    (1) Approved class. The term approved class means a class that 
consists of not less than 5,000 account beneficiaries and that includes 
all account beneficiaries who--
    (i) Are still in their growth period when the contribution is made 
to the Trump account;
    (ii) Reside in one or more States or other qualified geographic 
areas specified by the terms of and on the record date(s) provided in 
the Treasury acceptance agreement with respect to the general funding 
contribution; and
    (iii) Were born in one or more calendar years specified by the 
terms of the Treasury acceptance agreement with respect to the general 
funding contribution.
    (2) Eligible donor. The term eligible donor means--
    (i) An entity described in section 170(c)(1) (other than a 
possession of the United States or a political subdivision thereof) or 
an Indian Tribal government, or

[[Page 61725]]

    (ii) An organization described in section 501(c)(3) and exempt from 
tax under section 501(a).
    (3) General funding contribution. The term general funding 
contribution means a contribution that--
    (i) Is made by an eligible donor; and
    (ii) Specifies a qualified class of account beneficiaries to whose 
Trump accounts such contribution is to be distributed. For this 
purpose, an approved class is treated as a qualified class.
    (4) Minimum holding period requirement. The term minimum holding 
period requirement means the period of time described in paragraph 
(d)(3) of this section during which the qualified stock may not be sold 
or otherwise disposed of.
    (5) Qualified class. The term qualified class means any of the 
following classes of account beneficiaries--
    (i) All account beneficiaries who are still in their growth period 
when the contribution is made to the Trump account.
    (ii) All account beneficiaries who--
    (A) Are still in their growth period when the contribution is made 
to the Trump account; and
    (B) Reside in one or more States or other qualified geographic 
areas specified by the terms of and on the record date(s) provided in 
the Treasury acceptance agreement with respect to the general funding 
contribution.
    (iii) All account beneficiaries who--
    (A) Are still in their growth period when the contribution is made 
to the Trump account; and
    (B) Were born in one or more calendar years specified by the terms 
of the Treasury acceptance agreement with respect to the general 
funding contribution.
    (6) Qualified general contribution. The term qualified general 
contribution means a contribution made by the Secretary of the Treasury 
or the Secretary's delegate pursuant to a general funding contribution 
from an eligible donor and distributed to the Trump accounts of a 
qualified class of account beneficiaries in the manner described in 
paragraph (c) of this section. A qualified general contribution also 
includes a contribution made by the Secretary pursuant to a general 
funding contribution that specifies an approved class to whose Trump 
accounts the contribution is to be distributed, and otherwise satisfies 
the requirements of paragraph (c) of this section (approved class 
contribution). A qualified general contribution also includes a 
qualified stock contribution.
    (7) Qualified geographic area. The term qualified geographic area 
means a geographic area in which not less than 5,000 account 
beneficiaries eligible to receive the applicable qualified general 
contribution reside as of the record date and that is designated by the 
Secretary as a qualified geographic area.
    (8) Qualified stock--(i) In general. The term qualified stock means 
stock that meets the requirements in paragraph (b)(8)(ii) of this 
section.
    (ii) Requirements for qualified stock--(A) Domestic corporation. 
The issuer of the stock is a corporation that is domestic within the 
meaning of section 7701(a)(3) and (4).
    (B) Publicly traded. The stock is listed on a national securities 
exchange that is registered under section 6 of the Securities Exchange 
Act of 1934 (15 U.S.C. 78f). See Sec.  1.1092(d)-1(b)(1)(i).
    (C) Transferable without pre-existing restrictions. The stock is 
