Qualified Charitable Distributions in 2026: The $108,000 Limit, the RMD Offset, and Every Rule

The most efficient charitable-giving vehicle in the federal tax code for anyone over the age of seventy is not the itemized deduction, not the donor-advised fund, and not the appreciated-stock gift. It is a boring administrative maneuver called a qualified charitable distribution, or QCD, authorized in a single subsection of the Internal Revenue Code most CPAs skim past: IRC §408(d)(8).^[1] The mechanic is trivial: you tell your IRA custodian to send money directly to a qualifying public charity. The tax effects are extraordinary — the transfer is excluded from gross income, it counts against your required minimum distribution, it does not touch your itemized deduction schedule, it does not touch your standard deduction, it does not inflate the modified adjusted gross income that determines your Medicare premiums two years later, it does not push more of your Social Security check into taxation, and every dollar that leaves the IRA leaves your future taxable estate as well.

For 2026 the per-person QCD ceiling is $108,000, up from $105,000 in 2025 and up from the flat $100,000 that stood from the QCD's 2006 enactment through 2023.^[2] The lift is the direct product of SECURE 2.0 §307, enacted December 29, 2022, which amended §408(d)(8)(G) to index the ceiling for inflation starting in tax year 2024.^[3] A married couple with two IRAs can each execute a $108,000 QCD in 2026, so the household ceiling is $216,000. Very few consumer-tier retirees give at that scale, but many give at the $10,000–$40,000 range where the QCD's tax savings are still transformative relative to a cash gift or an appreciated-stock donation processed as an itemized deduction.

This guide is the definitive 2026 reference on the mechanic. It covers the statutory eligibility rules, the SECURE 2.0 §307(b) one-time $54,000 split-interest carve-out, the interaction with IRAs of all types (Traditional, Roth, inherited, SEP, SIMPLE), the post-70½ IRA-contribution trap that silently disqualifies QCDs for working retirees, the paperwork custodians will and will not send you, the IRMAA and Social Security taxation reduction chain, the state-tax dimension where states without a charitable deduction get an outsized QCD benefit, and how to sequence QCDs against Roth conversions, appreciated-stock gifts, and donor-advised-fund contributions. Three worked case studies at $54,000, $108,000, and $216,000 giving levels put dollar numbers on the choices. When you are ready to model the tax effects on your own return, the CalcLeap income tax calculator, the retirement calculator, and the Traditional IRA calculator handle the arithmetic against the 2026 brackets.

1. §408(d)(8): the statutory mechanic in one section

IRC §408(d)(8) is one of the shortest, most self-contained provisions in the retirement-plan sections of the Code. The operative language of subparagraph (A) reads: "Any qualified charitable distribution shall not be includible in gross income of the taxpayer for the taxable year for which the distribution is made." Subparagraph (F) closes the loop by treating the amount as satisfying the RMD requirement under §401(a)(9): "Any amount included in the qualified charitable distribution shall be treated as a distribution described in section 401(a)(9)(A)." Together those two sentences do almost all of the work.

Subparagraph (B) defines the term. A "qualified charitable distribution" is any distribution from an individual retirement account that meets four tests:

1. Age. The distribution is made on or after the date the IRA owner attains age 70½. The reference date is the individual's actual attainment of 70½, not the January 1 following the year of the 70th birthday. The custodian will confirm eligibility from the date-of-birth on file.
2. Direct trustee-to-charity transfer. The distribution is paid directly by the trustee to a §170(b)(1)(A) organization. Money that touches the account owner's hands — even for one day, even in a check made payable jointly — fails the test and becomes an ordinary taxable IRA distribution.
3. Amount limit. The aggregate for the taxable year does not exceed the §408(d)(8)(A) dollar limit, indexed to $108,000 in 2026 under SECURE 2.0 §307 and confirmed by IRS Notice 2025-67.^[4]
4. Otherwise deductible. The distribution would be fully deductible under §170 as a charitable contribution if the taxpayer had received it as ordinary income and paid it out. This test rules out any transfer to which the donor receives more than a token benefit — quid-pro-quo gifts (charity auctions, benefit dinners with substantial value received) do not qualify.

