Numerous changes to retirement accounts have come through two SECURE Acts, which took effect in 2020 and 2022. Yet one thing has remained constant: the age eligibility for making a tax-free withdrawal from an IRA that is paid directly to a qualified charity.
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Called a QCD, or qualified charitable distribution, the IRA owner must be at least age 70 1/2 at the time of the QCD withdrawal -- see IRS Publication 590-B (tinyurl.com/577djj2n). Age 70 1/2 used to be the age for starting required minimum distributions (RMDs) from retirement accounts, but that age requirement has been climbing since 2019, from 70 1/2 to 72 to the current age of 73 (with 75 set to arrive within the next decade).
A reader who inherited an IRA from someone well over 70 1/2 who had been taking QCDs (and RMDs) pushes the age question a little further. "Henry" wants to know if he can take QCDs from the IRA he inherited, even though he himself is under age 70 1/2. When he wrote to me, Henry pointed out that he did some research on his question and remarked: "I'm not finding any exceptions in IRS literature to the age rule."
Henry is right about the lack of exceptions.
IRS Notice 2007-7 supports the conclusion that QCD age 70 1/2 applies to beneficiaries of inherited IRAs (tinyurl.com/4hpf2kxa). Question 37 in the notice deals directly with Henry's situation: "Is the exclusion for qualified charitable distributions available for distributions from an IRA maintained for a beneficiary if the beneficiary has attained age 70 1/2 before the distribution is made?"
The answer? "Yes. The exclusion from gross income for qualified charitable distributions is 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 70 1/2 before the distribution is made."
Henry will need to wait until he is over 70 1/2 before he can take a QCD as the IRA beneficiary. That's too bad, since Henry does need to take RMDs from the inherited IRA, which trigger income taxes.
With no QCD available to him until he is QCD age, he does have other options to soften the tax bite while contributing to charity. For example, he can make a charitable contribution by writing a check to a charity using non-IRA money.
The tax savings won't be quite as large as a full offset that QCDs offer -- that is, if your RMD is $10,000 and your QCD is $10,000, your tax on the RMD is zero. If you can't do a QCD but instead donate $10,000 to charity from a non-IRA account, you would qualify for a charitable tax deduction, but the amount of the deduction would depend on your tax situation.
To get a sense of what that deduction would be in your situation, experiment with the Charitable Giving Tax Savings Calculator online at tinyurl.com/2xuethnz. The calculator is a tool offered by Fidelity Charitable.
Before leaving the topic of QCDs, there is a change in the maximum that can be donated to charity through a QCD. Starting in 2024, the maximum that can qualify for a QCD ($100,000) will increase annually. For 2024, the limit is $105,000 (tinyurl.com/3s4w73tb). Note that each spouse can do his or her own QCD, provided the spouse meets the other requirements, including being 70 1/2 or older.
As always, I caution you that while we can talk about general concepts in this column, you need to visit with your accountant or tax adviser before taking any action on RMDs, QCDs, charitable gifting or taxes. These decisions will be personal to you, based on your unique circumstances.
If you have topic ideas or questions that I can address in this column, I encourage you to write to me at readers@juliejason.com. It's always good to hear from you.
DISTRIBUTED BY ANDREWS MCMEEL SYNDICATION