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RMDs and IRA-to-Charity Distribution Provisions

Tax law requires individuals who have reached age 72 to begin taking minimum distributions from their traditional IRA accounts. These are referred to as a required minimum distribution or RMD. The RMD amount is the value of the IRA account on the last day of the prior year divided by the distribution period from the Uniform Lifetime Table, corresponding to the taxpayer’s attained age. For example, if an individual had their 75th birthday in the current year, the distribution period from the Table is 24.6. If the balance in the IRA were $500,000 on the last day of the prior year, then the individual’s RMD for the current year would be $20,325 ($500,000/24.6). (The IRS developed the Table using mortality rate data and updated it effectively with 2022 distributions.)

Qualified Charitable Distributions - The tax law also permits individuals aged 70½ or over to transfer funds from their IRA accounts to charities in what is referred to as Qualified Charitable Distributions (QCDs). These QCDs are not taxable, and where a taxpayer is also required to take required minimum distributions (RMDs), the QCDs count toward the RMD requirement. Thus, in our previous example, if the individual had transferred the $20,325 to a qualified charity in a QCD, the $20,325 would not have been taxable.

QCDs are not limited to RMDs. For those with large IRA balances, QCDs can total up to $100,000 per year. Neither are QCDs limited to a single transfer in a tax year so long as the total distributed does not exceed the $100,000 annual limit.

Example: Anne wants to contribute to her church’s building fund, the American Cancer Society, and the American Red Cross in the same year. She can do that by having her IRA make separate direct transfers to each charity.

It is important to remember that all Traditional IRAs are treated as one for determining an RMD and that the IRA trustee must directly transfer all QCDs to the charity.

QCD Benefits – QCDs can provide significant tax benefits. Here is how this provision, if utilized, plays out on a tax return:

  1. The IRA distribution is excluded from income.

  2. The distribution counts toward the taxpayer’s RMD for the year; and

  3. The distribution does NOT count as a charitable contribution deduction.

At first glance, this may not appear to provide a tax benefit. However, by excluding the distribution, a taxpayer lowers their adjusted gross income (AGI), which helps for other tax breaks (or punishments) pegged at AGI levels, such as medical expenses if itemizing deductions, passive losses, taxable Social Security income, and so on. In addition, non-itemizers essentially receive the benefit of a charitable contribution to offset the IRA distribution.

Fly In the Ointment – In the past, the tax code did not permit contributions to IRAs by individuals once they reached age 70½, which coordinated with the prior age requirement to begin RMDs and the ability to make QCDs. The age restriction to contribute to IRAs has been eliminated, so now, individuals may make IRA contributions at any age, provided they have earned income.

Whether intentional or oversight by Congress, the tax changes did not modify the age at which a taxpayer can begin making QCDs and left it at age 70½ – no longer in synchronization with the revised RMD age of 72.

Unfortunately, that has created a situation that can be detrimental for individuals who have earned income and wish to utilize the QCD provisions and continue to contribute to an IRA after age 70½.

The problem is that a QCD must be reduced by the sum of IRA deductions made after age 70½, even if they are not in the same year, causing unexpected tax results for taxpayers unaware of this complication. A couple of examples best explain this.

Example #1 Jack makes a deductible IRA contribution of $7,000 when he is 71 and another $7,000 contribution at 72. He claims an IRA deduction of $7,000 on his tax return for each year. Then later, when he is 74, he makes a QCD of $10,000 to his church’s building fund. Since Jack had made the IRA contributions after age 70½, his QCD must be reduced by the post-70½ contributions that were deducted, and as a result, the $10,000 is a taxable IRA distribution ($10,000 – 14,000 = <$4,000>). However, he can claim $10,000 to the church building fund as a charitable contribution on Schedule A if he itemizes his deductions.

In the next year, Jack makes a $5,000 QCD to the university where he got his degree. The excludable amount of the QCD is $1,000 ($5,000 - $4,000 = $1,000). The $4,000 is the amount that remained from post-age 70½ IRA contributions that didn’t previously offset QCDs. Jack includes $4,000 as taxable IRA income and can deduct $4,000 as a charitable contribution if he itemizes. No amount of post-age 70½ IRA contributions remains to reduce the excludable amount of QCDs for subsequent taxable years.

Example #2 Bob makes a traditional IRA contribution of $7,000 at age 71 and another $7,000 contribution at the age of 72 and deducts the IRA contributions on his returns. Then later, when he is 74, he makes a QCD of $20,000 to his church’s building fund. Since Bob had made the deductible IRA contributions after age 70½, his QCD must be reduced by $14,000. As a result, of the $20,000 QCD, $14,000 is a taxable distribution, $6,000 is nontaxable, and Bob can claim a $14,000 charitable contribution.

All this can become quite complicated. If you are considering making a QCD and made IRA contributions after age 70½ and don’t understand the tax ramifications, consult with this office before you make the distribution.


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