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530A Philanthropy Donor-Advised Funds Regulations

Can a donor-advised fund give money to Trump Accounts?

National Philanthropic Trust has opened a way for donor-advised funds to fund Trump Accounts – for a whole class of children, not one named child.

· · Updated
An older couple laughs with their adviser at a sunlit dining table by a tall window, coffee cups and a laptop between them.

Money held in a donor-advised fund can now reach Trump Accounts (530A). National Philanthropic Trust, a leading independent sponsor of donor-advised funds, said on October 12 that it worked with the Treasury Department to offer a "new pathway enabling DAF donors to support qualified contributions to Trump Accounts," per its announcement with the J.P. Morgan Charitable Giving Fund program. The route funds a whole class of children – every eligible child in a state or birth year, for example – and not one named child.

The first gift through it

The first donor to use the route is Brad Gerstner. Per the announcement, the Brad Gerstner Family Foundation – a donor-advised fund in the J.P. Morgan Charitable Giving Fund program at National Philanthropic Trust – will contribute $250 to the Trump Accounts of Indiana children born in 2023 and 2024 who live in ZIP codes with a median family income of $150,000 or less, which the trust puts at more than 140,000 children. We covered the terms of that gift in our reporting on the Gerstner gift for Indiana children.

The trust described the work as building something that did not exist before. "We hope that Mr. Gerstner's vision and our blueprint can serve as a model for donors in every state," CEO Holly Welch Stubbing said in the announcement.

What the federal rules say about donor-advised funds

The tax questions were settled in Treasury's temporary regulations published September 30. Federal tax law restricts what a donor-advised fund can pay to individuals, so the rules address the point directly. Per the regulations, a 501(c)(3) organization furthers its charitable purposes by making a general funding contribution, "including by providing such amount through a distribution from a donor advised fund," and that contribution "is neither a grant to an individual for purposes of section 4945 nor a distribution to a natural person for purposes of section 4966."

The regulations also address the donor's side. Contributions to a 501(c)(3) eligible donor to fund a general funding contribution "are deductible under section 170, subject to the other requirements of that section." Whether a particular donor can deduct a particular gift still depends on those other requirements – a question for the donor's tax adviser.

How the money reaches a child's account

A donor-advised fund does not deposit money into accounts itself. Under section 530A and IRS Notice 2025-68, an eligible donor – a government entity, an Indian Tribal government or a 501(c)(3) organization – applies to Treasury with the total amount and the class of children it wants to reach. Treasury then identifies every child in that class and distributes equal amounts to each child's account.

The class has to be broad. Per the regulations, it can be every child still in the growth period, children in a state or a Treasury-designated area where at least 5,000 eligible children live, or children born in named years. A donor can also use an approved class of at least 5,000 children that combines location and birth years, set in an agreement with Treasury – the Indiana gift's terms combine both. For 2026 and 2027, per Notice 2025-68, the application requires at least $25 per child in the class.

That structure is why the route cannot fund one particular child. Nothing in the regulations or the trust's announcement describes a way for a donor-advised fund to pay into a single named child's account. A grandparent who wants to give to one grandchild still can – but that is an ordinary contribution from the grandparent's own money, and it counts toward the child's $5,000/yr limit.

What it means for families

Money that arrives this way is a qualified general contribution, and it is treated differently from a family's own deposits:

  • It does not count toward the $5,000/yr limit. Per the regulations, contributions to a qualified class "facilitated by the Treasury Department and funded by a government or nonprofit" are outside it, as we explained in our reporting on what counts toward the $5,000 limit.

  • It can reach an account nobody has claimed yet. Per the regulations, an account Treasury opened automatically may accept qualified general contributions during the growth period, which we covered in our reporting on the automatic accounts.

  • It creates no basis. Under section 530A, qualified general contributions are left out of the account's after-tax basis, so the share of a later withdrawal that comes from them is generally taxed as ordinary income.

  • The donor may be named. Per Notice 2025-68, Treasury tells the account's trustee who made the gift only if the donor consents.

What to watch

The trust's announcement describes a blueprint and names no other gift made through it. Gifts announced by other donors and foundations, and the terms each one sets, are collected in our reporting on who has pledged money to Trump Accounts.

For families, the practical question is which of these gifts may apply to their own child. Our Match and Bonus Finder at https://trumpaccounts.com/finder takes a child's age, state and ZIP code and shows which programs may apply.

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