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QCDs and Required Minimum Distributions: How a QCD Satisfies Your RMD

Josh Rendler, CFP®

Creator of Motion Retirement

Updated 2026-10-12 · Tax year 2026 · Figures checked October 10, 2026 · How this is checked

Can a QCD fulfill the RMD requirement?

Yes. Once you reach a set age, you must take some money out of your traditional IRA each year. This is the RMD (the least you must take out of a regular IRA each year once you reach a set age). A gift sent straight from your IRA to a charity counts toward it. That gift is a QCD (money sent straight from your IRA to a charity at 70½ or older, not taxed as income, up to a yearly limit). The part of your RMD you give this way stays out of your taxable income (the part of your income that tax rates are actually charged on). But order matters. The first money out each year counts toward the RMD first.

  • A QCD counts toward your RMD and isn't taxed. The limit is $111,000 per IRA owner in 2026, up from $108,000 in 2025.
  • The first money out each year counts toward the RMD. A QCD made after taxed withdrawals already met the RMD doesn't replace them.
  • A QCD bigger than your RMD is allowed. It doesn't count toward next year's RMD.
  • You can add up the RMDs on your own IRAs and take the total from any of them, including by QCD. An inherited IRA (an IRA you get from someone who died) is a separate group.
  • If you were born in 1951 or later, RMDs start at 73, or 75 if you were born in 1960 or later. You can start QCDs at 70½. For people born in 1959, the rule isn't final.
Jump to a question

This page is for IRA owners who take RMDs and also give to charity.

For people in that spot, a QCD is usually the first thing I look at. Whether it fits depends on the details below.

New to QCDs? Start with the QCD overview and who can make one.

Can a QCD fulfill the RMD requirement?

Yes.

A QCD counts toward your required minimum distribution (RMD) for the year.1 Taking out more than your RMD doesn’t earn credit toward a later year’s RMD.2

Say your RMD is $20,000 and you give $20,000 by QCD. Your RMD is met. None of that $20,000 is taxed.

A QCD is left out of your income, so it never reaches your AGI.34 Because of that, you can’t also deduct it as a charitable gift.3 If your IRA holds after-tax money, the QCD comes first from the money that would be taxed.3

That is why it can help even if you take the standard deduction (the flat amount most people can subtract from income without listing costs).

Most people’s RMD is well under the yearly cap of $111,000 per IRA owner in 2026 ($108,000 in 2025).567. See the QCD limit for more, including the rule for spouses.

How do a QCD and an RMD compare?

A QCD is a choice. An RMD is required. This table puts them side by side.

QCD RMD
Starting age 70½ or older on the day the money leaves the IRA.8 73 or 75, by birth year (see below)
Required? No Yes, every year once it starts 9 10
Taxed? Left out of income before AGI (your total income minus a few set subtractions, the number many tax rules start from), so it can't also be deducted.34 Yes, unless sent to charity by QCD Counts toward your RMD for the year.12
Yearly cap or minimum Cap of $111,000 per IRA owner in 2026 ($108,000 in 2025).567 A minimum, figured each year 9
Deadline Counts in the year the IRA firm pays it.11, so by December 31 December 31 (first one can wait until April 1 of the next year) 9
If you miss it No penalty You may owe an extra tax on the amount you missed 12

At what age do RMDs start?

Required minimum distributions start at 73 if you were born from 1951 through 1958.1314 They start at 75 if you were born in 1960 or later.14 For people born in 1959, the law’s wording fits both ages, so the answer is unsettled.14

Those ages are for people born in 1951 or later. 15 The older rules set the start age for anyone born earlier.

You can start QCDs earlier.

You must be at least 70½ on the day the money leaves your IRA.8

So there are a few years when you can make QCDs but have no RMD yet. Those gifts are still left out of income. They just aren’t meeting a required withdrawal.

This table is for IRAs you own. An inherited IRA follows its own rules and can require withdrawals at any age. See QCDs from an inherited IRA.

Your situation (your own IRAs) RMD required? QCD allowed?
Under 70½ No No
70½ through the year before your RMD age No Yes
RMD age and older Yes Yes, and it counts toward the RMD

You can put off your first RMD until April 1 of the next year. 9 If you wait, that next year has two RMDs. One is due by April 1, and that year’s own is due by December 31. The first money out goes toward the older RMD first. So a giving plan for that year has to cover both.

How is my RMD figured?

Your RMD is usually your IRA’s balance on the prior December 31, divided by a factor. 9 The factor comes from IRS tables based on your age. Your IRA firm usually works out the number and tells you.

Does a QCD lower future RMDs?

It can, a little. Each RMD is based on last year’s ending balance. 9 A QCD takes money out of the IRA, so the balance is lower than it would be. If nothing else changes, later RMDs are a bit smaller. Market gains and losses move the balance too, so this is not a sure thing.

Does the order of withdrawals matter?