Subparagraph (C) sweeps in inherited IRAs by explicit reference: "Section 408(d)(8) shall be applied to a distribution from an inherited individual retirement account by substituting the beneficiary for the individual." The age test then applies to the beneficiary. A 74-year-old widow who inherits her deceased husband's Traditional IRA can QCD from that inherited IRA up to her own $108,000 ceiling; her deceased husband's age at death is irrelevant.

Subparagraph (D) preserves the pro-rata basis rule of §408(d)(1) with a QCD-specific twist that heavily favors donors with commingled pre-tax and after-tax IRA balances: the QCD is treated as coming out of the pre-tax portion of the IRA first. If you have a $500,000 IRA of which $50,000 is after-tax basis from post-tax contributions or a non-deductible-IRA rollover, and you QCD $50,000, the QCD is pulled entirely from the $450,000 pre-tax slice — and your $50,000 basis is fully preserved for later withdrawals. This is the opposite of the pro-rata rule that applies to a normal IRA distribution, and it makes the QCD the single most efficient way for a donor with mixed-basis IRAs to eliminate the "phantom income" attached to the pre-tax slice.

2. The 2026 numbers: $108,000, indexed under SECURE 2.0 §307

From the QCD's enactment in the Pension Protection Act of 2006 (Pub. L. 109-280) through tax year 2023, the per-person limit was a flat $100,000. Congress did not index it — a fact that grew painful as the CPI-U climbed roughly 65% over the seventeen years. SECURE 2.0 §307 finally amended §408(d)(8)(G) to add an inflation-adjustment mechanic tied to the same CPI-U August-to-August index used for §219(b)(5)(D) IRA contribution limits, rounded to the nearest $1,000. The first indexed year was 2024, at $105,000. The 2025 figure was also $105,000 (small CPI move insufficient to trigger the next $1,000 step). The 2026 figure is $108,000 per person, published in IRS Notice 2025-67 alongside the other retirement-plan cost-of-living adjustments.^[4]

3. The RMD offset — the reason QCDs exist

The QCD's single largest tax effect is that it satisfies the required minimum distribution obligation dollar-for-dollar up to the amount of the RMD. Under IRC §408(d)(8)(F), the QCD is a "distribution described in section 401(a)(9)(A)" — the RMD section. Custodians report the QCD on Form 1099-R like any other IRA distribution, but the taxpayer excludes the amount from gross income by writing "QCD" on the Form 1040 line 4b margin and reducing the taxable amount by the QCD figure.^[5]

The RMD age is now 73, moving to 75 in 2033. SECURE 1.0 (Pub. L. 116-94, Dec. 2019) pushed the RMD age from 70½ to 72; SECURE 2.0 §107 pushed it further to 73 for individuals attaining age 72 after 2022 and to 75 for individuals attaining age 74 after 2032.^[6] But — and this is the load-bearing detail — the QCD age remained fixed at 70½ throughout both amendments. Congress deliberately declined to move it. That gap between the QCD age (70½) and the RMD age (73, moving to 75) creates a two-and-a-half to four-and-a-half year window in which a retiree can execute QCDs without yet having an RMD to satisfy.

In that pre-RMD window, the QCD still gets its full income-tax exclusion, and every dollar transferred reduces the IRA balance that will drive future RMDs. A donor age 71 who QCDs $108,000 in 2026 removes $108,000 of what would otherwise be taxable RMD basis from year 2029 forward — the year the donor turns 74 and takes their first RMD. At a typical 30–35% combined federal-plus-state marginal rate on RMDs pulled at that age, the QCD's compounding effect on future taxable income is meaningful.