not subject to any pre-existing transfer restriction, such as being a 
restricted security as defined in 17 CFR 230.144(a)(3). For purposes of 
this paragraph (b)(8)(ii)(C), the minimum holding period requirement in 
paragraph (d)(3) of this section is not a pre-existing transfer 
restriction.
    (D) Satisfaction of the requirements for qualified stock. To be 
treated as qualified stock, stock must satisfy the requirements in 
paragraphs (b)(8)(ii)(A) through (C) of this section at the time of 
contribution to the Treasury Department as part of the general funding 
contribution. Following the contribution, the stock will continue to be 
treated as qualified stock so long as the requirement in paragraph 
(b)(8)(ii)(B) of this section is satisfied.
    (9) Qualified stock contribution. The term qualified stock 
contribution means a qualified general contribution of qualified stock 
that otherwise satisfies the requirements of paragraphs (c) and (d) of 
this section.
    (10) Record date. The term record date means the date(s) specified 
in a Treasury acceptance agreement as of which the Secretary determines 
the account beneficiaries eligible to receive a qualified general 
contribution.
    (11) Treasury acceptance agreement. The term Treasury acceptance 
agreement means the written agreement or other documentation under 
which the Secretary accepts a general funding contribution as described 
in paragraph (c)(2) of this section.
    (c) Qualified general contributions--(1) In general. All qualified 
general contributions must meet the requirements of paragraphs (c)(2) 
through (4) of this section.
    (2) Made by the Secretary pursuant to a general funding 
contribution--(i) In general. A qualified general contribution will 
only be made by the Secretary pursuant to a Treasury acceptance 
agreement, as described in paragraph (c)(2)(iv) of this section, that 
has been validly entered into by the eligible donor and the Secretary, 
and is made in accordance with the terms of that agreement.
    (ii) Request to make a general funding contribution. An eligible 
donor may request to make a general funding contribution on the form 
prescribed by the Secretary or through an electronic application or web 
page made available by the Secretary.
    (iii) Treasury Department approval. The Secretary will review the 
request and may, in the Secretary's sole discretion, approve the 
request after determining that the request satisfies the requirements 
of this section and considering objective criteria, including the cost 
of implementation and operational feasibility of the contribution. If 
the request includes qualified stock, then the Secretary will consider 
the cost of transferring and administering the shares of qualified 
stock.
    (iv) Treasury acceptance agreement. The Treasury acceptance 
agreement must identify the eligible donor, the aggregate funding 
amount or funding commitment, the qualified class, the record date or 
dates, whether the identity of the eligible donor will be reported to 
account beneficiaries, and any other information required by the 
Secretary. If the general funding contribution consists of qualified 
stock, the Treasury acceptance agreement must also include information 
about the name and employer identification number (EIN) of the issuer 
of the qualified stock, the number of shares of qualified stock that 
will be contributed, and any other information required by the 
Secretary.
    (3) Made to a Trump account of an account beneficiary in the 
qualified class of account beneficiaries--(i) In general. A qualified 
general contribution is made to the Trump account of each account 
beneficiary in the qualified class of account beneficiaries specified 
in the Treasury acceptance agreement. The qualified class for a general 
funding contribution is the qualified class identified in the Treasury 
acceptance agreement. If the qualified class proposed in the eligible 
donor's request differs from the qualified class identified in the 
Treasury acceptance agreement, the qualified class identified in the 
Treasury acceptance agreement controls.
    (ii) Approved class contributions. For purposes of section 
530A(f)(1)(B), an approved class used for an approved

