Retirement Giving
Start here

QCD Eligibility: Age 70½, Which IRAs Qualify, and Which Charities Can Receive a QCD

Josh Rendler, CFP®

Creator of Motion Retirement

Updated 2026-10-12 · Tax year 2026 · Figures checked October 10, 2026 · How this is checked

How old do you have to be to make a QCD?

You have to be at least 70½ on the day the money leaves your IRA. The date counts, not the year. A QCD (money sent straight from your IRA to a charity at 70½ or older, not taxed as income, up to a yearly limit) must come from an IRA, not a 401(k). It must go straight to an eligible charity, which mainly means a public charity (a charity like a church, school or hospital that gets the best tax treatment for gifts). Apart from one once-in-a-life option, you can't get anything back. Up to $111,000 per person can count in 2026.

  • You can start QCDs the day you turn 70½, six months after your 70th birthday. You don't have to wait for RMD (the least you must take out of a regular IRA each year once you reach a set age) age, which is 73 or 75. The IRS has proposed age 73 for people born in 1959, and that proposal isn't final.
  • QCDs can come from traditional, rollover and inherited IRAs (an IRA you get from someone who died). A SEP or SIMPLE IRA counts only if no employer contribution is made for the plan year. A 401(k) can't.
  • A church, school or hospital usually counts. A donor-advised fund (a giving account at a charity that holds your gifts until you pick where they go), a supporting organization (a charity set up to help one or more specific public charities) and most family foundations (a charity funded mostly by one person, family or company, not a public charity) don't.
  • Apart from a one-time gift (a one-time IRA gift to a charity trust or annuity that pays you back) to a charitable remainder trust or gift annuity (a deal where you give a charity money and it pays you a set amount for life), nothing comes back to you. That gift counts inside the yearly limit.
  • Deducted IRA contributions for the year you reach 70½ or later count against you. They can make some or all of a QCD that year or later taxable.
Jump to a question

You must be at least 70½ on the day the money leaves your IRA.1

Three more tests come with it: the account, the charity, and what you get back. Two rules can also shrink the tax-free amount. One is deducting IRA contributions for the year you reach 70½ or later. The other is after-tax money in your IRAs. That one only matters if a QCD is bigger than all your pre-tax IRA money put together.2 For a quick yes or no, try the QCD eligibility checker. For the big picture, see the QCD guide.

At what age can you make a QCD?

At 70½, counted to the exact day. A QCD made earlier that year, before your half-birthday, doesn’t count. It’s taxed like a normal withdrawal. If your half-birthday falls late in the year, waiting until January avoids cutting it close.

Is the QCD age the same as the RMD age?

No. QCDs start at 70½. RMDs start later.

Required minimum distributions start at 73 if you were born from 1951 through 1958.34 They start at 75 if you were born in 1960 or later.4 For people born in 1959, the law’s wording fits both ages, so the answer is unsettled.4

When Congress raised the RMD age, it left the QCD age at 70½.

QCDs RMDs
Starting age 70½ or older on the day the money leaves the IRA.1 73 or 75, depending on birth year.43
Required? No, it’s your choice Yes, every year once they start
Taxed? No, kept out of income Yes, as regular income
Accounts IRAs only IRAs and most workplace plans

People born in 1959 fall in a gap in the law. The IRS has proposed treating 73 as their RMD age, and that proposal isn’t final.5 The page on QCDs and RMDs explains it, plus the timing and year-end deadline rules.

So there are often a few years when you can make QCDs but owe no RMD yet. Some retirees who give anyway use those years. Each QCD keeps the gift out of income and shrinks the IRA, so later RMDs are smaller. Whether that fits depends on how much you give and what else you earn. A Roth conversion can shrink later RMDs too.

How do you find your exact 70½ date?

Six calendar months after your 70th birthday. That’s the first day a QCD can count.6

The QCD law doesn’t say how to count the date. The six-month count comes from the older RMD rules, and it’s the method people use for QCDs.6

Date of birth 70th birthday Date you reach 70½ First year a QCD can count
January 10, 1956 January 10, 2026 July 10, 2026 2026
June 30, 1956 June 30, 2026 December 30, 2026 2026 (only December 30 or 31)
August 20, 1956 August 20, 2026 February 20, 2027 2027

Someone born on June 30, 1956 has two days in 2026 to make a QCD. Your IRA firm may need longer than that.