4. Which charities qualify (and which absolutely do not)

The eligible-recipient rules are strict and are the second most common source of QCD disqualification (after the direct-transfer rule). §408(d)(8)(B)(i) permits distributions only to charities described in IRC §170(b)(1)(A), and it explicitly names three excluded categories that Congress worried retirees would otherwise use:

The SECURE 2.0 §307(b) split-interest carve-out

Congress opened a narrow one-time exception in SECURE 2.0 §307(b). A donor may make a single lifetime QCD of up to $54,000 in 2026 (indexed) to fund one of three "split-interest" charitable vehicles: a charitable remainder annuity trust (CRAT) under §664(d)(1), a charitable remainder unitrust (CRUT) under §664(d)(2), or a charitable gift annuity (CGA) under §501(m)(5).^[3] The mechanic mirrors an ordinary QCD — direct trustee-to-charity transfer, gross-income excluded, RMD-satisfying — but with three sharp restrictions. First, the election is a one-time lifetime election. Once made, it cannot be repeated in a later year. Second, only certain family members can be the non-charitable income beneficiaries — the donor and/or the donor's spouse. Third, the split-interest vehicle must pay out at least 5% and no more than 50% of the trust value annually, and the payments must be fully taxable to the recipient as ordinary income (no cost-basis recovery).

The §307(b) split-interest election is most useful for a 70+ donor who wants some income stream from the gift and does not need the RMD offset for the full $54,000. In practice it is executed most often as a charitable gift annuity funded by a QCD — a $54,000 IRA-to-CGA transfer that generates a lifetime monthly payment (~5–7% of face at typical 70+ ages) taxed entirely as ordinary income to the donor. The tax deduction on the actuarial value of the remainder interest is unavailable (since the QCD already gets the income exclusion), but the estate is reduced, the donor gets a lifetime income stream, and the eventual remainder passes to charity.

5. Which accounts a QCD can come from — and the 401(k)/403(b) workaround

QCDs come only from IRAs. Not 401(k)s. Not 403(b)s. Not 457(b) plans. Not Solo 401(k)s. Not TSPs. Not active SEP-IRAs or SIMPLE-IRAs. The statutory hook is §408(d)(8)(B)(iii), which limits QCD source accounts to "an individual retirement account or individual retirement annuity (other than a Simplified Employee Pension account described in section 408(k) or a SIMPLE retirement account described in section 408(p) that is ongoing)." An "ongoing" SEP or SIMPLE is one to which an employer contribution has been made in the year of the QCD or in an earlier year still under the plan's contribution horizon. A dormant, no-current-contribution SEP or SIMPLE — common for a retiree whose former employer's plan is still open but not funding — can be a QCD source.

6. The IRMAA and Social Security taxation reduction chain

Two of the QCD's most important effects are what it does not do to two other federal calculations.

IRMAA (Medicare Part B and Part D income-related monthly adjustment amount). A retiree's Medicare Part B and Part D premiums are surcharged when modified adjusted gross income two years prior exceeds threshold amounts published annually by the Social Security Administration. For 2026, the first IRMAA tier begins at MAGI above $109,000 (single) / $218,000 (MFJ) and adds $75.60/month to Part B on top of the $185 standard premium; the top tier at $500,000+ MAGI single / $750,000+ MFJ adds $421.80/month.^[8] A Roth conversion or a large RMD that pushes a retiree across an IRMAA tier boundary costs the couple $1,000–$5,000 per year in extra Medicare premiums, per person, for two full years. A QCD generates zero MAGI because it is excluded from gross income at §408(d)(8)(A) — so the QCD is IRMAA-neutral. A $54,000 RMD taken as an ordinary distribution can trigger an IRMAA tier crossing; the same $54,000 taken as a QCD does not.

Social Security taxation. Under IRC §86(a), between 0% and 85% of Social Security benefits are includible in gross income depending on "combined income" (adjusted gross income + tax-exempt interest + one-half of Social Security benefits). For a MFJ couple, the two thresholds are $32,000 and $44,000 of combined income; single filers see $25,000 and $34,000.^[9] The formula runs off AGI. A QCD does not enter AGI (it is a below-the-line adjustment via the gross-income exclusion). A $54,000 RMD taken in ordinary form adds $54,000 to combined income and can push a couple that would have had 50% of their Social Security taxed into the 85% zone; the same $54,000 as a QCD leaves the taxation zone untouched.