Yes.

A QCD counts in the year the IRA firm pays it.11 The first dollars out of your IRA each year count toward your RMD.11 By my reading, a taxable withdrawal taken earlier in the year can’t be turned into a QCD later.11

So a taxed withdrawal early in the year counts toward the RMD first, up to the amount you took out. The later QCD is still valid, and still left out of income. But it is extra money out of the IRA.

This matters most if you get automatic monthly or quarterly RMD payments. Every payment you get before the QCD shrinks the part of the RMD the QCD can cover.

For CPAs and attorneysWhy first-dollars-out is labeled an inference

The regulation stating that the first amounts distributed in a year are the RMD is written for rollovers from employer plans. It reaches IRAs through a separate regulation. No IRS sentence reviewed for this page says “a later QCD cannot offset an earlier withdrawal” in those words. It is the mechanical result of the rule. 11

How should I order QCDs and withdrawals during the year?

A common order is QCD first, then the rest of the RMD as a normal withdrawal. That way every QCD dollar counts toward the RMD.

Related video The PERFECT $2M Retirement Spending Plan To Pay Less Taxes

Already took some taxed money out this year? A QCD can still cover the part of the RMD that’s left. Say your RMD is $24,000 and you got $8,000 in monthly payments. A QCD of up to $16,000 still counts toward the rest. A bigger QCD is still a QCD. The extra just isn’t covering the RMD.

I need cash for a tax bill. Should it come from my RMD or from selling investments?

It depends on your situation. One order many retirees consider is to give first from the RMD, then take the rest as cash. The rest of the RMD has to come out by the deadline and be taxed anyway.

A QCD is left out of your income, so it never reaches your AGI.34 Because of that, you can’t also deduct it as a charitable gift.3 If your IRA holds after-tax money, the QCD comes first from the money that would be taxed.3

So giving first uses up the part of the RMD that would have been taxed. That is by my reading of the order above.

Here is how I think about a cash need in an RMD year:

  1. Decide how much you’d like to give to charity this year.
  2. Take that amount off your total RMD. That part can go out as QCDs.
  3. Take the rest of the RMD now to cover the tax bill or other cash need.
  4. Only if you need more cash, look at other accounts. Selling an investment there can create its own taxed gain.

Whether this fits depends on a few things. The size of the need matters, and so does your tax bracket this year. So do what your other accounts hold and how your income lines up with Medicare’s income lines. It’s worth running the numbers with your tax preparer.

Can my RMD go straight into my Roth IRA?

No.

A conversion from a traditional IRA to a Roth IRA is taxed as income.16 There is no 10% early-withdrawal penalty on the conversion itself.16 Taking the converted money out of the Roth within five years can bring that penalty back.17 An exception may still apply.17 An RMD can’t be converted.18 So in a year you owe an RMD, it has to come out before you convert.18

A QCD is one way the RMD can come out. Counts toward your RMD for the year.12 Any conversion that year is on top of the RMD.

Do I have to take my RMD as monthly withdrawals?

No. The law requires the year’s total to come out by the deadline. It doesn’t set a schedule. Monthly, quarterly or once a year all work. 10

If you give by QCD, monthly payments have a cost. Each payment you get before the QCD counts toward the RMD first. Counts in the year the IRA firm pays it.11 Some retirees pause monthly payments until the year’s QCDs are done. Then they restart them.

What if my QCD is larger than my RMD?

That is allowed. The part above your RMD is just extra money out.

A QCD counts toward your required minimum distribution (RMD) for the year.1 Taking out more than your RMD doesn’t earn credit toward a later year’s RMD.2

So one big QCD can’t pay ahead for several years. Each year’s RMD is figured fresh. The gift does leave a smaller balance, which can make later RMDs a bit smaller.

Two things can shrink the amount left out of income. One is after-tax money in your IRAs. By my reading, that matters only if your QCDs for the year top the pre-tax money in them.

Deducted IRA contributions for years ending once you’re 70½ or older shrink the QCD you can leave out of income.19 It shrinks dollar for dollar, minus amounts that already shrank earlier QCDs.19

See the QCD limit for both.

A QCD above your RMD may still be worth considering if you give large amounts. You give from money that hasn’t been taxed yet. And the gift doesn’t raise your income. Whether that beats giving stock depends on your situation. See QCD versus giving stock.

I have several IRAs. Which one should the QCD come from?

Any of your own eligible IRAs can make the QCD.

