Beginning July 4, taxpayers may begin making contributions to Trump accounts, the new child-focused savings vehicle created under Code section 530A as part of the One Big Beautiful Bill Act (OBBBA). Ahead of that start date, the IRS has issued guidance to answer a question for donors: Will those contributions trigger a gift tax return filing requirement?

The guidance, issued as a revenue procedure, makes clear that many individual donors will not have to file gift tax returns merely because they contribute to Trump accounts.

What Are Trump accounts?

Trump accounts are a new kind of retirement savings account created by Congress as part of OBBBA. Under OBBBA, a Trump account can be opened for an eligible individual who has not turned 18 before the close of the calendar year in which the initial account election is made. The eligible individual must have a Social Security number issued before the initial account election.

To open the account, an authorized person (such as a parent or guardian) must make an election. After the election is made, an initial Trump account can be established for the child.

The federal government will also deposit a one-time $1,000 “pilot program” contribution into the Trump account of any eligible child (with an election) who is a U.S. citizen and whose birth falls between January 1, 2025, and December 31, 2028. This $1,000 will not count against any contribution limits.

The funds in Trump accounts are subject to investment restrictions, including that eligible investments be low-cost mutual funds or exchange-traded funds (ETFs) that track U.S. stock indexes, carry no leverage, and have annual fees no greater than 0.1%.

What Does This Have To Do With Gift Tax?

Under current law, a gift tax return is generally required when an individual makes gifts during the year that exceed the annual exclusion amount, or when the gift is not eligible for the annual exclusion, such as a gift of a future interest. That gets reported on Form 709, generally due April 15 of the year after the gift is made.

During the account’s growth period—generally the period before January 1 of the calendar year in which the beneficiary turns 18—Trump accounts are tightly restricted. The exceptions are narrow and include qualified rollover contributions, certain ABLE rollovers during the........

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