Sometimes six months after your birthday lands on a day that doesn’t exist. A birthday on August 31 points to February 31. The same happens with the 31st of March, May, October or December. An August 30 birthday points to February 30, which no year has. August 29 points to February 29, which only a leap year has. The sources I checked don’t say which day counts then.6 Waiting until the 1st of the next month takes the question away.

Which accounts can make a QCD?

A QCD must come from an IRA — traditional, rollover or inherited.7 From an inherited IRA, you, the heir, must be 70½ or older.7 A Roth IRA generally can’t be used, because only money that would otherwise be taxed can be a QCD.8 A SEP or SIMPLE IRA can be used only in some years.7 It can’t if an employer puts money in for the plan year ending with or within your tax year.9 Money from your own pay put into a SIMPLE IRA counts as an employer contribution.9 A 401(k), 403(b) or other workplace plan can’t make a QCD.7

Only money that would otherwise be taxed can be a QCD.8 A qualified Roth withdrawal is already tax-free, so it can’t be one.108

A SEP or SIMPLE IRA is looked at year by year, so ask your employer what went in. Gifts from an inherited IRA have their own page.

Can you make a QCD from a 401(k)?

No. Only IRAs can make one.

A traditional or inherited IRA, or a SEP or SIMPLE IRA with no employer contribution that year.79

To give that money as a QCD, you’d first move it into a traditional IRA. By 70½ you’re past the age the law uses to hold back elective deferrals. In a profit-sharing or stock bonus plan, that age is 59½.11 So whether the money can come out while you still work there depends on your plan’s own rules, not on the law.

If you already owe an RMD from the plan that year, those first dollars can’t be moved to an IRA.12 Moving money also takes time. That matters if you want the QCD done the same year.

It works the other way too. Some people who still work past RMD age move IRA money into their work 401(k). Once it sits there, it’s out of reach for QCDs.

A traditional or inherited IRA, or a SEP or SIMPLE IRA with no employer contribution that year.79

For someone who gives every year, that’s a trade-off to weigh.

Which charities can receive a QCD?

A QCD must go to a public charity or one of a few special kinds of foundation.13 It can’t go to a donor-advised fund, a supporting organization, or most private foundations.13 The charity generally has to be organized in the United States or a U.S. possession.14 Being organized under U.S., state or D.C. law also counts.14

A US state, city or other government unit can count too, for gifts made only for public purposes.15

Recipient Can it get a QCD?
Public charity Yes
Church or congregation that’s a public charity Yes
A US state, city or other government unit, for public purposes only Yes
Donor-advised fund No. Ruled out by law
Supporting organization No. Ruled out by law
Private non-operating foundation, including most family foundations No, in most cases
Private operating foundation and a few other special foundation types Can qualify

Most family foundations are out. A private operating foundation, a pass-through foundation or a pooled-fund foundation can qualify.1316 If you give through a family foundation, check its type first.

Donor-advised funds trip people up most often. If you’re weighing the two, see DAF vs. QCD.

For CPAs and attorneysWhich organizations qualify, by code section

The recipient must be described in § 170(b)(1)(A), other than a § 509(a)(3) supporting organization or a § 4966(d)(2) donor-advised fund.13 Private foundations are included only if described in § 170(b)(1)(F) (operating foundations, pass-through foundations and pooled-fund foundations), through § 170(b)(1)(A)(vii).1316

Can you receive anything in return for a QCD?

No, apart from one once-in-a-lifetime option below.

The test below leans on two ideas. One is the yearly caps that tie a deduction to your AGI (your total income minus a few set subtractions, the number many tax rules start from). The other is the charity receipt (the written receipt a charity gives you for a large gift, needed before you file) a deduction needs.

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

If you get something of real value back, the QCD may not count. A gala dinner, event tickets and member perks are the usual examples. A mug or a tote bag is the usual token item that’s fine.

If the charity offers a ticket or a dinner, turning it down keeps things simple. Paying for it separately from your bank account is sometimes suggested. I haven’t found IRS text confirming that keeps the QCD whole, so it’s worth checking with your CPA.