A QCD must come from an IRA — traditional, rollover or inherited.20 From an inherited IRA, you, the heir, must be 70½ or older.20 A Roth IRA generally can’t be used, because only money that would otherwise be taxed can be a QCD.21 A SEP or SIMPLE IRA can be used only in some years.20 It can’t if an employer puts money in for the plan year ending with or within your tax year.22 Money from your own pay put into a SIMPLE IRA counts as an employer contribution.22 A 401(k), 403(b) or other workplace plan can’t make a QCD.20

If you own more than one traditional IRA, you figure an RMD for each one.23 Then you can add them up and take the total from any one or more of those IRAs.23

A QCD counts as money out for RMD purposes. So a QCD from one IRA can cover RMDs figured on your others. Counts toward your RMD for the year.12

There are a few limits:

  • Your own IRAs and inherited IRAs are separate groups. The adding-up rule for heirs only covers IRAs from the same person who died. 23 24 Money from your own IRA doesn’t meet an inherited IRA’s RMD, or the other way around. See QCDs from an inherited IRA.
  • Spouses don’t add up with each other. Each spouse’s IRAs are their own. The adding-up rule is written for one owner’s IRAs. By my reading, it doesn’t cross between spouses. 23 The QCD limit is per IRA owner too. $111,000 per IRA owner in 2026 ($108,000 in 2025).567

Can I do a QCD in December and still have it count for this year?

Yes, if the IRA makes the payment by December 31.

A QCD counts in the year the IRA firm pays it.11 The first dollars out of your IRA each year count toward your RMD.11 By my reading, a taxable withdrawal taken earlier in the year can’t be turned into a QCD later.11

The risk is how long it takes. IRA firms get busy in December, and some set their own earlier cutoffs. The date that counts is when the IRA pays, not when you ask. Leaving a few weeks of room before December 31 may be worth considering.

Late in the year, mutual funds also share estimates of their year-end gain payouts.

Capital gain payouts from a mutual fund are taxed as long-term gains in the year you get them.28 That’s true however long you’ve owned the fund’s shares.28

If you are near a tax bracket or a Medicare income line, that can affect how much you give.

Missing December 31 has two results. The gift becomes next year’s QCD. And if it was meant to cover this year’s RMD, the RMD may now be short. A short RMD can bring an extra tax on the amount you missed. 12

Can a QCD to a gift annuity count toward my RMD?

Yes. It is still money out of your IRA, so it counts toward your RMD. Counts toward your RMD for the year.12

The wording below covers the one-time option, its conditions, a gift annuity (a deal where you give a charity money and it pays you a set amount for life), and the line 4c (the lines on your tax return where IRA withdrawals and QCDs are reported) entry for an SIE (a one-time IRA gift to a charity trust or annuity that pays you back) on your tax return.

Once in your life, a QCD can fund a charitable gift annuity or a charitable remainder trust.29 The limit is $55,00029 in 2026, and it counts toward your yearly QCD limit.29 It was $50,000 in 2023 and is adjusted for inflation after that.30 Only QCDs can fund it, and only you, your spouse or both can get the payments.29 The right to those payments can’t be passed to anyone else.31 A gift annuity must start fixed payments of 5% or more within one year.29 The payments are taxed as ordinary income.29 On line 4c of Form 1040, you check box 3, enter “SIE,” and attach a statement.31

See the QCD to a charity trust or gift annuity.

Worked example: two IRAs, one QCD, right order versus wrong order

Worked example · tax year 2026Using a QCD to cover most of a combined RMD
Assumptions
  • Hypothetical IRA owner, age 75, no nondeductible basis in any IRA.
  • IRA A has a 2026 RMD of $18,000; IRA B has a 2026 RMD of $12,000.
  • The owner wants to give $20,000 to qualified public charities in 2026.
  • Files as single and takes the standard deduction plus the age-65 amount ($2,050). Apart from the IRA, AGI is $70,000. So AGI is $80,000 in the right order and $100,000 in the wrong order.
  • Income after deductions is $56,150 in the right order and $77,350 in the wrong order. State tax ignored.
  • At 75 the owner gets the $6,000 senior deduction, cut by 6% of modified AGI over $75,000: $5,700 in the right order, $4,500 in the wrong order.

Step 1: Total RMD. Both are the owner’s own IRAs. So the RMDs can be added up and taken from either one.

Item Amount
IRA A RMD $18,000
IRA B RMD $12,000
Total 2026 RMD $30,000

Step 2: Right order (QCD first). In February the owner gives $20,000 by QCD from IRA B. Then they take the rest as a withdrawal from IRA A.

Item Amount
QCD from IRA B (counts toward RMD) $20,000
RMD left ($30,000 − $20,000) $10,000
Taxed withdrawal from IRA A $10,000
Total taken out $30,000
Taxed IRA income $10,000

Step 3: Wrong order (withdrawals first). The owner takes the full $30,000 RMD as monthly taxed payments. Then they give the same $20,000 by QCD in November.

Item Amount
Taxed withdrawals already received $30,000
RMD already met by those withdrawals $30,000
Later QCD (not taxed, but not an RMD offset) $20,000
Total taken out $50,000
Taxed IRA income $30,000

Step 4: The difference.

