How QCDs Can Impact Your Taxes | Rodgers & Associates
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How Qualified Charitable Distributions Can Impact Your Taxes and Favorite Charities

The ability to make a “Qualified Chari­table Distri­b­ution” (QCD) from an IRA was first created in the Pension Protection Act of 2006. However, the Tax Cuts and Jobs Act of 2017 (TCJA) made QCDs appealing in record numbers. Anyone who had an IRA and reached age 70½ in 2018 needed to consider carefully how he or she made chari­table gifts.

While chari­table deduc­tions were not directly affected by TCJA, the potential tax benefits were elimi­nated for many people because of the higher standard deduction. Making chari­table gifts through a QCD was a way to keep the tax benefits of a donation.

Qualified Charitable Distribution Rules

Let’s review some of the core require­ments. Under the QCD rules1, the IRA owner must have attained the age of 70 ½ before they can make a QCD. An IRA owner who reaches age 70 in February will be 70 ½ during the year. They cannot make the QCD until August when they actually reach the age of 70 ½. A benefi­ciary of an inherited IRA is eligible to make a QCD once the benefi­ciary is at least age 70 ½2.

There is a maximum QCD dollar amount of $100,000 per year for any individual. This annual limitation is on a per-taxpayer basis (not per IRA). A married couple can each donate up to $100,000 per year from their own IRAs.

QCDs cannot be made from SEP IRAs, SIMPLE IRAs, or from any type of employer retirement plan. Oddly enough, a QCD is permitted from a Roth IRA. But, most distri­b­u­tions from a Roth IRA are already tax-free. Therefore, it generally would not make sense to make a QCD from a Roth IRA.

QCD rules stipulate that distri­b­u­tions must go to a public charity3. Private founda­tions and donor-advised funds do not qualify. Like any other chari­table deduction, the rules specify that the IRA donor cannot receive any kickbacks or other “quid pro quo” benefits. Therefore, donations to any “split-interest chari­table trust” like a chari­table remainder trust or a chari­table lead trust are also not eligible to receive QCD donations.

Normally when a distri­b­ution is made from an IRA containing pre-tax and after-tax dollars, the allocation is made pro-rata. This means part of the distri­b­ution is pre-tax and part after-tax based on the amount of each type of dollars in the account.

This does not apply in the case of a QCD. QCDs are deemed to come from the taxable portion of the account first, ensuring the most favorable treatment.4

To properly complete a QCD:

  1. The IRA owner must be at least age 70 ½ on the date of distri­b­ution
  2. The distri­b­ution comes from the IRA custodian and the check is made payable directly to the charity
  3. The IRA custodian sends the check directly to the charity
  4. Ask the charity to send a gift acknowl­edgment form so you have proof of the gift for your tax records
  5. The IRA custodian reports the distri­b­ution from your IRA but doesn’t specify it as a QCD. On tax Form 1040, the total distri­b­ution is reported on line 4a. The taxable amount is reported on line 4b and “QCD” is noted next to the box to indicate a qualified chari­table distri­b­ution. If the entire amount was given to charity, write $0 and “QCD” on line 4b.

The Benefit of a QCD From an IRA

The biggest benefit of a QCD is the distri­b­ution comes out of the IRA without the tax conse­quences that would otherwise apply. The QCD is deemed to satisfy the required minimum distri­b­ution (RMD), even though the QCD is not taxable. Given the requirement that an IRA owner must be at least age 70 ½ to do the QCD, they will also have at least some RMD due for that tax year.

If Drawing Social Security Benefits

The ability to satisfy RMD require­ments without first showing up as income can be signif­icant for taxpayers drawing Social Security benefits. Social Security recip­ients with incomes above the base amounts of $25,000 (single filer) and $32,000 (joint filer) are subject to federal income tax on their Social Security benefits. For joint filers with incomes above Modified Adjusted Gross Income (MAGI)5 of $44,000, up to 85% of benefits can be taxed. The trigger point for taxing benefits is based on MAGI. Making a QCD lowers MAGI and could poten­tially lower or eliminate the taxation of Social Security.

If You’re on Medicare

It can also be signif­icant for those on Medicare. In 2019, the standard monthly premium for Medicare Part B is $135.50; however, a surcharge applies to seniors with higher income. The surcharge starts at MAGI of $85,000 (singles) and $170,000 (marrieds) and can be as large as $460.50 a month for each person in the household on Medicare! Making a QCD could lower MAGI enough to stay out of the Medicare surcharge range.

Careful planning could be the key to a lower tax bill in 2019 and lower Medicare premiums in subse­quent years. Normal RMDs increase Adjusted Gross Income (AGI) (and MAGI) which may increase tax brackets, increase Medicare premiums, and/or cause a greater portion of Social Security benefits to be taxed.

Consult with a tax profes­sional and/or financial adviser to determine if gifting through a QCD makes sense. There may be factors other than taxes to be considered.

Rick’s Tips:

  • An IRA owner must have attained the age of 70 ½ before they can make a QCD.
  • QCDs cannot be made from SEP IRAs, SIMPLE IRAs, or from any type of employer retirement plan.
  • QCD rules stipulate that distri­b­u­tions must go to a public charity.

1 IRC Section 408(d)(8).

2 IRS Notice 2007–7, Q&A‑37.

3 Public charities are defined in IRC Section 170(b)(1)(A).

4 IRC Section 408(d)(8)(D).

5 Modified adjusted gross income repre­sents your adjusted gross income with the addition of certain deduc­tions and includes interest from tax-exempt bonds.