Retirement Giving
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The One-Time QCD to a Charitable Remainder Trust or Gift Annuity

Josh Rendler, CFP®

Creator of Motion Retirement

Updated 2026-10-12 · Tax years 2023, 2024, 2025, 2026 · Figures checked October 10, 2026 · How this is checked

Can I do a QCD to a charitable gift annuity?

Yes, once in your life. At 70½ or older, you can send IRA money straight to a charity contract or trust that pays you. People call it a one-time QCD (a one-time IRA gift to a charity trust or annuity that pays you back). The 2026 limit is $55,000. It was $54,000 in 2025. It counts inside your yearly IRA giving limit. Every payment you get back is ordinary income.

  • This is a once-in-a-life QCD (money sent straight from your IRA to a charity at 70½ or older, not taxed as income, up to a yearly limit). It can fund a gift annuity (a deal where you give a charity money and it pays you a set amount for life). Or a charitable remainder trust (a CRAT (a charity trust that pays you the same dollar amount every year) or CRUT (a charity trust that pays you a set percent of its value, so payments go up and down)). It can pay you, your spouse, or both.
  • The limit is $55,000 for 2026, up from $54,000 for 2025. It's part of the yearly IRA giving limit, not extra.
  • An older, lower number you may see was the 2023 amount written into the law. It has gone up with inflation each year since.
  • Only money that came in as a QCD can go into the annuity or trust. No other money of yours. A gift annuity must start fixed payments of 5% or more within one year of funding.
  • Every payment is ordinary income. There's no deduction, because the IRA money was never taxed.
Jump to a question

Normally, a QCD must go straight to a charity. You get nothing back. A 2022 law made one small exception.

Once in your life, that QCD can go to something that pays you back. One is a gift annuity. The other is a CRT (a trust that pays you or people you name for life or a set term, then gives what is left to charity). This page is for IRA owners 70½ and older. It’s for those weighing income for themselves plus a future gift.

What is the one-time QCD to a split-interest entity?

It’s a one-time choice to send a QCD to a gift annuity or a charity trust that pays you. The wording below covers the limit, the conditions, and line 4c (the lines on your tax return where IRA withdrawals and QCDs are reported) of your tax return.

Once in your life, a QCD can fund a charitable gift annuity or a charitable remainder trust.1 The limit is $55,0001 in 2026, and it counts toward your yearly QCD limit.1 It was $50,000 in 2023 and is adjusted for inflation after that.2 Only QCDs can fund it, and only you, your spouse or both can get the payments.1 The right to those payments can’t be passed to anyone else.3 A gift annuity must start fixed payments of 5% or more within one year.1 The payments are taxed as ordinary income.1 On line 4c of Form 1040, you check box 3, enter “SIE,” and attach a statement.3

The trust must be a CRAT. Or a CRUT. There’s no deduction on top. Left out of income before AGI, so it can't also be deducted.45

The normal QCD rules still apply.

  • Your age: 70½ or older on the day the money leaves the IRA.6
  • How it’s paid: Paid by the IRA firm straight to the charity, never to you first.789

How much can you put into a CGA or CRT with a QCD?

The limit is $55,0001 for 2026, up from $54,0001 for 2025. Once in a lifetime, up to $55,000 in 2026, inside the yearly QCD limit.123

Tax year One-time limit Yearly IRA giving limit
2024 $53,0001 $105,00010
2025 $54,0001 $108,00010
2026 $55,0001 $111,00010

Why you may see an older, lower number

That lower number was the 2023 amount: $50,0002. It applied to 2023, the first year this option existed. The law raises it for inflation each year after that. The IRS has posted a higher figure every year since. So a page quoting the old number is out of date.

It’s inside your yearly limit, not extra

This amount counts toward your yearly IRA giving limit. $111,000 per IRA owner in 2026 ($108,000 in 2025).101112 Say you use the full one-time amount in 2026. That amount comes out of your $111,00010 yearly limit. Only what’s left after it is still open for gifts straight to charities. See IRA giving limits.

What are the requirements?

Every part of the rule above must be met. Miss one and it isn’t a QCD, so that money is taxed.

Only QCD money can go in. By my reading, that means a new, separate contract or trust. Nothing else of yours can ever have gone in. See the open question about two spouses, one trust.

A deferred annuity doesn’t fit either. By my reading, that’s because the payments must start within one year of funding.

For a gift annuity, the law asks for “fixed payments of 5 percent or greater” but doesn’t say 5% of what. By my reading, it’s the amount you put in, and the example below uses that.

Two more conditions sit outside that wording.

