If you meet all five conditions in Revenue Procedure 2026-25 — including keeping total gifts to each beneficiary at or below the $19,000 annual exclusion — you won’t need to file Form 709 for those contributions. However, if you make additional gifts that push total giving to any beneficiary above $19,000 or if you’re required to file Form 709 for any other reason, all Trump Account contributions for that year will lose safe harbor protection.
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