Key Takeaways
- Trump Accounts
- AMT Guidance
- ACA Credit Lapse
- Bonus Depreciation Implications
- Tariffs
- Remote Working
- Foreign Passive Income
- In the Courts
- Make a Gift
Trump Accounts
With 'Trump Accounts,' your baby could qualify for $1,000. Here's what to know – Moriah Balingit, Washington Post:
When the children of wealthy households leave the nest, they often benefit from their parents’ largesse in the form of a trust fund. Less affluent peers may receive nothing at all — or even be expected to support their families when they become adults.
But what if all children, regardless of their family’s circumstances, could get a financial boost when they turn 18?
That’s the idea behind “Trump Accounts,” a lesser-known provision of President Donald Trump’s tax legislation. The bill, signed into law earlier this year, gives $1,000 to every newborn, so long as their parents open an account. That money is invested in the stock market by private firms, and the child can access the funds when they turn 18. The parents of older children can also open accounts, but they won’t get the $1,000 bonus.
But what if all children, regardless of their family’s circumstances, could get a financial boost when they turn 18?
That’s the idea behind “Trump Accounts,” a lesser-known provision of President Donald Trump’s tax legislation. The bill, signed into law earlier this year, gives $1,000 to every newborn, so long as their parents open an account. That money is invested in the stock market by private firms, and the child can access the funds when they turn 18. The parents of older children can also open accounts, but they won’t get the $1,000 bonus.
Trump Accounts Get Guidance Following $6.25 Billion Donation – Trevor Sikes, Tax Notes ($):
New IRS guidance provides clarity on the eligibility, investing, and distribution requirements for the Trump administration’s tax-deferred investment program for children, which also received a $6.25 billion corporate contribution pledge.
Notice 2025-68, 2025-51 IRB 1, issued December 2, announces Treasury’s intent to issue proposed regulations under section 530A. In the meantime, it addresses a wide range of questions while defining eligible child and eligible investment. It also explains how a taxpayer can elect to open a Trump account and what happens if a child were to die before turning 18.
Notice 2025-68, 2025-51 IRB 1, issued December 2, announces Treasury’s intent to issue proposed regulations under section 530A. In the meantime, it addresses a wide range of questions while defining eligible child and eligible investment. It also explains how a taxpayer can elect to open a Trump account and what happens if a child were to die before turning 18.
Treasury Clarifies Tax-Advantaged 'Trump Accounts' – Anna Scott Farrell, Law 360 ($):
The federal government issued guidance Tuesday on the new type of tax-advantaged brokerage account for children, known as Trump accounts, that specifies how to create the savings plans and who can make contributions and receive government seed money for them.
The account, established by Congress in this summer's budget law and expected to start next year, is a type of traditional individual retirement account with special rules that last until the child turns 18, according to Notice 2025-68.
The account, established by Congress in this summer's budget law and expected to start next year, is a type of traditional individual retirement account with special rules that last until the child turns 18, according to Notice 2025-68.
IRS Issues Guidance on ‘Trump Accounts’ from GOP Tax Law – Erin Slowey & Naomi Jagoda, Bloomberg ($):
The Treasury Department and IRS Tuesday released guidance on the tax-advantaged “Trump accounts” for children created by Republicans’ 2025 tax law.
The new retirement account for kids is meant to build savings and encourage more families to invest. It’s expected to launch in 2026, following new IRS guidance detailing how the account will work.
Under the GOP tax law, the federal government will provide children born from 2025 through 2028 with $1,000. Parents, employers, and states can also make contributions to the accounts, which will be limited to $5,000 annually. Funds in the accounts must be invested in index funds, and can’t be accessed until the beneficiary turns 18.
The new retirement account for kids is meant to build savings and encourage more families to invest. It’s expected to launch in 2026, following new IRS guidance detailing how the account will work.
Under the GOP tax law, the federal government will provide children born from 2025 through 2028 with $1,000. Parents, employers, and states can also make contributions to the accounts, which will be limited to $5,000 annually. Funds in the accounts must be invested in index funds, and can’t be accessed until the beneficiary turns 18.
Dell CEO pledges $6.25 billion to ‘Trump accounts’ for American children – Maegan Vazquez & Aaron Gregg, Washington Post:
Dell Technologies founder and CEO Michael Dell and his wife, Susan, said Tuesday that they plan to donate $6.25 billion to seed investment accounts for 25 million American children, building on a program launched in President Donald Trump’s massive tax and immigration legislation signed into law this year.