Item Amount
Taxed IRA income, wrong order $30,000
Taxed IRA income, right order $10,000
Extra taxed income from the wrong order $20,000
Senior deduction lost to the higher AGI $1,200
Extra taxable income ($77,350 − $56,150) $21,200
Tax rate, right order ($56,150 taxable) 22%32
Tax rate, wrong order ($77,350 taxable) 22%32
Extra federal tax ($21,200 × 22%32, all in one bracket) $4,664

The charity gets $20,000 either way. In the wrong order, the owner takes $50,000 out of the IRA instead of $30,000. And $20,000 more of their IRA money is taxed this year.

The wrong-order owner didn’t lose the QCD. Their gift is still left out of income. What they lost was the chance to have the gift replace taxed RMD dollars.

Common mistakes

  • Letting automatic RMD payments run before the QCD. Counts in the year the IRA firm pays it.11
  • Taking the money, then writing a check to charity. Money paid to you first is taxed. It is not a QCD. Paid by the IRA firm straight to the charity, never to you first.262527
  • Using an inherited IRA’s QCD to cover your own RMD. The adding-up rule works within your own IRAs, or within IRAs from the same person who died. It doesn’t cross between them. 23 24
  • Thinking a big QCD pays ahead next year’s RMD. Counts toward your RMD for the year.12
  • Waiting until the last week of December. Delays can push the payment into January.
  • Trying to convert the RMD to a Roth. The RMD comes out first, and a conversion is on top of it.
  • Not telling your tax preparer. The 1099-R (the tax form that reports money paid out of an IRA or an annuity) doesn’t always mark a QCD. You claim it on your return. See how to report a QCD, including what records to keep.

Related video I Tested 4 Ways to Beat RMDs on $2M — Here's What Won

Sources (32)

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  1. A QCD counts toward the IRA owner's (or beneficiary's) required minimum distribution for the year.

    • IRS Publication 590-B (2025), Ch. 1, Required minimum distributions noteA qualified charitable distribution will count towards your required minimum distribution. Checked 2026-10-09.
    • IRS Notice 2007-7, A-42The amount distributed in a qualified charitable distribution is an amount distributed from the IRA for purposes of §§ 408(a)(6), 408(b)(3), and 408A(c)(5). Checked 2026-10-09.

  2. Distributing more than the RMD in one year (including through a QCD larger than the RMD) does not create a credit toward future years' RMDs.

    • IRS Publication 590-B (2025), Ch. 1, Miscellaneous Rules for Required Minimum Distributions, More than minimum receivedIf, in any year, you receive more than the required minimum amount for that year, you won't receive credit for the additional amount when determining the minimum required amounts for future years. Checked 2026-10-09.

  3. A QCD is excluded from gross income and cannot also be claimed as a charitable deduction. Only the portion that would otherwise be taxable can be a QCD; when an IRA has nondeductible basis, the QCD is treated as coming first from the taxable (pre-tax) money, overriding the normal pro-rata rule.

    • 26 U.S.C. § 408 (LII), § 408(d)(8)(E)shall not be taken into account in determining the deduction under section 170. Checked 2026-10-09.
    • 26 U.S.C. § 408 (LII), § 408(d)(8)(B), flush languageA distribution shall be treated as a qualified charitable distribution only to the extent that the distribution would be includible in gross income without regard to subparagraph (A). Checked 2026-10-09.
    • 26 U.S.C. § 408 (LII), § 408(d)(8)(D)Notwithstanding section 72, in determining the extent to which a distribution is a qualified charitable distribution Checked 2026-10-09.
    • IRS Publication 590-B (2025), Ch. 2, QCDsIf your IRA includes nondeductible contributions, the distribution is first considered to be paid out of otherwise taxable income. Checked 2026-10-09.
    • IRS Publication 590-B (2025), Ch. 2, QCDsYou can't claim a charitable contribution deduction for any QCD not included in your income. Checked 2026-10-09.

  4. Adjusted gross income means, for an individual, gross income minus the deductions listed in § 62(a), so an amount excluded from gross income never enters AGI.

    • 26 U.S.C. § 62 (LII), § 62(a)For purposes of this subtitle, the term "adjusted gross income" means, in the case of an individual, gross income minus the following deductions: Checked 2026-10-12.

  5. The annual QCD exclusion was $100,000 through 2023 and is inflation-indexed for tax years beginning after 2023 (SECURE 2.0 § 307), rounded to the nearest $1,000: $105,000 for 2024, $108,000 for 2025, $111,000 for 2026.

  6. The limit applies per IRA owner. On a joint return each spouse may exclude up to the limit, but only from IRAs that spouse owns; one spouse cannot use the other's unused limit.

    • IRS Publication 590-B (2025), Ch. 2, QCDsIf you file a joint return, your spouse can also have a QCD and exclude up to $108,000. Checked 2026-10-09.
    • IRS Notice 2007-7, A-34For married individuals filing a joint return, the limit is $100,000 per individual IRA owner. Checked 2026-10-09.