7. Why QCDs beat itemized deductions for most retirees

The Tax Cuts and Jobs Act of 2017 nearly doubled the standard deduction and capped the state-and-local-tax itemized deduction at $10,000 (a SALT cap the OBBBA of 2025 extended and did not repeal). The result: the share of taxpayers itemizing collapsed from ~30% pre-TCJA to under 10% post-TCJA.^[10] For anyone taking the standard deduction, a cash gift to charity has zero federal-tax effect — the charitable deduction line on Schedule A is unavailable because Schedule A itself is unavailable.

The QCD sidesteps this problem entirely. It is an above-the-line gross-income exclusion, not an itemized deduction. The standard deduction remains fully available. For 2026 under IRS Notice 2025-67 and Rev. Proc. 2025-30, the standard deduction figures are:

An age-65+ MFJ couple gets $36,400 of standard deduction in 2026. A $10,000 cash gift claimed as an itemized deduction produces zero federal benefit until the couple's other Schedule A items ($10,000 SALT cap + mortgage interest + medical over 7.5% AGI floor) plus the gift exceed $36,400. For most retirees who paid off the mortgage a decade ago and have low medical expenses, that threshold is out of reach. A $10,000 QCD from the same couple's IRA delivers $2,200–$3,400 of federal tax savings (22–34% marginal bracket) plus IRMAA insulation plus Social-Security-taxation insulation — regardless of Schedule A eligibility.

8. The post-70½ IRA contribution trap

SECURE 1.0 §107 repealed the age-70½ ban on Traditional IRA contributions in 2019. A working retiree with earned income can now contribute to a Traditional IRA at any age, including at 82. But Congress worried this would open a laundering channel — deduct a Traditional IRA contribution today, QCD it tomorrow, get a double benefit. To close the loophole, SECURE §107(b) added §408(d)(8)(A)(iii): the annual QCD exclusion is reduced (but not below zero) by the aggregate deductible IRA contributions the taxpayer has made after attaining age 70½ that have not yet been offset against prior years' QCDs.^[6]

The mechanic is cumulative and lifetime. If you contributed $7,500 (deductible) to a Traditional IRA at age 71 and $7,500 at age 72, you have $15,000 of "post-70½ deductible contribution" balance. At age 73 you QCD $50,000. The QCD exclusion is reduced by the full $15,000 — you get a $35,000 QCD exclusion and a $15,000 taxable IRA distribution. The RMD-satisfaction rule still works for the full $50,000 (all $50K counts against the RMD), but only $35K is excluded from income. In a later year you QCD another $50,000; because the $15,000 was already absorbed, that later year gets the full $50,000 exclusion.

9. The state-tax dimension — a hidden QCD kicker

Every state that imposes an income tax and starts from federal adjusted gross income (a majority) automatically inherits the QCD exclusion — the QCD is not in federal AGI, so it is not in state taxable income. But most states do not permit itemized deductions in the same generous form as the federal system, and several states (Massachusetts, Michigan, Illinois, Pennsylvania, Indiana, and a handful of others) permit no charitable itemized deduction at all. In those states, a QCD delivers state-tax savings that a cash charitable gift cannot.

The pattern that emerges: for retirees domiciled in Illinois, Pennsylvania, Michigan, or (partially) New Jersey, the QCD's state-tax kicker is a genuinely large number. An Illinois retiree QCD'ing $54,000 to their alma mater saves 4.95% × $54,000 = $2,673 of Illinois income tax that a cash gift + Schedule A cannot recover, because Illinois offers no charitable deduction. Over a decade of QCDs, the cumulative state-tax savings can exceed $25,000 in Illinois alone.