The savings accounts, also known as “Trump accounts,” are tax-advantaged investment accounts for children intended to help them save for their futures. The U.S. Treasury will contribute $1,000 to the accounts for children born from 2025 through 2028 as outlined in the legislation signed into law by Trump. The Dells’ announcement will seed 25 million additional accounts with $250 each, dedicated to the accounts of children 10 and under who don’t qualify for the federal government’s $1,000 contribution.
The savings accounts, also known as “Trump accounts,” are tax-advantaged investment accounts for children intended to help them save for their futures. The U.S. Treasury will contribute $1,000 to the accounts for children born from 2025 through 2028 as outlined in the legislation signed into law by Trump. The Dells’ announcement will seed 25 million additional accounts with $250 each, dedicated to the accounts of children 10 and under who don’t qualify for the federal government’s $1,000 contribution.
Trump Hails $6 Billion Dell Gift to Boost Accounts for Children – Josh Wingrove, Bloomberg ($). “Donald Trump hailed a gift from Michael and Susan Dell to jumpstart investment accounts for American children, expanding a signature initiative from the president’s tax law that has drawn support from corporate and financial leaders.”
AMT Guidance
Mega-Taxpayers Angle for More Friendly Corporate AMT Guidance – Chandra Wallace, Tax Notes ($):
Dozens of America’s largest companies are looking to shape forthcoming proposed rules implementing the corporate alternative minimum tax that was enacted during the Biden administration.
The Alliance for Competitive Taxation (ACT) represents multibillion-dollar companies in tech, finance, pharmaceuticals, retail, and more, including the Walt Disney Co., Google Inc., and Exxon Mobil Corp.
The corporate AMT was expected to apply to about 150 of the largest corporations and corporate groups, according to Joint Committee on Taxation estimates around the time it was enacted as part of the Inflation Reduction Act in August 2022.
The Alliance for Competitive Taxation (ACT) represents multibillion-dollar companies in tech, finance, pharmaceuticals, retail, and more, including the Walt Disney Co., Google Inc., and Exxon Mobil Corp.
The corporate AMT was expected to apply to about 150 of the largest corporations and corporate groups, according to Joint Committee on Taxation estimates around the time it was enacted as part of the Inflation Reduction Act in August 2022.
Imminent ACA Credit Lapse?
Health insurance costs could spike, as bipartisan ACA deal looks less likely – Riley Beggin, Theodoric Meyer, and Kadia Goba, Washington Post:
Affordable Care Act subsidies that help millions of Americans pay for health insurance will expire in less than a month. But razor-thin margins in Congress, partisan division and competing plans are making it less and less likely that lawmakers will find a bipartisan deal to keep the assistance going — which means some households will probably face spiking insurance costs next year.
Senate Republicans promised Democrats a mid-December vote on a plan of their choice to extend the subsidies — which were implemented in 2021 to lower health care costs during the covid-19 pandemic — in exchange for support from a group of Democrats to end the government shutdown.
…
With time dwindling, Senate Democrats still haven’t released their plan, which would extend the subsidies for an unknown duration, and House Democrats are pushing for a three-year extension. But it’s clear there are not enough Senate Republicans willing to support any extension, especially without significant changes to address GOP concerns about fraud and whether subsidized plans will cover abortion.
Senate Republicans promised Democrats a mid-December vote on a plan of their choice to extend the subsidies — which were implemented in 2021 to lower health care costs during the covid-19 pandemic — in exchange for support from a group of Democrats to end the government shutdown.
…
With time dwindling, Senate Democrats still haven’t released their plan, which would extend the subsidies for an unknown duration, and House Democrats are pushing for a three-year extension. But it’s clear there are not enough Senate Republicans willing to support any extension, especially without significant changes to address GOP concerns about fraud and whether subsidized plans will cover abortion.
Congress Speeds Toward Health Care Cliff Without GOP Consensus – Maeve Sheehey, Bloomberg ($):
Republicans emerged from House and Senate conference meetings Tuesday united on a need for the party to chart a path forward on health care — but worlds apart on what it should be.
While leaders of both chambers said they’re actively working on a Republican response to Democrats’ call for a clean extension of enhanced Obamacare tax credits, their GOP members telegraphed a swath of contradictory plans to deal with the health care cliff. And with little time left before the end of the year, the expiration of those expanded Covid-era Affordable Care Act credits looks more likely by the day.