  7. The QCD exclusion cap applies to the aggregate amount of qualified charitable distributions with respect to a taxpayer during a taxable year, not per account.

    • 26 U.S.C. § 408 (LII), § 408(d)(8)(A)So much of the aggregate amount of qualified charitable distributions with respect to a taxpayer made during any taxable year which does not exceed $100,000 shall not be includible in gross income of such taxpayer for such taxable year. Checked 2026-10-09.

  8. The IRA owner (or beneficiary) must be at least age 70½ on the date the distribution is made. This age was not changed when the RMD starting age rose to 73 (and later 75); QCD eligibility can begin years before RMDs are required.

    • 26 U.S.C. § 408 (LII), § 408(d)(8)(B)(ii)which is made on or after the date that the individual for whose benefit the plan is maintained has attained age 70½ Checked 2026-10-09.
    • IRS Publication 590-B (2025), Ch. 2, Qualified charitable distributions (QCDs)You must be at least age 70½ when the distribution is made. Checked 2026-10-09.
    • IRS Publication 590-B (2025), Ch. 1, Required beginning date FAQYou must begin receiving required minimum distributions by April 1 of the year following the year you reach age 73. Checked 2026-10-09.

  9. An RMD is generally figured for each account by dividing the account's prior December 31 balance by a life expectancy factor from the IRS tables in Publication 590-B. Because the balance drives the figure, money that leaves the IRA this year (including a charitable distribution) lowers the balance used for later years' RMDs, all else equal.

    • IRS, Retirement plan and IRA required minimum distributions FAQs, Q4Generally, a RMD is calculated for each account by dividing the prior December 31 balance of that IRA or retirement plan account by a life expectancy factor that the IRS publishes in Tables in Publication 590-B, Distributions from Individual Retirement Arrangements (IRAs) . Checked 2026-10-10.
    • IRS, Retirement plan and IRA required minimum distributions FAQs, Q2 (example)Your first RMD is due by April 1, 2025, based on your account balance on December 31, 2023, and Your second RMD is due by December 31, 2025, based on your account balance on December 31, 2024. Checked 2026-10-10.

  10. The yearly RMD can be taken in installments (monthly, quarterly or otherwise) or at once, as long as total distributions for the year are at least the required amount.

    • IRS Publication 590-B (2025), Ch. 1, Required Minimum DistributionsThe yearly required minimum distribution can be taken in a series of installments (monthly, quarterly, etc.) as long as the total distributions for the year are at least as much as the minimum required amount. Checked 2026-10-10.

  11. QCDs count for the calendar year in which the trustee makes the distribution (exclusion is per taxable year). Under the RMD rules, the first amounts distributed in a year are treated as the RMD, so a taxable withdrawal taken earlier in the year satisfies the RMD and cannot be converted into a QCD by a later charitable distribution.

    • 26 U.S.C. § 408 (LII), § 408(d)(8)(A)made during any taxable year which does not exceed Checked 2026-10-09.
    • 26 CFR § 1.402(c)-2 (LII), § 1.402(c)-2(f)(2)(i) examplethe first $5,000 distributed will be treated as the required minimum distribution and will not be an eligible rollover distribution Checked 2026-10-09.

  12. If you do not receive the full minimum distribution for a year, you may owe an additional tax on the amount that should have been distributed.

    • Instructions for Form 1040 (2025), Lines 4a and 4b, More than one distributionIf you don’t receive the minimum distribution amount, you may have to pay an additional tax on the amount that should have been distributed. Checked 2026-10-09.

  13. The 73 applicable age applies to individuals who attain age 72 after December 31, 2022 (born in 1951 or later); 75 applies to those who attain 74 after 2032. So the 73/75 RMD start ages apply to people born in 1951 or later.

    • 26 U.S.C. § 401 (LII), § 401(a)(9)(C)(v)In the case of an individual who attains age 74 after December 31, 2032, the applicable age is 75. Checked 2026-10-10.
    • 26 U.S.C. § 401 (LII), § 401(a)(9)(C)(v)(I)the applicable age is 73 Checked 2026-10-10.

  14. The RMD applicable age is 73 for an individual who attains age 72 after 2022 and age 73 before 2033, and 75 for an individual who attains age 74 after 2032 (generally, people born in 1960 or later). Read literally, people born in 1959 fit both clauses; the statute's text does not resolve that overlap.

    • 26 U.S.C. § 401 (LII), § 401(a)(9)(C)(v)(I) In the case of an individual who attains age 72 after December 31, 2022 , and age 73 before January 1, 2033 , the applicable age is 73. (II) In the case of an individual who attains age 74 after December 31, 2032 , the applicable age is 75. Checked 2026-10-09.
    • Instructions for Form 1040 (2025), Lines 4a and 4b, More than one distributionYou must start receiving at least a minimum amount from your traditional IRA by April 1 of the year following the year you reach age 73. Checked 2026-10-09.