10. Custodian paperwork and the Form 1099-R quirk

The single most confusing part of QCD administration is that IRA custodians do not report the QCD status on Form 1099-R. The custodian reports the transfer as an ordinary Traditional IRA distribution with Box 1 (gross distribution) equal to the QCD amount, Box 2a (taxable amount) equal to the same amount, and Box 7 (distribution code) generally as "7" (normal distribution) or, less commonly, blank. Nothing in the Form 1099-R identifies the transfer as a QCD.^[5]

The taxpayer bears the burden of adjusting on Form 1040. The 2026 draft Form 1040 instructions repeat the QCD reporting mechanic:

1. Enter the total gross IRA distribution amount on Form 1040 line 4a.
2. Subtract the QCD amount from the gross to arrive at the taxable amount, and enter that on line 4b.
3. Write "QCD" in the margin next to line 4b.

The IRS does not require Form 8606 for QCDs (the QCD's pre-tax-first rule under §408(d)(8)(D) sidesteps the pro-rata basis mechanic that §8606 tracks), but many tax preparers file an informational statement anyway to document the transfer. For state returns, the QCD flows through automatically to any state that starts from federal AGI, which is most.

The documentation the donor must retain mirrors the ordinary charitable-gift substantiation rules under IRC §170(f)(8):

• A written acknowledgment from the receiving charity for any gift of $250 or more, stating the amount of cash received and whether the charity provided any goods or services in exchange.
• The IRA custodian's copy of the check made payable to the charity, or the electronic-transfer confirmation showing the direct trustee-to-charity payment.
• A copy of the Form 1099-R the custodian issued in January of the following year.

11. Three worked case studies

Case A — Priya, age 74, $54,000 RMD, IL resident

Priya is a 74-year-old widow living in Chicago. Her Traditional IRA balance on December 31, 2025 was $1.35 million; her 2026 RMD (25.5-year distribution period at age 74 under the 2022 Uniform Lifetime Table) is $52,941. She rounds up and takes the $54,000. She has $32,000 of Social Security, $8,000 of pension income, no other taxable income, and takes the standard deduction ($16,550 base + $2,050 age-65 additional = $18,600 for single).

Scenario 1 — RMD as cash, $10,000 cash gift to her church itemized: AGI = $54,000 RMD + $8,000 pension + 85% × $32,000 Social Security = $89,200. Standard deduction $18,600 vs itemized ($10,000 charitable + $0 SALT because Illinois has no property tax at her level of homeownership + no mortgage interest) = $10,000. She takes the standard. Taxable income = $70,600. Federal tax ≈ $10,650 (24% bracket for the top slice, blended average ~15%). Illinois tax on $54,000 non-retirement source income (Illinois excludes the pension AND the RMD under §203(a)(2)(F)) = $0. Church receives $10,000. Priya's federal tax on the RMD ≈ $8,400 (RMD's marginal contribution).

Scenario 2 — $54,000 QCD to her church: QCD satisfies the RMD; nothing enters AGI from the IRA. AGI = $8,000 pension + 50% × $32,000 Social Security = $24,000 (below the 85% threshold now). Standard deduction $18,600. Taxable income = $5,400. Federal tax ≈ $540 (10% bracket). Illinois tax on $8,000 pension = $0 (Illinois exempts). Church receives $54,000. Priya's federal tax on the RMD = $0. Delta vs Scenario 1: ~$10,100 in federal tax saved and the church gets $44,000 more.

Case B — David and Rachel, ages 71 and 68, $216,000 combined giving budget, NJ residents

David and Rachel are a MFJ couple in Short Hills, NJ. David is 71, retired, with a $2.4M Traditional IRA. Rachel is 68, still working part-time, with a $980K Traditional IRA. Combined 2026 income: $180,000 W-2 (Rachel), $60,000 Social Security (David only, taken at 70), $18,000 dividends. They plan a $216,000 combined charitable gift year — half to their local university, half to a family-recommended DAF.

