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With careful planning, a QCD can be a smart tax-planning strategy for an IRA holder taking distributions.
by Brian Dobbis | May 2024
Qualified charitable distributions (QCDs) first became available in 2006 as part of the Pension Protection Act, with an expiration date of December 31, 2007. This deadline was extended several times and finally became permanent as Congress included it in the Consolidated Appropriations Act of 2016. The SECURE 2.0 Act passed in 2022 made two significant changes to the QCD rules.
A qualified charitable distribution is a tax-free withdrawal from an individual retirement account (IRA) made directly to a qualifying charity. It serves as a popular way to do good while also satisfying the IRA holder’s required minimum distribution (RMD). Although not eligible for a charitable deduction, a QCD is excluded from the IRA owner’s adjusted gross income (AGI) under Internal Revenue Service (IRS) rules. Leveraging a QCD to lower one’s AGI could potentially reduce those taxes based on income, such as Social Security benefits or Medicare Parts B and D premium surcharges. Available to owners and beneficiaries age 70½ or older, a QCD offers tax-free IRA distributions of up to $105,000 in 2024. Here, we discuss the importance of coordinating an RMD with a QCD to maximize tax benefits, SECURE 2.0 Act rule changes and other rules you must be familiar with to ensure tax-free QCD treatment.
RMDs start for IRA owners (excluding Roth IRAs) in the year they reach age 73. For IRA owners with charitable intentions, a potentially substantial tax benefit becomes available when a QCD is used. A QCD can reduce or even eliminate the income tax ordinarily due on RMD income. Notably, QCDs can start as early as 70½ (the account owner’s 70½ birthday), even though RMDs aren’t required until age 73.
But, timing is everything. To help ensure you receive a QCD tax benefit, you must coordinate your QCD with your RMD, or the QCD may be treated as taxable income. Why? The first dollars withdrawn from an IRA in any year (when an owner is subject to an RMD) are deemed to satisfy the RMD. This rule is referred to as the “first-dollars-out” rule, and that, in turn, creates a timing oddity for QCDs.
Many IRA owners like to get their RMD out of the way by withdrawing from their IRA early in the year or taking systematic (i.e., monthly, quarterly, etc.) distributions. However, those individuals who want to reduce their RMD income should first make a QCD directly from their IRA to a qualifying charity, then take their annual RMD. We suggest doing QCDs early in the year to avoid any conflict with the first-dollars-out rule.
If an IRA owner is looking to offset the income from an RMD with a QCD, those transactions must be done in conjunction with each other. In other words, an IRA owner cannot take their RMD and then decide to retroactively do a QCD with those same dollars. Notably, a QCD can be done after an RMD is taken, but the QCD will be an additional distribution on top of the RMD.
To illustrate this point using a hypothetical example, here is an all-too-common scenario where a QCD can become a taxable distribution:
Tanya withdrew a total of $10,000 from her traditional IRA, $5,000 of which is current taxable income because the RMD was taken before the QCD. However, since the $5,000 distribution taken in December was transferred directly to a qualifying charity, it qualifies as a QCD and is thus excluded from taxable income.
To avoid this outcome, Tanya’s $5,000 distribution in February should have been transferred directly to a qualifying charity prior to taking her 2023 RMD. By doing it this way, the $5,000 QCD would have satisfied her 2023 RMD, so no additional funds would need to be distributed from her IRA. Furthermore, Tanya would have withdrawn only $5,000 (as opposed to $10,000), and the distribution would have been completely tax-free because it’s eligible for QCD treatment.
QCDs for individuals age 70½ or older are permitted from IRAs only (including an inherited IRA). QCDs cannot be done from an employer-sponsored retirement plan—i.e., 401(k), 403(b), 457(b), etc.
SECURE 2.0 Act enacted two new rules in 2022 affecting qualified charitable distributions.
The QCD limit had remained at $100,000 (annually) since its inception in 2006. Beginning in 2024, the limit is now linked to the rate of inflation. The 2024 QCD limit is $105,000.
Beginning in 2023, account holders were offered a once-in-a-lifetime opportunity to use a QCD to fund a charitable remainder unitrust (CRUT), charitable remainder annuity trust (CRAT) or charitable gift annuity (CGA). The maximum (lifetime) distribution amount is $53,000 in 2024.
This rule essentially allows a traditional IRA owner to move funds (to a split-interest entity) free of income or estate tax to future generations. However, it’s not that simple. There are several hurdles that must be satisfied before the individual can reap the tax benefits of such a transaction. We urge you to discuss this new opportunity with your financial adviser and/or tax professional.

Roth IRAs are generally not QCD-eligible because qualified Roth IRA distributions are tax-free. Thus, QCDs can be made from a Roth IRA only if the account owner had not satisfied the requirements for a qualified distribution.
Per the IRS, a qualified distribution is any payment or distribution from your Roth IRA that meets the following requirements:
A qualified charitable distribution provides an excellent opportunity for retirement account owners to “give something back” from a lifetime of savings. With proper foresight, and a careful eye on distribution planning, the QCD can be a “win-win,” for the account holder looking for a smart tax-planning strategy and the qualifying charity that stands to benefit.
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