The Internal Revenue Service (IRS) and Treasury Department have issued proposed regulations (REG-101355-26) outlining the requirements for making employer contributions to Trump Accounts under Code section 128. The guidance provides the first comprehensive framework for employers interested in offering Trump Account contributions to benefit employees and clarifies several issues that practitioners have been debating since enactment of the One Big Beautiful Bill Act (OBBBA). The proposed regulations also modernize and clarify the nondiscrimination rules applicable…