Trump Account Contribution Program: Planning Opportunities for Employers

Beginning in July 2026, employers may be able to contribute up to $2,500 annually to eligible Trump Accounts on a tax-advantaged basis through a Trump Account Contribution Program (TACP).

What Is a TACP?

A TACP is a formal employer benefit program that allows an employer to make contributions to Trump Accounts for employees or their dependents. Employers that properly establish and administer a program may be able to provide up to $2,500 per employee per year on a tax-advantaged basis beginning on or after July 4, 2026.

Employers may also offer a Section 125 cafeteria plan that allows employees to make pre-tax salary reductions to fund a child’s Trump Account. Salary reduction contributions generally cannot be made to the employee’s own Trump Account.

Why Should Employers Care?

A TACP is a family-focused benefit with relatively low employer cost that can provide financial support to employees with young families while helping employers differentiate their benefits offerings. As organizations continue to compete for talent, family-focused benefits may enhance recruitment and retention.

Here is a High-Level Employer Setup Checklist

Decide program design

Key decisions typically include:

• Eligibility: Define employee eligibility criteria.
• Benefit level: Establish employer contribution levels.
• Employee funding option for dependents: Determine if pre-tax salary reductions through a Section 125 cafeteria plan will be included.
• Contribution approach: Determine if contributions will be a fixed amount for everyone, a matching formula, or a discretionary contribution (subject to plan rules and administration).

Draft and adopt a separate written plan (required)

A TACP must be implemented under a separate written plan. The plan must be designed to meet requirements that are similar to other tax-favored employee benefit programs.

The plan should address:

• Eligibility Requirements
• Contribution provisions
• Employee Notification
• Nondiscrimination compliance

This is typically where benefits counsel and/or a third-party administrator (TPA) add the most value.

Coordinate administration and payroll

Operationally, a TACP is not “just send money.” Employers should coordinate:

• Routing contributions to the appropriate Trump Account
• Collecting required participant information
• Payroll setup to ensure contributions or cafeteria plan deductions are handled correctly.

Set up internal tracking for contribution limits

A TACP requires processes to prevent excess contributions and support clean reporting. Employers should be prepared to track:

• The $2,500 per-employee annual limit for excludable employer (and permitted dependent salary reduction) contributions, and
• How those contributions interact with the Trump Account’s overall $5,000 annual contribution cap as employer contributions are part of, not in addition to, this limit.

This tracking often requires coordination between HR/benefits, payroll, and the trustee/recordkeeper.

Put required reporting and notices in place

Current guidance indicates employers should be ready for:

• Reporting, notification, and recordkeeping requirements
• As additional guidance becomes available, employers should review procedures with their payroll provider and tax advisors to ensure compliance.

What Employers Should Do Now

Employers considering a TACP should begin evaluating plan design, payroll integration, and compliance requirements now. Kirsch CPA Group can help assess whether this benefit aligns with your workforce and assist with implementation planning.

Because guidance surrounding Trump Accounts and employer contribution programs continues to evolve, employers should consult their tax and benefits advisors before implementing a program.

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