Requirement What it means
It must be a standard gift annuity The law borrows the usual legal definition of a gift annuity.13 So the payments must run over one or two lives.14 The contract can’t promise a minimum amount of payments, or set a maximum amount. By my reading, that limit is about the total paid out, not each payment. The payments also can’t move with the income the charity earns. And their value must be under 90% of what you put in.13 It’s worth asking the charity to confirm in writing that the contract meets these conditions
The charity’s share would be deductible For a trust, the whole remainder interest. For a gift annuity, what you put in minus the value of your payments.15 The yearly caps on charity deductions, like the cap based on your income, are ignored for this test.16

A regular QCD has to be a gift you could fully deduct. This one-time version swaps in the test in the table above: the charity’s share.15 The wording below is that general QCD test. It also covers the caps tied to your AGI (your total income minus a few set subtractions, the number many tax rules start from), which are ignored either way, and the charity receipt (the written receipt a charity gives you for a large gift, needed before you file) you need.

A QCD must be a gift you could fully deduct if it weren’t a QCD.17 By my reading, a benefit you get back, like a dinner, can stop it from counting.17 A small token item doesn’t count. That holds if the charity correctly decides it isn’t worth much and says the gift is fully deductible.18 The AGI caps on deductions don’t count for this test.19 For a QCD of $25017 or more, you need the same charity receipt a deduction needs.17

A trust has its own payout rules.

A CRAT pays a fixed amount each year, set at 5% to 50% of what went in.20 A CRUT pays a set 5% to 50% of the trust’s value, measured again each year.21 Either pays at least once a year.20 It can run for a set term of up to 20 years, or for the lives of the people paid.2022 Those people must be alive when the trust starts.22 The charity’s share must be worth at least 10% of what goes in.23

Pooled income funds aren’t allowed. Nor are donor-advised funds or private foundations (a charity funded mostly by one person, family or company, not a public charity).

Can a married couple get one joint annuity?

Yes. The payments can go to you, your spouse, or both. Once in a lifetime, up to $55,000 in 2026, inside the yearly QCD limit.123 So one annuity paying you both is allowed. Whether each spouse can put their own one-time gift into it is less clear. See the open questions below.

How are the payments taxed?

Every payment is ordinary income. The usual gift annuity split, with a tax-free part and capital gain, doesn’t apply. Neither does a tax-free layer from a trust.

The reason is simple. The money left your IRA without being taxed. So it’s taxed when it comes back to you.

You also get no deduction for the gift part. The wording below covers how that works with your taxable income (the part of your income that tax rates are actually charged on).

A QCD is left out of your income, so it never reaches your AGI.45 Because of that, you can’t also deduct it as a charitable gift.4 If your IRA holds after-tax money, the QCD comes first from the money that would be taxed.4

How do you report it?

You report it like other QCDs, with one extra step.

  1. Ask the firm that holds your IRA to send the money straight to the charity or the trust. The law allows this. But each firm sets its own process, so it’s worth confirming early.
  2. Get the written acknowledgment from the charity or trust.
  3. Report the amounts on Form 1040, lines 4a and 4b. The 2026 form isn’t out yet, so check the line numbers for your year.
  4. On line 4c, check box 3 and write SIE. Once in a lifetime, up to $55,000 in 2026, inside the yearly QCD limit.123
  5. Attach a short statement. It says you haven’t made this choice before. It says only you or your spouse get paid. It says the payments can’t be transferred. And it gives the amount.3

Here are the lines for a regular QCD, which this builds on. They cover Form 1099-R (the tax form that reports money paid out of an IRA or an annuity), an inherited IRA (an IRA you get from someone who died) and Form 8606 (the tax form that tracks money in an IRA you already paid tax on).

Your IRA firm reports a QCD on Form 1099-R as an ordinary IRA payout.24 It uses code 7 from your own IRA, or code 4 from an inherited IRA.24 For 2026 it may add code Y, but it doesn’t have to.25 Code Y pairs only with codes 4, 7 or K, and none of those is a Roth IRA code.26 On the 2025 Form 1040, put the whole payout on line 4a.27 Put only the part that isn’t a QCD on line 4b, and check box 2 on line 4c.2724 If you ever made nondeductible IRA contributions, Form 8606 figures line 4b.28

One thing isn’t settled. Pub 590-B says to check box 3 for this choice. The Form 1040 instructions say to check box 2 when a QCD is included. Neither one says whether box 2 is checked here too. Ask your preparer to confirm against the form for your year.327

For the rest, see how to report a QCD.