The one-time exception

The rule below points to line 4c (the lines on your tax return where IRA withdrawals and QCDs are reported) of your tax return. How to report a QCD walks through that line. The 2026 form isn’t out yet, so check the line number then.

Once in your life, a QCD can fund a charitable gift annuity or a charitable remainder trust.20 The limit is $55,00020 in 2026, and it counts toward your yearly QCD limit.20 It was $50,000 in 2023 and is adjusted for inflation after that.21 Only QCDs can fund it, and only you, your spouse or both can get the payments.20 The right to those payments can’t be passed to anyone else.22 A gift annuity must start fixed payments of 5% or more within one year.20 The payments are taxed as ordinary income.20 On line 4c of Form 1040, you check box 3, enter “SIE,” and attach a statement.22

See QCDs to a trust or gift annuity. How to report a QCD covers the tax-return steps for any QCD.

Does the money have to go directly to the charity?

Yes.

The firm that holds your IRA must pay the charity directly.2324 Money paid to you first and then given away is not a QCD.23 A check your IRA firm issues to the charity still counts if you deliver it yourself.25 The IRS hasn’t said whether a check you write on an IRA checkbook counts.25

In my experience, most IRA firms only process QCDs as cash.

So if your IRA holds stocks or funds, the usual step is to sell inside the IRA and send cash.

No QCD rule says the gift must be cash.26 Tax-form instructions even have a code for a QCD of IRA assets with no easy market value.26

How to make a QCD covers payment methods and the steps.

Do IRA contributions after 70½ affect a QCD?

Yes, if you deducted them.

Deducted IRA contributions for years ending once you’re 70½ or older shrink the QCD you can leave out of income.27 It shrinks dollar for dollar, minus amounts that already shrank earlier QCDs.27

Only deducted contributions to a traditional IRA count. Roth contributions aren’t deducted, so they don’t count.27 IRS Publication 590-B has a worksheet for the running total. Your IRA firm doesn’t track it.

The cut part still went to charity, so you may be able to deduct it. A deduction lowers your taxable income (the part of your income that tax rates are actually charged on). Two rules decide how much that’s worth.

  • If you itemize: From 2026, itemized gifts count only above 0.5% of AGI.282930
  • If you don’t: Up to $1,000 ($2,000 joint) of cash to public charities, from 2026, if you don't itemize.31323334
Worked example · tax year 2026Working past 70½ and still contributing
Assumptions
  • A hypothetical retiree reached 70½ in 2024 and still has consulting income.
  • They deducted a $5,000 traditional IRA contribution for 2024 and another $5,000 for 2025. Both tax years ended after they reached 70½.
  • They make no IRA contribution for 2026 or 2027.
  • They made no QCDs before 2026.
  • They make a $25,000 QCD in 2026 and another $25,000 QCD in 2027.
  • This example only works out how much of each QCD stays out of income, not taxable income.
Step 2026 2027
Deducted contributions for the year you reached 70½ and later, total so far $10,000 $10,000
Less amounts already used to cut earlier QCDs $0 −$10,000
Cut available this year $10,000 $0
QCD made $25,000 $25,000
Less the cut −$10,000 $0
Tax-free as a QCD $15,000 $25,000
Taxable (still a gift to charity) $10,000 $0

In 2026 the charity got the full $25,000, but only $15,000 stayed out of income. The other $10,000 is taxed, and deductible only under the two rules above. By 2027 the cut is used up, so the whole QCD is tax-free again.

For someone who plans to make QCDs, a deducted IRA contribution after 70½ mostly moves tax from one year to another. The deduction now is paid back on a later QCD. Whether it’s still worth making depends on your tax rate in each year. It also depends on whether a Roth contribution is an option.

What if your IRA has after-tax money in it?

A QCD is left out of your income, so it never reaches your AGI.3536 Because of that, you can’t also deduct it as a charitable gift.35 If your IRA holds after-tax money, the QCD comes first from the money that would be taxed.35

So your after-tax money stays in the IRA. It still lowers the tax on later withdrawals. This only matters if a QCD is bigger than all the pre-tax money in all your IRAs added together.2 That usually happens only when your IRAs hold mostly after-tax money.