Scenario 1 — $108,000 cash to university itemized, $108,000 to DAF itemized: AGI = $180K + $51K taxable SS (85% of $60K) + $18K dividends = $249K. Schedule A = $10K SALT + $216K charitable = $226K. Federal tax ≈ $23K (blended). NJ state tax: NJ does not offer a general charitable deduction, so NJ taxable income ≈ $240K (excludes Social Security), NJ tax ≈ $12,600 at NJ's brackets. Total = $35,600.

Scenario 2 — David QCDs $108,000 to university from his IRA; Rachel (age 68, ineligible for QCD) writes a $108,000 cash check to DAF and itemizes: AGI = $180K + $51K SS + $18K div = $249K (Rachel is not yet 70½, so no QCD from her). But David's $108K QCD is excluded from AGI even though it satisfies part of his eventual RMD landscape. Schedule A = $10K SALT + $108K DAF charitable = $118K. Federal tax ≈ $22K. NJ state tax: David's QCD is excluded from NJ income too (NJ starts from a modified federal AGI). NJ taxable income ≈ $132K (much lower after excluding both David's Social Security and the $108K QCD amount because David has no RMD until 73 and this is a pre-RMD QCD that removes IRA basis). NJ tax ≈ $6,900. Total = $28,900. Delta vs Scenario 1: ~$6,700 in state tax saved and future RMD basis reduced by $108K.

Scenario 3 (the winning move) — Wait one more year: In 2027, Rachel turns 70. She still cannot QCD (needs 70½). But she can start planning the $216,000 combined QCD strategy for 2029 when she turns 70½ mid-year. The lesson: the QCD is a per-owner tool that requires each spouse to individually cross the 70½ threshold. Household giving budgets that exceed one spouse's $108K limit for the year should either wait for the second spouse to qualify or use a hybrid QCD-plus-cash-gift structure like Scenario 2.

Case C — Marcus, age 78, $2.2M IRA, $200K annual charitable intent, WA resident then FL relocator

Marcus is 78, widowed, a former engineer at a Seattle biotech. Traditional IRA balance $2.2M on 12/31/2025; 2026 RMD (age 78, 22.9-year period) = $96,070. He gives ~$200,000 annually to charity because his living expenses are covered by Social Security + a rental property. He plans to relocate from Washington (no state income tax, but with the 2026 estate-tax regime) to Florida (no state income tax, no state estate tax) in mid-2027.

The 2026 plan: Marcus executes a $108,000 QCD in January to a mix of his local hospital foundation ($50K), his church ($30K), and a public university foundation ($28K). The QCD fully satisfies the $96,070 RMD (with $11,930 of the QCD reducing future-year IRA basis). Marcus's AGI drops from what would have been ~$140K (RMD + Social Security + rental) to ~$44K (Social Security + rental). His federal tax bill drops ~$21K. His IRMAA baseline for 2028 Medicare premiums stays below the first tier. The remaining ~$92K of his charitable intent for the year comes from appreciated Amazon stock in his taxable brokerage account — he gifts $92K of AMZN shares (basis ~$8K) to the same three charities as a §170(e)(1) qualified appreciated stock gift, deducts $92K on Schedule A, avoids ~$18K of capital gains tax on the embedded gain, and pays $0 federal tax on the stock gift itself.

Combined 2026 outcome: $200K to charity, ~$21K federal tax saved on the RMD side, ~$18K capital gains tax avoided on the stock side, ~$44K standard-deduction-plus-QCD-plus-appreciated-stock stack of federal savings, zero state tax (WA has no state income tax on retirement income), IRMAA-tier preserved. Over an eight-year retirement horizon executing the same strategy annually, Marcus removes over $860,000 of what would otherwise be RMD basis from the IRA and saves over $250,000 in cumulative federal income tax vs an equivalent all-cash gifting strategy.