Worked example · tax year 2026A 2026 one-time QCD to a gift annuity
Assumptions
  • Single IRA owner, age 76, with a required minimum distribution of $40,000 for 2026.
  • She sends $40,000 from her IRA to a new gift annuity funded only by that gift. She has never made this choice before.
  • Assume the charity's rate for her age is 7%, with payments starting within one year.
  • She has taken nothing else out of the IRA this year.
  • Her other income gives her 2026 taxable income of $120,000 (single). Each payment is taxed at the federal bracket for that income (shown below).
  • Her taxable income is stated after all deductions, including any senior deduction her AGI still allows.
Step Calculation Result
One-time QCD to the gift annuity Within the 2026 one-time limit ($55,0001) $40,000
Required withdrawal covered $40,000 of the $40,000 $40,000
Taxable IRA income this year from that $40,000 Left out of income $0
Yearly payment $40,000 × 7% $2,800
Taxable part of each payment All ordinary income $2,800
Federal tax on each payment $2,800 × 24%29 $672

The gift counts toward her required minimum distribution (the least you must take out of a regular IRA each year once you reach a set age), like any QCD. Counts toward your RMD for the year.3031

So instead of $40,000 of income taxed this year, she reports $2,800 a year for life.

Should you fund a gift annuity from an IRA, with cash, or with stock?

It depends on whether you itemize, whether you must take IRA money out anyway, and what you own. Here’s how the three compare.

One-time QCD Cash Stock that grew
Deduction None. Left out of income before AGI, so it can't also be deducted.45 The gift part, if you itemize. If you don’t, by my reading the small 2026 cash deduction can cover part of it. Up to $1,000 ($2,000 joint) of cash to public charities, from 2026, if you don't itemize.32333435 The gift part, if you itemize
Taxable income now None from the gift, and it counts toward your required withdrawal. Counts toward your RMD for the year.3031 None Part of the gain, spread over your expected years, if the conditions below are met (details)
Tax on payments All ordinary income. Once in a lifetime, up to $55,000 in 2026, inside the yearly QCD limit.123 Part tax-free until your cost is paid back, then all ordinary income36 Part tax-free and part gain until your cost is paid back, then all ordinary income36
Size limit The one-time limit The charity’s minimum only The charity’s minimum only

The cash and stock columns rest on this wording.

A gift annuity is part sale and part gift.37 Your gift is what you give minus today’s value of the payments you’ll get.37 What you paid is split between the two parts only when you can deduct the gift part.38 A deduction you have to carry forward to a later year still counts.38 Say only you or your survivor can get the payments, and you can deduct the gift part.3738 Then any gain is reported a bit each year, out of the part of each payment that returns what you paid.37 That spreading also applies only if the annuity can’t be passed to anyone but the charity that issued it.37

The IRA route tends to matter most for people who don’t itemize. It also matters when your required withdrawal is at least as big as the gift. For them, the gift lowers the income taxed this year. A deduction usually wouldn’t help them much anyway. See gift annuities for that math.

Is the one-time QCD to a CRT practical?

Rarely. A trust has drafting, trustee and yearly filing costs. Those are mostly fixed.

A charitable remainder trust pays no income tax, so it can sell what you gave without tax at that moment.39 Business-type income inside it is taxed at 100%.39 That includes part of the income from an asset with a loan on it, like a mortgaged building.40 The trust can’t be undone, and it files Form 5227 every year.41

Only the IRA gift can go in. So you can’t add other money to reach a sensible size.

Can spouses pool two gifts into one trust? That’s not settled (see below). Even pooled, the trust would be small.

For many people, a gift annuity is the more practical choice here. Charities already issue them in small amounts at little or no cost to you. This is a planning view, not a rule.

Gift annuity, CRAT or CRUT: which vehicle?

The three allowed choices differ mainly in cost and in how the payment behaves.

Choice Payment Cost to you Fit for this gift
Gift annuity Fixed, 5% or more, starting within one year of funding; paid over one or two lives14 Usually none The common choice
CRAT CRAT: a fixed amount; CRUT: a set percent of each year's value.20212223; for life or a set term of up to 20 years42 Drafting, trustee, a return each year Rarely worth it at this size
CRUT Revalued each year; same choice of life or a set term42 Same as a CRAT Rarely worth it at this size

Before picking a charity, it’s worth getting a few things in writing. Will it set up a separate annuity funded only by your IRA gift? Will it send the acknowledgment your preparer needs? Some charities have a minimum gift. Some don’t offer this at all.

How does it compare with a regular QCD?

The big difference is income. A regular QCD sends it all to charity now. Nothing comes back, so there’s no tax later. The one-time version pays you back, and all of it is taxed.

Regular QCD One-time version
How often Every year Once in a lifetime. Once in a lifetime, up to $55,000 in 2026, inside the yearly QCD limit.123
2026 limit $111,00010 $55,0001, inside the yearly limit
Income back to you None Payments to you, all ordinary income
Counts toward your required withdrawal Yes Yes. Counts toward your RMD for the year.3031
Deduction No No. Left out of income before AGI, so it can't also be deducted.45

For someone who doesn’t need the payments, the regular gift is simpler. The one-time version is usually looked at by people who want to give. They also want to turn part of a required withdrawal into a small, steady payment back to them.