While leaders of both chambers said they’re actively working on a Republican response to Democrats’ call for a clean extension of enhanced Obamacare tax credits, their GOP members telegraphed a swath of contradictory plans to deal with the health care cliff. And with little time left before the end of the year, the expiration of those expanded Covid-era Affordable Care Act credits looks more likely by the day.
Lawmakers Bearish on ACA Credit Fix by Year-End Deadline – Cady Stanton, Tax Notes ($):
Rank-and-file senators returned from the Thanksgiving recess voicing pessimism on the prospects for a bipartisan solution to address an expiring healthcare tax credit, while Republican leadership said work on an agreement continues.
Congress has less than three legislative weeks to address the enhanced premium Affordable Care Act tax credit that is scheduled to sunset at the end of the year, but senators seem no closer to a deal based on press conferences and hallway interviews.
Congress has less than three legislative weeks to address the enhanced premium Affordable Care Act tax credit that is scheduled to sunset at the end of the year, but senators seem no closer to a deal based on press conferences and hallway interviews.
ACA Expansion Lapse May Impede Organ Access, Panel Told – Asha Glover, Law 360 ($):
Allowing the Affordable Care Act's premium tax credit expansion to lapse would make it harder for Americans to be listed for organ transplants, potentially dampening an upward trend in transplants in the years since the expansion was enacted, a panelist told House lawmakers Tuesday.
The expanded credits have led to an uptick in organ transplants, and the increase in organ donor listings suggests that more wide-ranging health coverage is giving patients options they may not have had otherwise, Emily Gee, senior vice president for economic policy at the Center for American Progress, told the House Ways and Means Oversight subcommittee.
The expanded credits have led to an uptick in organ transplants, and the increase in organ donor listings suggests that more wide-ranging health coverage is giving patients options they may not have had otherwise, Emily Gee, senior vice president for economic policy at the Center for American Progress, told the House Ways and Means Oversight subcommittee.
Bonus Depreciation Implications
JCT: Retroactive Bonus Depreciation to Cost $16 Billion in 2025 – Katie Lobosco, Tax Notes ($):
Businesses are expected to claim $16 billion in new tax deductions this year for investments made before the Republican tax bill was enacted in July.
The One Big Beautiful Bill Act (P.L. 119-21) made full bonus depreciation permanent for property acquired and placed in service after January 19, 2025. The provision allows companies to fully deduct the cost of new business investments in the tax year in which they were incurred.
The tax deduction will cost the federal government $16 billion more in fiscal 2025 than it would have if it didn’t take effect retroactively for the six months before the law was enacted, according to Joint Committee on Taxation data released December 2.
The One Big Beautiful Bill Act (P.L. 119-21) made full bonus depreciation permanent for property acquired and placed in service after January 19, 2025. The provision allows companies to fully deduct the cost of new business investments in the tax year in which they were incurred.
The tax deduction will cost the federal government $16 billion more in fiscal 2025 than it would have if it didn’t take effect retroactively for the six months before the law was enacted, according to Joint Committee on Taxation data released December 2.
Corporations to claim $16B from retroactive GOP tax break, federal report says – Riley Beggin, Washington Post:
Corporations are expected to claim $16 billion in new tax breaks this year for purchases they had already made and put into use before the July passage of the Republican tax law, according to an analysis from the Joint Committee on Taxation.
The GOP tax law, the One Big Beautiful Bill Act, restored a provision that allows companies to write off the full expense of some new investments — including technology, equipment and facilities — in the first year of use. That had been allowed under President Donald Trump’s 2017 tax law, but the provision was phasing out over the last few years and was scheduled to end in 2026.
The change allows companies to get the full benefit of business deductions right away, rather than over the years in which it’s used. The idea is to encourage companies to invest in equipment that will grow their business, contributing to the economy.
The GOP tax law, the One Big Beautiful Bill Act, restored a provision that allows companies to write off the full expense of some new investments — including technology, equipment and facilities — in the first year of use. That had been allowed under President Donald Trump’s 2017 tax law, but the provision was phasing out over the last few years and was scheduled to end in 2026.
The change allows companies to get the full benefit of business deductions right away, rather than over the years in which it’s used. The idea is to encourage companies to invest in equipment that will grow their business, contributing to the economy.
