Treasury and IRS Notice 2025-68 on Section 530A Trump Accounts

Summary

SIFMA provided comments to the Office of Associate Chief Counsel on Notice 2025-68 regarding section 530A Trump accounts on certain rules that Treasury and the IRS are considering proposing as part of this framework.

Excerpt

The Securities Industry Financial Markets Association (“SIFMA”) ¹ supports the goal of facilitating long-term investment savings and believes that tax-advantaged savings programs, such as Trump accounts, are vital tools that help savers build wealth. Helping Americans build long-term savings, including for retirement, is among the most important roles of the U.S. capital markets. Especially through the power of compound interest, Trump accounts can jumpstart the financial future for American children and provide opportunities for important financial education. Trump accounts will provide important opportunities to foster saving and investment in capital markets starting in childhood to build financial foundations for a lifetime.

We appreciate the guidance provided in Notice 2025-68 regarding section 530A Trump accounts and the opportunity to submit comments on certain rules that Treasury and the IRS ar considering proposing as part of this framework. As Treasury works to provide guidance on Trump accounts, we support practical, workable solutions for operationalizing these accounts and look forward to working with Treasury and other agencies and stakeholders toward achieving this goal.

I. Executive Summary

Our suggestions aim to simplify the establishment of Trump accounts, clarify questions
regarding contributions and eligible investments, and make Trump accounts consistent with
similar existing tax-advantaged savings vehicles where appropriate.

We make multiple recommendations to Treasury as our members work towards implementing these accounts:

• Add a note to trumpaccounts.gov indicating when the page was last updated so that we can be sure not to miss any changes or new information;
• Edit the penalty of perjury section of Form 4547 to cover all eligibility criteria, including legal status;
• Clarify that rollover trustees are able to rely on information from the financial agent with regard to eligibility status of the beneficiary and the designation of the Authorized
  Individual;
• Provide flexibility with regard to Rollover Trustees setting up policies and procedures to address changes in the Authorized Individual;
• Issue sample governing instrument language for these accounts, whether set up as trust or custody accounts;
• Confirm that these accounts are not considered “plans” under IRC 4975 or ERISA;
• Allow trustees to adopt reasonable policies and procedures for determining how to
  address excess contributions;
• Allow an account to be rolled over from the Financial Agent even if the account is unfunded;
• Clarify certain general funding contribution aspects;
• Establish a safe harbor that carves out employer contributions to Trump accounts;
• Create a safe harbor and grace period for addressing investments options that become
  ineligible;
• Clarify the taxation of distributions;
• Ensure that reporting and disclosure are as similar as possible to current requirements for similar accounts; and
• Create a self-correction program.