Unsettled questions

Here are the account rules for a regular QCD.

A QCD must come from an IRA — traditional, rollover or inherited.43 From an inherited IRA, you, the heir, must be 70½ or older.43 A Roth IRA generally can’t be used, because only money that would otherwise be taxed can be a QCD.44 A SEP or SIMPLE IRA can be used only in some years.43 It can’t if an employer puts money in for the plan year ending with or within your tax year.45 Money from your own pay put into a SIMPLE IRA counts as an employer contribution.45 A 401(k), 403(b) or other workplace plan can’t make a QCD.43

Common mistakes

  • Adding other money. Only the IRA gift can go in.
  • Naming a child to be paid. Only you and your spouse can be paid.
  • Forgetting the statement on your return.
  • Planning on a deduction too. The IRA money is left out of income, not deducted.
  • Spreading it over two years. The choice covers one tax year only.

Sources (45)

Show

  1. 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.

  2. 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.

  3. 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.

  4. 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.

  5. 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.

  6. 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.

  7. 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.

  8. 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.

  9. 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.

  10. 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.

  11. 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.

  12. 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.

  13. Because section 408(d)(8)(F)(ii)(III) defines a charitable gift annuity by reference to section 501(m)(5), which requires the annuity to be described in section 514(c)(5), the contract must also satisfy section 514(c)(5)'s conditions: the value of the annuity must be less than 90 percent of the value of the property transferred, the contract must not guarantee a minimum amount of payments or specify a maximum amount of payments, and the payment amount must not be adjusted by reference to income received from the transferred or other property.

    • 26 U.S.C. § 408 (LII), § 408(d)(8)(F)(ii)(III)a charitable gift annuity (as defined in section 501(m)(5)), but only if such annuity is funded exclusively by qualified charitable distributions and commences fixed payments of 5 percent or greater not later than 1 year from the date of funding. Checked 2026-10-11.
    • 26 U.S.C. § 501 (LII), § 501(m)(5)(B)the annuity is described in section 514(c)(5) (determined as if any amount paid in cash in connection with such issuance were property) Checked 2026-10-11.
    • 26 U.S.C. § 514 (LII), § 514(c)(5)(A)is the sole consideration (other than a mortgage to which paragraph (2)(B) applies) issued in exchange for property if, at the time of the exchange, the value of the annuity is less than 90 percent of the value of the property received in the exchange Checked 2026-10-11.
    • 26 U.S.C. § 514 (LII), § 514(c)(5)(C)is payable under a contract which— (i) does not guarantee a minimum amount of payments or specify a maximum amount of payments, and (ii) does not provide for any adjustment of the amount of the annuity payments by reference to the income received from the transferred property or any other property Checked 2026-10-11.

  14. A charitable gift annuity is defined by reference to section 514(c)(5), which requires the annuity to be payable over the life of one individual in being when it is issued, or over the lives of two such individuals.

    • 26 U.S.C. § 501 (LII), § 501(m)(5)(B)the annuity is described in section 514(c)(5) (determined as if any amount paid in cash in connection with such issuance were property) Checked 2026-10-11.
    • 26 U.S.C. § 514 (LII), § 514(c)(5)(B)is payable over the life of one individual in being at the time the annuity is issued, or over the lives of two individuals in being at such time Checked 2026-10-11.

  15. For the one-time split-interest QCD, § 408(d)(8)(F)(iii) replaces the entire-distribution deductibility test: for a CRAT or CRUT, a deduction for the entire value of the remainder interest must be allowable under § 170; for a charitable gift annuity, a deduction equal to the distribution reduced by the value of the annuity must be allowable (determined without regard to § 170(b)).

    • 26 U.S.C. § 408 (LII), § 408(d)(8)(F)(iii)(I)a deduction for the entire value of the remainder interest in the distribution Checked 2026-10-10.
    • 26 U.S.C. § 408 (LII), § 408(d)(8)(F)(iii)(II)reduced by the value of the annuity described in section 501(m)(5)(B) would be allowable under section 170 Checked 2026-10-10.

  16. The split-interest QCD deductibility test in section 408(d)(8)(F)(iii) is applied without regard to section 170(b), so the AGI percentage limits on charitable deductions are ignored when testing whether the deduction would be allowable.

    • 26 U.S.C. § 408 (LII), § 408(d)(8)(F)(iii)(I)In the case of a distribution to a charitable remainder annuity trust or a charitable remainder unitrust, a deduction for the entire value of the remainder interest in the distribution for the benefit of a specified charitable organization would be allowable under section 170 (determined without regard to subsection (b) thereof and this paragraph). Checked 2026-10-11.
    • 26 U.S.C. § 408 (LII), § 408(d)(8)(F)(iii)(II)In the case of a charitable gift annuity, a deduction in an amount equal to the amount of the distribution reduced by the value of the annuity described in section 501(m)(5)(B) would be allowable under section 170 (determined without regard to subsection (b) thereof and this paragraph). Checked 2026-10-11.