  15. The 2024 final RMD regulations leave the applicable age for people born in 1959 reserved; they set 73 for births 1951-1958 and 75 for births on or after January 1, 1960. Proposed regulations published July 19, 2024 would set the applicable age for people born in 1959 at 73. As of 2026-10-09 the eCFR shows no amendment to § 1.401(a)(9)-2 after 2024-09-17, so the proposal has not been finalized.

  16. A conversion (rollover) from a traditional IRA to a Roth IRA is included in gross income to the extent it would have been includible had it not been rolled over; the 10% early-distribution tax of § 72(t) does not apply.

    • 26 U.S.C. § 408A (LII), § 408A(d)(3)(A)(i)-(ii)there shall be included in gross income any amount which would be includible were it not part of a qualified rollover contribution , (ii) section 72(t) shall not apply, Checked 2026-10-09.

  17. If a Roth IRA distribution within the 5-taxable-year period beginning with the year of a conversion is allocable to the converted amount, § 72(t) (the 10% additional tax, with its exceptions) is applied as if that portion were includible in income, limited to the taxable amount converted.

    • 26 U.S.C. § 408A (LII), § 408A(d)(3)(F)(i)such distribution is made within the 5-taxable year period beginning with the taxable year Checked 2026-10-10.
    • 26 U.S.C. § 408A (LII), § 408A(d)(3)(F)(i)then section 72(t) shall be applied as if such portion were includible in gross income. Checked 2026-10-10.

  18. Amounts that must be distributed from a traditional IRA for a year under the RMD rules cannot be converted to a Roth IRA (and are not eligible for rollover), so in an RMD year the RMD has to come out before any of the IRA can be converted.

    • IRS Publication 590-A (2025), Converting From Any Traditional IRA Into a Roth IRA, Required distributionsYou can’t convert amounts that must be distributed from your traditional IRA for a particular year (including the calendar year in which you reach age 73) under the required distribution rules (discussed in Pub. 590-B). Checked 2026-10-10.
    • IRS Publication 590-A (2025), Rollover From One IRA Into Another, Required distributionsAmounts that must be distributed during a particular year under the required distribution rules (discussed in Pub. 590-B) aren’t eligible for rollover treatment. Checked 2026-10-10.

  19. The excludable QCD amount is reduced by the total deductible IRA contributions made for years ending on or after the owner reached 70½, less amounts already used to reduce prior years' QCDs (effective for tax years after 2019, SECURE Act). The reduced amount is taxable but may be deductible as a charitable contribution if itemizing.

    • 26 U.S.C. § 408 (LII), § 408(d)(8)(A), second sentencethe aggregate amount of deductions allowed to the taxpayer under section 219 for all taxable years ending on or after the date the taxpayer attains age 70½ Checked 2026-10-09.
    • IRS Publication 590-B (2025), Ch. 2, Offset of QCDs by amounts contributed after age 70½Beginning in tax years after December 31, 2019, the amount of QCDs that you can exclude from income is reduced by the excess of the aggregate amount of IRA contributions you deducted Checked 2026-10-09.

  20. QCDs may come from a traditional IRA, an inherited IRA if the beneficiary is 70½. Only an amount that would otherwise be includible in gross income can be a QCD (§ 408(d)(8)(B)), so a qualified (tax-free) Roth IRA distribution cannot be one. A SEP or SIMPLE IRA is eligible only if it is not "ongoing" — i.e., no employer contribution for the plan year ending with or within the tax year. 401(k), 403(b) and other employer plans are not IRAs and cannot make QCDs.

    • 26 U.S.C. § 408 (LII), § 408(d)(8)(B)means any distribution from an individual retirement plan (other than a plan described in subsection (k) or (p)) Checked 2026-10-09.
    • IRS Notice 2007-7, A-36that is neither an ongoing SEP IRA described in § 408(k) nor an ongoing SIMPLE IRA described in § 408(p). Checked 2026-10-09.
    • IRS Notice 2007-7, A-37is available for distributions from an IRA maintained for the benefit of a beneficiary after the death of the IRA owner if the beneficiary has attained age 70½ Checked 2026-10-09.
    • Instructions for Forms 1099-R and 5498 (current online version, covers 2026), Box 7a, Qualified charitable distributions (QCDs)Code 4 for a QCD from an inherited (death distribution) IRA Checked 2026-10-09.

  21. A distribution is a QCD only to the extent it would be includible in gross income without the QCD exclusion (§ 408(d)(8)(B) flush language). A qualified Roth IRA distribution is not includible, so it cannot be a QCD.

    • 26 U.S.C. § 408(d)(8)(B), § 408(d)(8)(B), flush languageA distribution shall be treated as a qualified charitable distribution only to the extent that the distribution would be includible in gross income without regard to subparagraph (A). Checked 2026-10-10.

