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I have reported several times on the Trump Accounts established under the One Big, Beautiful Bill Act (OBBBA): first in a special October 20th edition introducing the program, again on December 4th with a follow-up covering IRS Notice 2025-68 and the $6.25 billion Dell family contribution pledge, and most recently in my pre-Super Bowl edition on February 7th.
On March 6, 2026, the Department of the Treasury and the Internal Revenue Service issued two proposed regulations that move the program significantly closer to operational reality.
Here is where things stand — presented with concise clarity.
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📋 THE TWO NEW PROPOSED RULES
The IRS released two distinct rulemaking notices last Friday, each addressing a different dimension of the Trump Accounts program:
• REG-117270-25 — Proposed regulations under IRC §530A, covering how to open an initial Trump Account.
• REG-117002-25 — Proposed regulations under IRC §6434, covering the $1,000 Pilot Program contribution.
Both proposed rules were published in the Federal Register1,2 on March 9, 2026. The §530A rulemaking carries a 60-day comment period; the §6434 pilot program rulemaking carries a 30-day comment period. More on how to do that later — if you’re interested in being heard.
📋 REG-117270-25: HOW TO OPEN A TRUMP ACCOUNT
My October reporting introduced the core structure of Trump Accounts as a new type of traditional IRA for eligible children under age 18. These proposed regulations fill in some additional procedural mechanics since earlier guidance.
Key provisions include:
• Election Process: A parent or other authorized individual opens an account using new IRS Form 4547, Trump Account Election(s). The form may be filed with a federal tax return or submitted separately through an IRS online portal. According to more reporting this Monday from Martha Waggoner in the Journal of Accountancy3, Treasury Secretary Scott Bessent stated in February that two million forms for Trump Accounts have been filed.
• Deadline Window: Elections may be made as soon as a child receives a Social Security number, and no later than December 31 of the year the child turns 17 — giving families up to 17 years to open an account.
• Responsible Party: The individual who opens the account generally becomes the responsible party. That person has authority to select eligible investments, request qualified rollover contributions, and designate a successor responsible party, until the account beneficiary attains legal capacity.
• Growth Period: Special contribution, investment, and distribution rules apply from account creation through the end of the year the child turns 17. After that, the account converts to a standard traditional IRA.
This rule directly builds on the §530A framework my earlier newsletters outlined in October and December, including the $5,000 annual contribution limit, the July 4, 2026 start date for contributions, and the prohibition on distributions prior to age 18.
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📋 REG-117002-25: THE $1,000 PILOT PROGRAM
The December follow-up issue covered IRS Notice 2025-68, which provided a general Q&A overview of the pilot program. These proposed regulations go further, establishing the legal framework for how the government actually deposits the $1,000.
Key provisions include:
• Mechanism: The eligible child is deemed to have made a $1,000 overpayment of income tax, which the IRS then refunds directly into the child's Trump Account. This functions as a refundable tax credit deposited to the account — as our October issue anticipated.
• Who Makes the Election: The pilot program election must be filed by an individual who anticipates the child will be their qualifying child for that year — typically a parent or guardian. Crucially, this election and the account-opening election (Form 4547 and instructions) can be made simultaneously.
• Eligibility Confirmed: The child must be born between January 1, 2025 and December 31, 2028; be a U.S. citizen; have a Social Security number; and have no prior pilot election filed on their behalf.
• Timing: Parents may enroll in the pilot program in the same tax year the child is born.
📣 If you want to be heard…SPEAK UP!
There’s plenty of time for interested parties to chime in on this. Commenters are encouraged to use the Federal e-Rulemaking portal to submit comments online. Treasury and IRS invite comments on the earlier Trump Accounts proposed rule until May 8, 2026 at 11:59 PM Eastern Standard Time. Use “IRS. and REG-117270-25” in the search field. For comments on the pilot program, go to the same portal website, enter “IRS and REG-117002-25” by April 8, 2026. Keep in mind that once submitted to the Federal eRulemaking Portal, comments cannot be edited or withdrawn.
📋 WHAT'S STILL AHEAD
These are proposed regulations — final rules will be issued following a public comment period. Families and financial institutions should not expect full operationalization until after final rules are publissed. Given the high profile of this program, I’d expect everything that is absolutely necessary will be live by the one-year anniversary of the OBBBA on July 4, 2026.
Private contributions from donors like Michael and Susan Dell — whose $6.25 billion pledge was covered in the December issue — remain subject to the qualified geographic area and qualified class rules under IRC §530A(f). Those frameworks are not addressed in these two proposed rulemakings and are expected to be covered in subsequent guidance. Another area barely mentioned in the proposed rule is the limited list of trustees eligible to manage the rollover IRA accounts once the growth period for all of the eligible children ends.
There is plenty more to come on this front. The Tax Clarity Newsletter will continue to stay on the case. Stay tuned.
There’s the scoop, everyone! Thanks for taking time to check out this week’s edition of the Tax Clarity Newsletter.
Thank you so much!
References (3):
1 Federal Register, Trump Accounts, 91 FR 11194, last accessed March 11, 2026.
2 Federal Register, Trump Accounts Contribution Pilot Program, 91 FR 11203, last accessed March 11, 2026.
3 IRS proposes regulations for Trump accounts, pilot program, by Martha Waggoner, Journal of Accountancy, March 9, 2026, last accessed March 12, 2026.
DISCLAIMER: The information in this newsletter is derived from public information, provided for education purposes. It is not provided as a financial advisory service and should not be relied upon as such. For advice on a specific tax matter, please consult a tax professional.