  17. The QCD must satisfy § 170 deductibility rules (other than percentage limits), including the contemporaneous written acknowledgment requirement for gifts of $250 or more. Any benefit received (e.g., a gala dinner) can disqualify the QCD because the entire distribution must be deductible.

    • 26 U.S.C. § 408 (LII), § 408(d)(8)(C)only if a deduction for the entire distribution would be allowable under section 170 Checked 2026-10-09.
    • IRS Notice 2007-7, A-39including the substantiation requirements under § 170(f)(8). Checked 2026-10-09.
    • 26 U.S.C. § 170 (LII), § 170(f)(8)(A)No deduction shall be allowed under subsection (a) for any contribution of $250 or more unless the taxpayer substantiates the contribution by a contemporaneous written acknowledgment Checked 2026-10-09.
    • IRS Publication 590-B (2025), Ch. 2, QCDsyou must have the same type of acknowledgment of your contribution that you would need to claim a deduction for a charitable contribution. Checked 2026-10-09.

  18. A donor need not reduce a contribution for a benefit of only token value when the charity correctly determines the value isn't substantial and tells the donor the payment is fully deductible. So such a token item does not stop a gift from being fully deductible.

    • IRS Publication 526 (2025), Contributions From Which You Benefit, Token itemsYou don’t have to reduce your contribution by the value of any benefit you receive if both of the following are true. You receive only a small item or other benefit of token value. The qualified organization correctly determines that the value of the item or benefit you received isn’t substantial and informs you that you can deduct your payment in full. Checked 2026-10-10.

  19. For the QCD test that the entire distribution be deductible under § 170, the § 170(b) percentage-of-AGI limits are disregarded, so a large QCD does not fail because a deduction of that size would exceed those limits.

    • 26 U.S.C. § 408 (LII), § 408(d)(8)(C)only if a deduction for the entire distribution would be allowable under section 170 (determined without regard to subsection (b) thereof and this paragraph). Checked 2026-10-10.

  20. A charitable remainder annuity trust (CRAT) pays a fixed sum each year of at least 5% and no more than 50% of the initial net fair market value of the trust property, at least annually, for life or lives of individuals living when the trust is created or for a term of no more than 20 years; the remainder goes to charity.

    • 26 U.S.C. § 664 (LII), § 664(d)(1)(A)a sum certain (which is not less than 5 percent nor more than 50 percent of the initial net fair market value of all property placed in trust) is to be paid, not less often than annually Checked 2026-10-09.
    • 26 U.S.C. § 664 (LII), § 664(d)(1)(A)for a term of years (not in excess of 20 years) or for the life or lives of such individual or individuals Checked 2026-10-09.
    • IRS: Charitable remainder trusts, Types of charitable remainder trustsA charitable remainder annuity trust (CRAT) pays a specific dollar amount each year. Checked 2026-10-09.

  21. A charitable remainder unitrust (CRUT) pays a fixed percentage, at least 5% and no more than 50%, of the trust's net fair market value revalued every year, so payments rise and fall with the trust's value.

    • 26 U.S.C. § 664 (LII), § 664(d)(2)(A)a fixed percentage (which is not less than 5 percent nor more than 50 percent) of the net fair market value of its assets, valued annually Checked 2026-10-09.
    • IRS: Charitable remainder trusts, Types of charitable remainder trustsThe payments generally must equal at least 5% and no more than 50% of the fair market value of the assets, valued annually. Checked 2026-10-09.

  22. A charitable remainder unitrust's payments, like a charitable remainder annuity trust's, may run only for a term of years not in excess of 20 years, or for the life or lives of individuals living when the trust is created.

    • 26 U.S.C. § 664 (LII), § 664(d)(2)(A)for a term of years (not in excess of 20 years) or for the life or lives of such individual or individuals Checked 2026-10-11.
    • 26 U.S.C. § 664 (LII), § 664(d)(2)(A)from which a fixed percentage (which is not less than 5 percent nor more than 50 percent) of the net fair market value of its assets, valued annually, is to be paid, not less often than annually, to one or more persons (at least one of which is not an organization described in section 170(c) and, in the case of individuals, only to an individual who is living at the time of the creation of the trust) for a term of years (not in excess of 20 years) or for the life or lives of such individual or individuals, Checked 2026-10-11.

  23. The value of the charitable remainder, determined under § 7520, must be at least 10% of the net fair market value of the property placed in the trust (for a CRUT, tested at each contribution).

