The IRS has released Form 4547, allowing parents to register eligible children for Trump Accounts during the 2025 tax filing season. According to the new guidance, taxpayers can now elect to open these long-term savings accounts for minor children, with the option to request a $1,000 federal pilot program contribution for qualifying newborns. While the form is available immediately, actual contributions to Trump Accounts cannot begin until July 4, 2026.
The single-page form serves two distinct functions, the IRS announced. First, it enables authorized individuals to open an initial Trump Account for a qualifying child. Second, it provides a separate election specifically for the $1,000 pilot contribution, which requires parents to affirmatively check a box to receive the seed money.
Understanding Trump Account Registration Requirements
Form 4547 introduces the concept of a “responsible party” who will work with Treasury to establish and administer the account. Taxpayers can register up to two children on a single form, with additional forms required for families with more qualifying children. The form can be filed either on paper or electronically with a 2025 tax return, according to the instructions.
However, the registration process extends beyond simply filing the form. Treasury will send activation instructions to the responsible party beginning in May 2026, which will include identity verification steps before the account becomes fully operational.
Who Qualifies as an Authorized Individual
The eligibility rules differ depending on whether parents are simply opening an account or also requesting the pilot contribution. For opening a basic Trump Account, the IRS establishes a priority order: legal guardians first, then parents, followed by adult siblings, and finally grandparents.
Additionally, stricter requirements apply when requesting the $1,000 pilot contribution. The authorized individual must anticipate that the child will be their qualifying child for the applicable tax year. The instructions emphasize that taxpayers don’t need to have already claimed the child as a dependent on their 2025 return, but checking the pilot contribution box requires confidence in meeting qualifying-child rules for 2026.
Contribution Limits and Tax Treatment
Trump Accounts come with a $5,000 annual contribution limit, which applies to employer contributions and individual contributions from family members. Employer contributions, capped separately at $2,500 annually, are excluded from taxable income but count toward the $5,000 limit. Meanwhile, certain contributions fall outside this cap, including the federal pilot program contribution, qualified general contributions from governments or charities, and specified rollover contributions.
The tax treatment varies significantly by contribution type. Contributions from parents and grandparents made with after-tax dollars create basis in the account, while the federal pilot contribution, employer contributions, and qualified general contributions do not. This distinction becomes critical when the beneficiary reaches age 18 and begins taking distributions.
Withdrawals after age 18 will generally be treated like distributions from a traditional IRA, according to IRS guidance. Part of each distribution may be taxable, while part represents a tax-free return of basis. The agency has emphasized that careful recordkeeping will be essential, particularly for accounts funded by multiple sources over time.
Strict Withdrawal and Investment Rules
Before the beneficiary turns 18, Trump Accounts operate under tight restrictions designed to preserve long-term savings. Distributions are generally prohibited during this period, with limited exceptions for rolling the account into another Trump Account, correcting excess contributions, or distributing upon the beneficiary’s death. Hardship withdrawals are not permitted, and account holders cannot simply close the account due to changed circumstances.
In contrast, investment options face significant limitations throughout the account’s life. Eligible investments must track U.S. stock indexes, carry no leverage, and have annual fees capped at 0.1 percent. Cash and money market funds are generally not permitted except in limited circumstances, and trustees must maintain procedures for monitoring ongoing compliance.
Additional Seed Money from Private Donors
Beyond the federal pilot program, Michael and Susan Dell have pledged $6.25 billion to provide $250 seed contributions for approximately 25 million children under age 10. According to a statement the couple posted online, children must live in ZIP codes with a median household income below $150,000 to qualify. If insufficient families of children under 10 open accounts, remaining funds could be allocated to older children.
However, information about this private seed money does not yet appear in Form 4547, its instructions, or current IRS guidance. The agency has indicated that more details will likely be released separately as the program develops.
Key Considerations Before Filing
The IRS instructions recommend that taxpayers verify several requirements before filing Form 4547. The child must be under age 18 at the end of the election year and possess a valid Social Security number. Filers must qualify as an authorized individual and, if requesting the pilot contribution, expect the child to be their qualifying child for the relevant tax year.
Parents should also understand that no contributions of any kind can be made before July 4, 2026, including the federal pilot contribution. Furthermore, filers must be prepared to complete an account activation process in 2026 that will include identity verification steps before the account becomes operational.
Treasury and the IRS are expected to release additional guidance on Trump Account administration and the activation process before contributions begin in mid-2026. Families considering participation should monitor for updates as the program’s implementation continues to develop throughout the coming year.