[[Page 61726]]

class contribution is treated as a qualified class.
    (iii) Manner of contribution. A qualified general contribution must 
be made in cash to a Trump account, except in the case of qualified 
stock contributed as part of a qualified stock contribution.
    (4) Is in an equal amount--(i) In general. A qualified general 
contribution must be made in an equal amount to the Trump account of 
each account beneficiary in the qualified class. Thus, every account 
beneficiary in the qualified class must receive the same amount, which 
may be provided in cash, shares of qualified stock, or a combination of 
cash and shares. Details regarding the form and amount of the qualified 
general contributions will be addressed in the Treasury acceptance 
agreement. The amount of the qualified general contribution made to the 
Trump account of each account beneficiary is determined based on the 
ratio of--
    (A) The amount of the general funding contribution allocated under 
the Treasury acceptance agreement to the applicable record date; to
    (B) The number of account beneficiaries in the qualified class who 
are determined under paragraph (c)(4)(iv) of this section to be 
eligible to receive the qualified general contribution on the 
applicable record date.
    (ii) Approved class contributions. For purposes of section 
530A(f)(1)(C), an approved class used for an approved class 
contribution is treated as a qualified class.
    (iii) Multiple record dates. If eligibility is determined using 
multiple record dates, each account beneficiary who receives a 
qualified general contribution for any of the record dates pursuant to 
the general funding contribution must receive the same amount.
    (iv) Determination of account beneficiaries in a qualified class--
(A) In general. Whether an account beneficiary is part of a qualified 
class will be determined for each qualified general contribution based 
on the record date for that contribution, which may be a single date or 
multiple dates. For example, with respect to the first record date, 
contributions would be made to all account beneficiaries determined to 
be eligible as of that date, while with respect to subsequent record 
dates, contributions would be made only to those account beneficiaries 
who are eligible as of that subsequent record date and did not receive 
a contribution with respect to any preceding record date.
    (B) Information based on Treasury Department records. The Secretary 
will determine who is an account beneficiary eligible to receive a 
qualified general contribution based on information obtained during the 
election process of Sec.  1.530A-1T(d)(1)(i) and (ii), as updated by 
information reported to the Secretary under section 530A(i) as of the 
applicable record date.
    (d) Qualified stock contributions--(1) Overview. This paragraph (d) 
provides rules for qualified stock contributions, including 
requirements and procedures for making a qualified stock contribution, 
and rules for the administration of qualified stock contributions.
    (2) Eligible investment requirement of section 530A(b)(1)(C)(iii). 
The eligible investment requirement of section 530A(b)(1)(C)(iii) is 
not violated by the acceptance and holding of qualified stock received 
in a qualified stock contribution.
    (3) Minimum holding period requirement--(i) In general. The minimum 
holding period requirement lasts until the earlier of--
    (A) The date that is 5 years after the qualified stock contribution 
is received by the Trump account; and
    (B) The end of the growth period for the account beneficiary of the 
Trump account.
    (ii) Stock disposition during the minimum holding period. If 
qualified stock is disposed of in violation of the minimum holding 
period requirement, the trustee must repurchase a number of shares of 
the same class of qualified stock equal to the number of shares sold or 
otherwise disposed of as soon as practicable.
    (iii) Satisfaction of the minimum holding period requirement. Upon 
satisfaction of the minimum holding period requirement, the qualified 
stock may be sold or otherwise disposed of. During the growth period, 
the proceeds of a sale or other disposition must be invested in an 
eligible investment. See the eligible investment requirement during the 
growth period in section 530A(b)(1)(C)(iii).
    (iv) Exceptions to the minimum holding period requirement. The 
minimum holding period requirement does not prohibit a disposition 
required under paragraphs (d)(5) or (6) of this section. In addition, 
notwithstanding that requirement, qualified stock may be disposed of--
    (A) To effectuate a qualified ABLE rollover contribution as defined 
in section 530A(d)(4)(B);
    (B) To permit cash in lieu of fractional shares that cannot be 
transferred in kind as part of a qualified rollover contribution (for 
example, if fractional shares cannot be transferred as part of a 
qualified rollover contribution, the transferring trustee may sell the 
fractional shares and transfer cash as part of the qualified rollover 
contribution instead);
    (C) If the responsible party directs the trustee to accept a tender 
offer for the qualified stock; or
    (D) If the issuer of the qualified stock is acquired (by merger, 
purchase, or otherwise).
    (v) Minimum holding period requirement with respect to qualified 
rollover contributions. A qualified rollover contribution does not 
change or reset the minimum holding period for qualified stock.
    (4) Successor qualified stock. If the Trump account receives stock 
(new stock) by reason of owning qualified stock (original stock), the 
new stock will be treated as qualified stock if the new stock satisfies 
the requirements in paragraph (b)(8)(ii) of this section (successor 
qualified stock). New stock will be treated as successor qualified 
stock under this paragraph (d)(4) regardless of whether the new stock 
is received in a nonrecognition transaction (as defined in section 
7701(a)(45)), and regardless of whether the new stock is issued by the 
same corporation as the original stock. Successor qualified stock is 
subject to the same minimum holding period as the original stock 
measured from the date of the contribution of the original stock (for 
example if Company A stock was received by the Trump account on date X, 
any successor qualified stock received by reason of owning Company A 
stock would be treated as having been received by the Trump account on 
date X).
    (5) Consequences of notification of removal from listing. If the 
trustee becomes aware of the filing of a notification of removal of 
qualified stock that it holds from listing on a national securities 
exchange described in paragraph (b)(8)(ii)(B) of this section (see SEC 
Form 25), the trustee must promptly sell or dispose of the stock, 
invest the cash proceeds from that disposition in an eligible 
investment described in section 530A(b)(3), and disclose how the 
proceeds were invested to the account beneficiary (for an auto account, 
disclosure to the Secretary, as the responsible party, is not 
required). For purposes of this paragraph (d)(5), a sale or disposition 
of the stock and the investment of the proceeds will be considered 
prompt if the sale or disposition and investment of the proceeds occur 
as soon as practicable.