    • 26 U.S.C. § 664 (LII), § 664(d)(1)(D)the value (determined under section 7520) of such remainder interest is at least 10 percent of the initial net fair market value of all property placed in the trust Checked 2026-10-09.
    • 26 U.S.C. § 664 (LII), § 664(d)(2)(D)with respect to each contribution of property to the trust, the value (determined under section 7520) of such remainder interest in such property is at least 10 percent Checked 2026-10-09.
    • IRS: Charitable remainder trusts, How a charitable remainder trust worksThe remainder donated to charity must be at least 10% of the initial net fair market value of all property placed in the trust Checked 2026-10-09.

  24. The custodian reports the QCD as an ordinary IRA distribution on Form 1099-R (code 7 for an owner, code 4 for an inherited IRA); there is no QCD-specific code on 2025 forms. For 2026, the new code Y may optionally be added. On Form 1040 (2025), the taxpayer enters the gross amount on line 4a, the non-QCD taxable portion on line 4b, and checks box 2 on line 4c. The older "write QCD next to line 4b" instruction has been replaced by the line 4c checkbox on the 2025 form.

  25. Under the current Form 1099-R instructions, a QCD may be reported with code Y paired with code 7 (non-inherited IRA), code 4 (inherited IRA), or code K (IRA assets without a readily available fair market value). Code Y is optional for tax year 2026.

    • Instructions for Forms 1099-R and 5498 (current online version, covers 2026), Box 7a, Qualified charitable distributions (QCDs)To report a QCD, use code Y with: Code 7 for a QCD from a non-inherited (normal distribution) IRA, Code 4 for a QCD from an inherited (death distribution) IRA, or Code K for a QCD reporting distributions of traditional IRA assets not having a readily available FMV that are either from non-inherited or inherited IRAs. Checked 2026-10-09.

  26. Under the 2026 Form 1099-R instructions, code Y must be used together with code 4, 7 or K; none of those is a Roth IRA distribution code (Roth IRA distributions use codes Q, T or J), so the instructions provide no code Y combination for a QCD from a Roth IRA. Code Y is optional for tax year 2026.

  27. On the 2025 Form 1040, if all or part of an IRA distribution is a QCD, the total goes on line 4a; if only part is a QCD, the non-QCD part goes on line 4b; box 2 on line 4c is checked. When the IRA has nondeductible basis and a distribution goes to charity, Form 8606 is filed (Pub 590-B Amy example), and the basis portion may be deductible on Schedule A subject to AGI limits.

    • Instructions for Form 1040 (2025), Lines 4a and 4b, Exception 3If all or part of the distribution is a qualified charitable distribution (QCD), enter the total distribution on line 4a. If the total amount distributed is a QCD, enter -0- on line 4b. If only part of the distribution is a QCD, enter the part that is not a QCD on line 4b unless Exception 2 applies to that part. Check box 2 on line 4c. Checked 2026-10-09.
    • IRS Publication 590-B (2025), Ch. 2, QCDs, Amy exampleBecause Amy made a distribution of nondeductible contributions from her IRA, she must file Form 8606 with her return. Checked 2026-10-09.
    • IRS Publication 590-B (2025), Ch. 2, QCDs, Amy examplethe $5,000 portion of the distribution attributable to the nondeductible contributions can be deducted as a charitable contribution, subject to adjusted gross income (AGI) limits. Checked 2026-10-09.

  28. On the 2025 Form 1040, Exception 2 for lines 4a/4b: if you received a distribution from a non-Roth IRA and made nondeductible contributions to any traditional IRA for 2025 or an earlier year, enter the total on line 4a and use Form 8606 to figure line 4b. Rollovers are Exception 1.

    • Instructions for Form 1040 (2025), Lines 4a and 4b, Exception 2Exception 2. If any of the following apply, enter the total distribution on line 4a and see Form 8606 and its instructions to figure the amount to enter on line 4b. You received a distribution from an IRA (other than a Roth IRA) and you made nondeductible contributions to any of your traditional IRAs for 2025 or an earlier year. Checked 2026-10-10.

  29. 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.

  30. 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.

  31. 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.

  32. Beginning in 2026, taxpayers who do not itemize may deduct up to $1,000 ($2,000 joint) of cash gifts to § 170(b)(1)(A) public charities, excluding gifts to supporting organizations and donor-advised funds.

    • 26 U.S.C. § 170 (LII), § 170(p)the deduction under this section shall be equal to the deduction, not in excess of 1,000 ($2,000 in the case of a joint return) Checked 2026-10-09.
    • 26 U.S.C. § 170 (LII), Amendment note, P.L. 119-21 § 70424(a)substituted “$1,000 ($2,000” for “$300 ($600” Checked 2026-10-09.
    • 26 U.S.C. § 170 (LII), Effective date note, P.L. 119-21 § 70424(b)shall apply to taxable years beginning after December 31, 2025 . Checked 2026-10-09.

