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Can I can gift $4k to my sister(<MAGI requirements)

Sure. For that matter, you can give me $4,000.

for her birthday, then link her bank account to these 2 ESA accounts and withdraw $2k into each of them?

One hates to use blunt words, but in my day that was called theft. Once you give money to anyone it's not yours to control any longer.

It's never a good idea to try to game the system. Take a look at Chapter 8 of Pub 970, which covers 529 plans. There's no income restriction there. A while ago we discussed here how you could move money from an ESA to a 529.

If someone who meets the income limit for ESA contributions wants to make one to one of the accounts in question there's no prohibition on that.

Rule Your Retirement Home Fool
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