[[Page 61727]]

    (6) Corporate distributions and other transactions. If, by reason 
of owning qualified stock, the Trump account receives cash or other 
property that is not successor qualified stock, then the trustee must 
promptly sell or dispose of the other property, invest the net proceeds 
(and the distributed cash) in eligible investments described in section 
530A(b)(3), and disclose how the proceeds were invested to the account 
beneficiary. An investment under this paragraph (d)(6) will be 
considered prompt if it occurs within 30 calendar days of receiving the 
cash or other property.
    (7) Qualified stock in the master group trust. If, as a result of a 
qualified general contribution, an auto account (through its equitable 
interest in the master group trust) owns an equitable interest in stock 
that meets all the qualified stock requirements in paragraph (b)(8)(ii) 
of this section, the applicable equitable interest is treated as 
qualified stock for purposes of this paragraph (d).
    (e) Tax implications of contributions--(1) To the contributor to an 
eligible donor. Contributions made to an eligible donor that is an 
organization described in section 501(c)(3) and exempt from tax under 
section 501(a) to fund a general funding contribution satisfying the 
requirements of this section are deductible under section 170, subject 
to the other requirements of that section. With regard to individuals 
making a gift to an organization qualifying as an eligible donor for 
purposes of section 530A, whether or not that eligible donor 
subsequently makes a general funding contribution, the gift is to an 
organization described in section 2522.
    (2) To the eligible donor--(i) An eligible donor described in 
section 501(c)(3) and exempt from tax under section 501(a) furthers one 
or more of its purposes described in section 501(c)(3) by providing a 
general funding contribution, including by providing such amount 
through a distribution from a donor advised fund.
    (ii) By making a general funding contribution, the eligible donor 
is making an expenditure for a purpose specified in section 
170(c)(2)(B). In addition, a general funding contribution is neither a 
grant to an individual for purposes of section 4945 nor a distribution 
to a natural person for purposes of section 4966. Additionally, to the 
extent that an obligation to exercise expenditure responsibility arises 
under sections 4945 and 4966, a donor that makes a general funding 
contribution satisfying the requirements of this section is treated as 
exercising expenditure responsibility in accordance with section 
4945(h) with respect to that contribution.
    (f) Applicability and expiration dates. This section applies to 
taxable years beginning on or after January 1, 2026. This section 
expires on September 30, 2029.

    Approved: September 25, 2026.
Frank J. Bisignano,
Chief Executive Officer.
Kevin M. Salinger,
Assistant Secretary of the Treasury (Tax Policy).
[FR Doc. 2026-20026 Filed 9-29-26; 8:45 am]
BILLING CODE 4830-01-P


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