Kit document
HR FAQ (for legal review)
⚠️ Educational only
Have counsel verify against current IRS Notice 2025-68 and any newer guidance.
Is the limit per child or per employee?
Per employee (up to $2,500/year), not per dependent.
Does the employer amount count toward the $5,000 cap?
Yes. Family + employer + other sources share the child’s annual cap.
Can we contribute if the employee has no children?
No — §128 contributions are for employees with eligible children who have Trump Accounts.
Are contributions taxable wages to the employee?
Generally excluded under §128 when requirements are met — confirm with tax counsel / payroll.