12. Six mistakes to avoid

1. Making the check payable to yourself. The single most common QCD-disqualifying error. §408(d)(8)(B)(i) requires the distribution be paid "directly by the trustee" to the charity. A check made payable to the account owner, deposited to a personal checking account, and then written to the charity from that personal account is a taxable IRA distribution followed by a personal charitable gift. The direct-transfer requirement is unforgiving. The IRS has been consistent in Private Letter Rulings that even one-day intermediate custody kills QCD status.
2. QCD'ing to a DAF. Section 4966(d)(2) donor-advised funds are excluded from QCD-eligible recipients. Retirees who have used Fidelity Charitable, Schwab Charitable, or a community-foundation DAF for years often assume the DAF is a valid QCD destination. It is not. QCDs must go to underlying operating charities.
3. Ignoring the post-70½ deductible contribution offset. Working retirees who take a deductible Traditional IRA contribution at 71 or 72 silently reduce their subsequent QCD exclusion by the same amount. If you want to keep working and contributing to an IRA past 70½, contribute to a Roth or use non-deductible Traditional contributions to preserve full QCD eligibility.
4. Waiting until December 31 to execute a year-end QCD. Custodian processing times vary, and a QCD dated December 30 that clears January 3 is a next-year QCD, not a current-year QCD. Complete the transfer by mid-December to avoid the year-end custodian queue. This matters especially for donors who need the QCD to satisfy the current year's RMD — a late-clearing QCD leaves the RMD unsatisfied and triggers the 25% excise tax under §4974(a).
5. Missing the RMD-first sequencing rule. The QCD's RMD-satisfying rule works only if the QCD is the first distribution taken from the IRA in the year. If you take a regular $30,000 RMD distribution in March and then execute a $30,000 QCD in October, only the QCD portion is excluded from income — but the March distribution is already fully taxable. The March distribution counted against the RMD; the October QCD is "extra" and did not offset an RMD you had not yet taken. Execute QCDs first in the year to preserve the offset.
6. Assuming the state-tax benefit follows automatically. Most states start from federal AGI and inherit the QCD exclusion, but a few states (California and Massachusetts among them) require an additional confirmation on their own return, and a few (New York for high earners) apply a state-level "charitable deduction haircut" that does not affect the QCD but that a preparer may inadvertently apply out of muscle memory. Confirm with your state-return preparer that the QCD is being properly excluded.

13. Pre-execution checklist

1. Confirm the IRA source: Traditional IRA, Rollover IRA, inherited IRA, or dormant SEP/SIMPLE. If the balance is in a 401(k)/403(b)/457(b), initiate a direct trustee-to-trustee rollover to a Traditional IRA at least 60 days before the target QCD date.
2. Confirm the age test: you must be age 70½ or older on the date the transfer is executed. Confirm the custodian has your date of birth correctly on file.
3. Verify the recipient charity's IRS status. Use the IRS Tax Exempt Organization Search tool to confirm the charity is a §170(b)(1)(A) public charity and NOT a §509(a)(3) supporting organization, §4966(d)(2) DAF, or §509(a) private non-operating foundation.
4. Compute the year's RMD (or check with your custodian). Under the 2022 Uniform Lifetime Table divide your December 31 prior-year balance by the age-appropriate distribution period. If you have multiple IRAs, the RMD can be aggregated across them under §408(d)(2), but you must take the actual distribution — including the QCD — from an IRA account specifically.
5. Decide the split between QCD and any regular distribution. Take the QCD first in the year to preserve the RMD-offset order.
6. Initiate the direct trustee-to-charity transfer through your custodian's QCD request form. Fidelity, Schwab, Vanguard, and TD Ameritrade all have standard forms. Confirm the check will be made payable directly to the charity (not to you) and mailed to the charity (not to you). If your custodian offers a QCD debit-card or QCD-checkbook feature that generates checks payable to the charity from the IRA custodian, that also satisfies the direct-transfer rule.
7. Retain the charity's written acknowledgment (required for any gift ≥$250 under §170(f)(8)), the custodian's confirmation, and the copy of the check or wire.
8. File Form 1040 correctly: gross IRA distribution on line 4a, gross minus QCD on line 4b, "QCD" in the margin. If you use tax-preparation software, the software should prompt for QCD status when it encounters a §7-coded Form 1099-R for a taxpayer age 70½+.

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