  22. A SEP or SIMPLE IRA is 'ongoing' (and cannot make a QCD) if an employer contribution is made for the plan year ending with or within the owner's tax year. SIMPLE salary-reduction deferrals are made as elective employer contributions, so money deferred from your own pay into a SIMPLE IRA makes it ongoing.

    • IRS Notice 2007-7, A-36a SEP IRA or a SIMPLE IRA is treated as ongoing if it is maintained under an employer arrangement under which an employer contribution is made for the plan year ending with or within the IRA owner's taxable year in which the charitable contributions would be made. Checked 2026-10-10.
    • 26 U.S.C. § 408 (LII), § 408(p)(2)(A)(i)as elective employer contributions to a simple retirement account on behalf of the employee Checked 2026-10-10.

  23. An owner of more than one traditional IRA must figure a separate RMD for each IRA but may total the amounts and take the total from any one or more of the IRAs. The same applies to a designated beneficiary of more than one IRA owned by the same decedent.

    • IRS Publication 590-B (2025), Ch. 1, Miscellaneous Rules for Required Minimum Distributions, More than one IRAyou must determine a separate required minimum distribution for each IRA. However, you can total these minimum amounts and take the total from any one or more of the IRAs. The same rule applies if you are a designated beneficiary of more than one IRA that was owned by a single decedent. Checked 2026-10-09.

  24. IRAs a person holds as beneficiary of one decedent are aggregated with each other for RMD purposes, but not with IRAs the person holds as owner or as beneficiary of a different decedent.

    • 26 CFR § 1.408-8 (LII), § 1.408-8(e)(2)(ii)IRAs that a person holds as a beneficiary of a decedent are aggregated for purposes of paragraph (e)(1) of this section, but those amounts are not aggregated with IRAs that the person holds as the owner or as the beneficiary of a different decedent. Checked 2026-10-10.

  25. A QCD is a distribution from an IRA made directly by the IRA trustee to an eligible charity. The statute and IRS guidance say nothing about the payment method (check, wire, electronic transfer) beyond that the trustee must make it directly to the charity. Money paid to the owner first is not paid directly to the charity.

    • 26 U.S.C. § 408 (LII), § 408(d)(8)(B)(i)means any distribution from an individual retirement plan (other than a plan described in subsection (k) or (p))— (i) which is made directly by the trustee to an organization described in section 170(b)(1)(A) Checked 2026-10-10.
    • IRS Publication 590-B (2025), Ch. 2, Qualified charitable distributions (QCDs)A QCD is generally a nontaxable distribution made directly by the trustee of your IRA (other than an ongoing SEP or SIMPLE IRA) to an organization eligible to receive tax-deductible contributions. Checked 2026-10-10.

  26. The IRA trustee must pay the charity directly; a distribution paid to the owner and then donated is not a QCD. (Whether a check the owner writes from an IRA checkbook counts is not addressed by this source — see rw-qb-check-from-ira-a41.)

    • 26 U.S.C. § 408 (LII), § 408(d)(8)(B)(i)which is made directly by the trustee to an organization described in section 170(b)(1)(A) Checked 2026-10-09.
    • IRS Notice 2007-7, A-41will be considered a direct payment by the IRA trustee to the charitable organization for purposes of § 408(d)(8)(B)(i). Checked 2026-10-09.

  27. IRS Notice 2007-7 treats a check from an IRA, made payable to an eligible charity and delivered by the IRA owner, as a direct payment by the IRA trustee. The notice does not say whether this covers a check the owner writes personally on an IRA checkbook, and no fetched IRS text addresses owner-written IRA checkbook checks.

    • IRS Notice 2007-7, Q-41/A-41If a check from an IRA is made payable to a charitable organization described in § 408(d)(8) and delivered by the IRA owner to the charitable organization, the payment to the charitable organization will be considered a direct payment by the IRA trustee to the charitable organization for purposes of § 408(d)(8)(B)(i). Checked 2026-10-10.

  28. Mutual fund capital gain distributions are reported on Form 1099-DIV and are taxed as long-term capital gains for the year received, regardless of how long the fund shares were held, so they add to that year's income.

    • IRS Publication 550, Ch. 1, Capital Gain DistributionsReport capital gain distributions as long-term capital gains, regardless of how long you owned your shares in the mutual fund or REIT. Checked 2026-10-10.

  29. Once in a lifetime, a QCD may fund a charitable remainder annuity trust, charitable remainder unitrust, or charitable gift annuity, if the entity is funded only by QCDs, only the owner and/or spouse hold the (nonassignable) income interest, and a CGA starts fixed payments of 5% or more within 1 year. The limit is $53,000 (2024), $54,000 (2025), $55,000 (2026) and counts within the annual QCD limit. Payments received are ordinary income. A statement must be attached to the return.