  33. The non-itemizer deduction counts only cash contributions made during the year to § 170(b)(1)(A) organizations, not to § 509(a)(3) supporting organizations or for a new or existing donor-advised fund, and is computed without carryovers and without the 0.5% floor.

    • 26 U.S.C. § 170 (LII), § 170(p)which would be determined under this section if the only charitable contributions taken into account in determining such deduction were contributions made in cash during such taxable year (determined without regard to subsections (b)(1)(G)(ii), (b)(1)(I), and (d)(1)) Checked 2026-10-09.
    • 26 U.S.C. § 170 (LII), § 170(p)(1)-(2)to an organization described in section 509(a)(3), or (2) for the establishment of a new, or maintenance of an existing, donor advised fund Checked 2026-10-09.

  34. The § 170(p) deduction for non-itemizers (cash gifts, beginning 2026) does not apply to contributions for the establishment or maintenance of a donor-advised fund, or to § 509(a)(3) supporting organizations.

    • 26 U.S.C. § 170 (LII), § 170(p)(2)(2) for the establishment of a new, or maintenance of an existing, donor advised fund (as defined in section 4966(d)(2) ). Checked 2026-10-09.

  35. For a taxpayer who does not itemize, taxable income is AGI minus the standard deduction and other listed deductions, including the § 170(p) non-itemizer charitable deduction. That deduction therefore reduces taxable income but not AGI.

    • 26 U.S.C. § 63 (LII), § 63(b)the term “ taxable income ” means adjusted gross income , minus— (1) the standard deduction , (2) the deduction for personal exemptions provided in section 151, (3) any deduction provided in section 199A, (4) the deduction provided in section 170(p), Checked 2026-10-09.

  36. Under § 72(b), the part of each annuity payment excluded from income is the ratio of the investment in the contract to the expected return; the excluded amount cannot exceed the unrecovered investment, so once the investment is recovered later payments are fully includible.

    • 26 U.S.C. § 72 (LII), § 72(b)(1)which bears the same ratio to such amount as the investment in the contract (as of the annuity starting date) bears to the expected return under the contract (as of such date) Checked 2026-10-09.
    • 26 U.S.C. § 72 (LII), § 72(b)(2)shall not exceed the unrecovered investment in the contract immediately before the receipt of such amount Checked 2026-10-09.

  37. A charitable gift annuity is treated as a bargain sale: the gift portion (property value minus the present value of the annuity) is the charitable contribution; basis is allocated to the annuity portion, and for a nonassignable annuity to the donor (and survivor) the resulting gain can be reported ratably over the expected payout period; each payment is split under § 72 into a tax-free return of investment, capital gain, and ordinary annuity income.

    • 26 CFR § 1.1011-2 (LII), § 1.1011-2(a)(4)(ii)If in such case the annuity received in exchange for the property is nonassignable, or is assignable but only to the charitable organization to which the property is sold or exchanged Checked 2026-10-09.
    • 26 CFR § 1.1011-2 (LII), § 1.1011-2(c) Example 8(b)Thus, A makes a charitable contribution to the church of $40,245 ($100,000 −$59,755). Checked 2026-10-09.
    • 26 CFR § 1.1011-2 (LII), § 1.1011-2(c) Example 8(c)Such gain is to be reported by A ratably over the period of years measured by the expected return multiple under the contract , but only from that portion of the annual payments which is a return of his investment in the contract under section 72 of the Code . Checked 2026-10-09.
    • 26 CFR § 1.1011-2 (LII), § 1.1011-2(c) Example 8(d)Ordinary annuity income ($5,000−$3,985) $1,015.00 Checked 2026-10-09.

  38. In a bargain sale to charity, the donor's adjusted basis is apportioned between the sale portion and the gift portion only if a charitable contributions deduction is allowable under section 170 by reason of the sale or exchange; the apportioned basis is the share of total basis that the amount realized bears to the property's fair market value. If no deduction is allowable, no apportionment applies and the full basis offsets the amount realized, so less gain is recognized.

    • 26 CFR § 1.1011-2 (LII), § 1.1011-2(a)(1)If for the taxable year a charitable contributions deduction is allowable under section 170 by reason of a sale or exchange of property, the taxpayer's adjusted basis of such property for purposes of determining gain from such sale or exchange must be computed as provided in section 1011(b) and paragraph (b) Checked 2026-10-11.
    • 26 CFR § 1.1011-2 (LII), § 1.1011-2(b)the adjusted basis of the property which is sold or exchanged shall be that portion of the adjusted basis of the entire property which bears the same ratio to the adjusted basis as the amount realized bears to the fair market value of the entire property Checked 2026-10-11.
    • 26 CFR § 1.1011-2 (LII), § 1.1011-2(a)(2)If in the taxable year there is a sale or exchange of property which gives rise to a charitable contribution which is carried over under section 170(b)(1)(D)(ii) or section 170(d) to a subsequent taxable year or is postponed under section 170(a)(3) to a subsequent taxable year, section 1011(b) and paragraph (b) of this section must be applied for purposes of apportioning the adjusted basis of the property for the year of the sale or exchange, whether or not such contribution is allowable as a deduction under section 170 in such subsequent year. Checked 2026-10-11.