Tariffs
Dozens of U.S. and Foreign Companies Sue for IEEPA Tariff Refunds – Amanda Athanasiou, Tax Notes ($):
Over 100 companies — including Costco, Oakley, and Revlon — have joined in federal lawsuits to obtain refunds of International Emergency Economic Powers Act (IEEPA) tariffs, claiming that their refund options could be in jeopardy.
In addition to refunds, plaintiffs have asked the U.S. Court of International Trade to follow its own precedent and declare that the IEEPA tariffs are unlawful. Even if the Supreme Court decides that the tariffs and associated executive orders are illegal, importers “are not guaranteed a refund for those unlawfully collected tariffs in the absence of their own judgment and judicial relief,” according to a November 28 complaint filed by Costco Wholesale Corp. in Costco Wholesale Corp. v. U.S. Customs and Border Protection.
In addition to refunds, plaintiffs have asked the U.S. Court of International Trade to follow its own precedent and declare that the IEEPA tariffs are unlawful. Even if the Supreme Court decides that the tariffs and associated executive orders are illegal, importers “are not guaranteed a refund for those unlawfully collected tariffs in the absence of their own judgment and judicial relief,” according to a November 28 complaint filed by Costco Wholesale Corp. in Costco Wholesale Corp. v. U.S. Customs and Border Protection.
Costco becomes biggest company yet to demand refund of Trump tariffs – Paul Wiseman, Washington Post:
Costco is joining other companies that aren’t waiting to see whether the Supreme Court strikes down President Donald Trump’s most sweeping import taxes. They’re going to court to demand refunds on the tariffs they’ve paid.
The specialized U.S. Court of International Trade in New York and the U.S. Court of Appeals for the Federal Circuit in Washington ruled earlier this year that Trump’s biggest and boldest import taxes are illegal. The case is now before the Supreme Court. In a Nov. 5 hearing, several of the high court’s justices expressed doubts that the president had sweeping power to declare national emergencies to slap tariffs on goods from almost every country on earth.
The specialized U.S. Court of International Trade in New York and the U.S. Court of Appeals for the Federal Circuit in Washington ruled earlier this year that Trump’s biggest and boldest import taxes are illegal. The case is now before the Supreme Court. In a Nov. 5 hearing, several of the high court’s justices expressed doubts that the president had sweeping power to declare national emergencies to slap tariffs on goods from almost every country on earth.
Remote Working
Tax News & Views International Weekly: Telecommuting and Taxes – Alex M. Parker, Eide Bailly:
Remote work has been with us since the days of Marco Polo, but since the pandemic it’s become an entirely new dynamic. Today, the ease and availability of working from anywhere for many professions has changed the concept of work itself.
That this would lead to tax issues may seem obvious. The range of issues it raises may be less obvious, though. Cross-border disputes about the personal income tax are the first that come to mind. But it’s also an issue for corporate taxation, when the location of employees–and whether they’re key decision-makers, value-creators, or among the rank-and-file–can be a factor in determining if a company has a taxable presence in a jurisdiction.
That this would lead to tax issues may seem obvious. The range of issues it raises may be less obvious, though. Cross-border disputes about the personal income tax are the first that come to mind. But it’s also an issue for corporate taxation, when the location of employees–and whether they’re key decision-makers, value-creators, or among the rank-and-file–can be a factor in determining if a company has a taxable presence in a jurisdiction.
Foreign Passive Income
Bar Group Wants Flexibility On New Foreign Passive Income Rules – Michael Rapoport, Bloomberg ($):
The Treasury Department should give taxpayers choices on implementing new requirements governing how they include their share of their subsidiaries’ foreign passive income in their own income, a bar group said Tuesday.
In a report, the New York State Bar Association recommended “significant taxpayer flexibility” over changes in this year’s giant tax-and-spending law to the treatment of taxpayers’ pro rata shares of a controlled foreign corporation’s Subpart F income.
In a report, the New York State Bar Association recommended “significant taxpayer flexibility” over changes in this year’s giant tax-and-spending law to the treatment of taxpayers’ pro rata shares of a controlled foreign corporation’s Subpart F income.
In the Courts
Sixth Circuit Rejects Rehearing in Deficiency Deadline Case – Mary Katherine Browne, Tax Notes ($). “A circuit court rejected the federal government’s attempt to reverse the court’s determination that the deadline for filing deficiency petitions with the Tax Court is a claims processing rule subject to equitable tolling.”
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