    • 26 U.S.C. § 408 (LII), § 408(d)(8)(F)(i)(I)an election is not in effect under this subparagraph for a preceding taxable year Checked 2026-10-09.
    • 26 U.S.C. § 408 (LII), § 408(d)(8)(F)(ii)(III)commences fixed payments of 5 percent or greater not later than 1 year from the date of funding. Checked 2026-10-09.
    • 26 U.S.C. § 408 (LII), § 408(d)(8)(F)(iv)no person holds an income interest in the split-interest entity other than the individual for whose benefit such account is maintained, the spouse of such individual, or both Checked 2026-10-09.
    • 26 U.S.C. § 408 (LII), § 408(d)(8)(F)(v)(I)shall be treated as ordinary income in the hands of the beneficiary Checked 2026-10-09.
    • IRS Notice 2023-75 (2024 limits), Section 408(d)(8)(F) paragraphis increased from $50,000 to $53,000. Checked 2026-10-09.
    • IRS Notice 2024-80 (2025 limits), Section 408(d)(8)(F) paragraphis increased from $53,000 to $54,000. Checked 2026-10-09.
    • IRS Notice 2025-67 (2026 limits), Section 408(d)(8)(F) paragraphfrom $54,000 to $55,000. Checked 2026-10-09.
    • Instructions for Form 1040 (2025), Line 4a/4b, Exception 3This includes any amount (up to $54,000) of a one-time QCD to a split-interest entity (SIE). Checked 2026-10-09.

  30. The statute sets the one-time split-interest QCD amount at $50,000; the provision (SECURE 2.0 § 307) applies to distributions in taxable years beginning after December 29, 2022, so $50,000 was the 2023 amount. It is inflation-indexed for years after 2023 ($53,000 for 2024, $54,000 for 2025, $55,000 for 2026).

    • 26 U.S.C. § 408 (LII), § 408(d)(8)(F)(i)(II)the aggregate amount of distributions of the taxpayer with respect to which an election under this subparagraph is made does not exceed $50,000 Checked 2026-10-10.
    • 26 U.S.C. § 408 (LII), Effective date note, Pub. L. 117-328, div. T, § 307(c)shall apply to distributions made in taxable years beginning after the date of the enactment of this Act Checked 2026-10-10.
    • 26 U.S.C. § 408 (LII), § 408(d)(8)(G)(i)In the case of any taxable year beginning after 2023, each of the dollar amounts in subparagraphs (A) and (F) shall be increased Checked 2026-10-10.

  31. To report the one-time split-interest QCD, check box 3 on Form 1040 line 4c, enter "SIE", and attach a statement covering no prior election, that only the owner and/or spouse hold the income interest, that it is nonassignable, and the amount.

  32. 2026 federal income tax brackets (ordinary income). Married filing jointly: 10% to $24,800; 12% to $100,800; 22% to $211,400; 24% to $403,550; 32% to $512,450; 35% to $768,700; 37% above. Single: 10% to $12,400; 12% to $50,400; 22% to $105,700; 24% to $201,775; 32% to $256,225; 35% to $640,600; 37% above.

    • Rev. Proc. 2025-32, § 3.01 Table 1 (MFJ)Not over $24,800 10% of the taxable income Checked 2026-10-09.
    • Rev. Proc. 2025-32, § 3.01 Table 1 (MFJ)Over $24,800 but not over $100,800 $2,480 plus 12% of the excess over $24,800 Checked 2026-10-09.
    • Rev. Proc. 2025-32, § 3.01 Table 1 (MFJ)Over $100,800 but not over $211,400 Checked 2026-10-09.
    • Rev. Proc. 2025-32, § 3.01 Table 1 (MFJ)Over $211,400 but not over $403,550 Checked 2026-10-09.
    • Rev. Proc. 2025-32, § 3.01 Table 1 (MFJ)Over $403,550 but not over $512,450 Checked 2026-10-09.
    • Rev. Proc. 2025-32, § 3.01 Table 1 (MFJ)Over $512,450 but not over $768,700 Checked 2026-10-09.
    • Rev. Proc. 2025-32, § 3.01 Table 3 (single)Not over $12,400 10% of the taxable income Over $12,400 but not over $50,400 Checked 2026-10-09.
    • Rev. Proc. 2025-32, § 3.01 Table 3 (single)Over $50,400 but not over $105,700 Checked 2026-10-09.
    • Rev. Proc. 2025-32, § 3.01 Table 3 (single)Over $105,700 but not over $201,775 Checked 2026-10-09.
    • Rev. Proc. 2025-32, § 3.01 Table 3 (single)Over $201,775 but not over $256,225 Checked 2026-10-09.
    • Rev. Proc. 2025-32, § 3.01 Table 3 (single)Over $256,225 but not over $640,600 Checked 2026-10-09.