  39. A CRAT or CRUT is not subject to federal income tax, so it can sell contributed appreciated assets without paying tax at the trust level; unrelated business taxable income is hit with a 100% excise tax. The IRS describes deferral of income tax on sales of contributed assets as a reason to create a CRT; the trust takes the donor's carryover basis.

    • 26 U.S.C. § 664 (LII), § 664(c)(1)shall, for any taxable year, not be subject to any tax imposed by this subtitle. Checked 2026-10-09.
    • 26 U.S.C. § 664 (LII), § 664(c)(2)(A)there is hereby imposed on such trust or unitrust an excise tax equal to the amount of such unrelated business taxable income. Checked 2026-10-09.
    • IRS: Charitable remainder trusts, Reasons to create a charitable remainder trustAllow you to defer income taxes on the sale of assets transferred to the trust Checked 2026-10-09.
    • IRS: Charitable remainder trusts, How a charitable remainder trust worksThe trust's basis in the transferred assets is carryover basis, which is the same basis that it would be in the hands of the donor Checked 2026-10-09.

  40. Unrelated business taxable income includes income from debt-financed property — property held to produce income that is subject to acquisition indebtedness, such as a building with a mortgage on it. So for a charitable remainder trust, whose unrelated business taxable income is hit with a 100% excise tax under § 664(c)(2)(A), part of the income from a mortgaged asset is caught by that tax.

    • 26 U.S.C. § 512 (LII), § 512(b)(4)Notwithstanding paragraph (1), (2), (3), or (5), in the case of debt-financed property (as defined in section 514) there shall be included, as an item of gross income derived from an unrelated trade or business, the amount ascertained under section 514(a)(1), and there shall be allowed, as a deduction, the amount ascertained under section 514(a)(2). Checked 2026-10-11.
    • 26 U.S.C. § 514 (LII), § 514(b)(1)For purposes of this section, the term "debt-financed property" means any property which is held to produce income and with respect to which there is an acquisition indebtedness (as defined in subsection (c)) at any time during the taxable year Checked 2026-10-11.
    • 26 U.S.C. § 514 (LII), § 514(c)(1)For purposes of this section, the term "acquisition indebtedness" means, with respect to any debt-financed property, the unpaid amount of— Checked 2026-10-11.

  41. Charitable remainder trusts are irrevocable, and each CRT must file Form 5227 annually.

    • IRS: Charitable remainder trusts, How a charitable remainder trust worksCharitable remainder trusts are irrevocable. Assets that go in can't be taken back. Checked 2026-10-09.
    • IRS: Charitable remainder trusts, Tax filingsCharitable remainder trusts must annually file Form 5227, Split-Interest Trust Information Return . Checked 2026-10-09.

  42. A CRAT or CRUT used for the one-time split-interest QCD may pay its income interest for a term of years not in excess of 20 years, or for the life or lives of the individuals. Section 408(d)(8)(F)(ii) defines the split-interest entity by reference to section 664(d)(1) and 664(d)(2) and adds no requirement that the income interest run for life.

    • 26 U.S.C. § 664 (LII), § 664(d)(1)(A)for a term of years (not in excess of 20 years) or for the life or lives of such individual or individuals Checked 2026-10-11.
    • 26 U.S.C. § 664 (LII), § 664(d)(2)(A)a fixed percentage (which is not less than 5 percent nor more than 50 percent) of the net fair market value of its assets, valued annually, is to be paid, not less often than annually, to one or more persons (at least one of which is not an organization described in section 170(c) and, in the case of individuals, only to an individual who is living at the time of the creation of the trust) for a term of years (not in excess of 20 years) or for the life or lives of such individual or individuals Checked 2026-10-11.
    • 26 U.S.C. § 408 (LII), § 408(d)(8)(F)(ii)the term 'split-interest entity' means—(I) a charitable remainder annuity trust (as defined in section 664(d)(1)), but only if such trust is funded exclusively by qualified charitable distributions, (II) a charitable remainder unitrust (as defined in section 664(d)(2)), but only if such unitrust is funded exclusively by qualified charitable distributions Checked 2026-10-11.

  43. 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.

  44. 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.

  45. 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.