The U.S. Department of Labor (the “DOL”) recently issued Technical Release 2026-02, providing guidance on whether certain Trump accounts established under Section 530A of the Internal Revenue Code and the One, Big, Beautiful Bill Act (“Trump Accounts”) and employer contribution programs to such accounts constitute employee pension benefit plans subject to Title I of ERISA. In general, the DOL concluded that Trump Accounts and related employer contribution programs are not subject to Title I of ERISA.
Background
Trump Accounts are a new type of individual retirement account (“IRA”) for eligible individuals under age 18. Unlike traditional IRAs, which generally require compensation income for contributions, Trump Accounts may receive contributions from several sources, including employers, employees as account beneficiaries, and employees contributing as family members. Notably, beginning January 1 of the calendar year in which the account beneficiary attains age 18, the Trump… Read the complete article here...
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