For CPAs and attorneysOrdering rule for basis

§ 408(d)(8)(D) overrides § 72: the distribution is treated as includible up to the amount that would be includible if all of the owner’s IRAs were distributed in that year and treated as one contract.2 Only the includible portion can be a QCD, under the flush language of (B).35

Common eligibility mistakes

  • Going by the year, not the date. A QCD before your half-birthday is taxed: 70½ or older on the day the money leaves the IRA.1
  • Waiting for RMD age. QCDs can start years earlier: 73 or 75, depending on birth year.43
  • Trying a QCD from a 401(k) or 403(b). A traditional or inherited IRA, or a SEP or SIMPLE IRA with no employer contribution that year.79
  • Sending one to a donor-advised fund or a supporting organization. A public charity, not a donor-advised fund, supporting organization or most private foundations.1314
  • Taking a benefit back. The whole gift has to count as a gift to charity.
  • Forgetting deducted contributions after 70½. They cut the tax-free amount, and your IRA firm doesn’t track them.

How much can count each year is capped.

$111,000 per IRA owner in 2026 ($108,000 in 2025).373839

See the QCD limit for how it works across IRAs and spouses.

Sources (39)

Show

  1. 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.

  2. For QCD purposes, § 408(d)(8)(D) overrides § 72: the distribution is treated as includible in gross income up to the amount that would be includible if all of the individual's IRAs were distributed and treated as one contract, so a QCD comes first from the taxable portion of all IRAs combined.

    • 26 U.S.C. § 408 (LII), § 408(d)(8)(D)the entire amount of the distribution shall be treated as includible in gross income without regard to subparagraph (A) to the extent that such amount does not exceed the aggregate amount which would have been so includible if all amounts in all individual retirement plans of the individual were distributed during such taxable year and all such plans were treated as 1 contract Checked 2026-10-10.

  3. The 73 applicable age applies to individuals who attain age 72 after December 31, 2022 (born in 1951 or later); 75 applies to those who attain 74 after 2032. So the 73/75 RMD start ages apply to people born in 1951 or later.

    • 26 U.S.C. § 401 (LII), § 401(a)(9)(C)(v)In the case of an individual who attains age 74 after December 31, 2032, the applicable age is 75. Checked 2026-10-10.
    • 26 U.S.C. § 401 (LII), § 401(a)(9)(C)(v)(I)the applicable age is 73 Checked 2026-10-10.

  4. The RMD applicable age is 73 for an individual who attains age 72 after 2022 and age 73 before 2033, and 75 for an individual who attains age 74 after 2032 (generally, people born in 1960 or later). Read literally, people born in 1959 fit both clauses; the statute's text does not resolve that overlap.

    • 26 U.S.C. § 401 (LII), § 401(a)(9)(C)(v)(I) In the case of an individual who attains age 72 after December 31, 2022 , and age 73 before January 1, 2033 , the applicable age is 73. (II) In the case of an individual who attains age 74 after December 31, 2032 , the applicable age is 75. Checked 2026-10-09.
    • Instructions for Form 1040 (2025), Lines 4a and 4b, More than one distributionYou must start receiving at least a minimum amount from your traditional IRA by April 1 of the year following the year you reach age 73. Checked 2026-10-09.

  5. The final RMD regulations leave the applicable age for an employee born in 1959 reserved. In proposed regulations published July 19, 2024 (REG-103529-23), Treasury and the IRS proposed that the applicable age for an employee born in 1959 is 73. The preamble explains that such an employee is described in both section 401(a)(9)(C)(v)(I) (age 73) and section 401(a)(9)(C)(v)(II) (age 75). The proposed rule had not been finalized as of the retrieval date; the current Code of Federal Regulations still shows paragraph (b)(2)(v) as reserved.

  6. Under the pre-2024 RMD regulation (Treas. Reg. § 1.401(a)(9)-2, A-3, as in effect through 2024-09-16), a person attains age 70½ on the date six calendar months after the 70th anniversary of birth; a June 30 birthday reaches 70½ on December 30. The QCD statute uses 'attained age 70½' without its own definition, so applying this RMD-regulation definition to QCDs is an inference. The 2024 final regulations no longer contain the A-3 definition.

    • 26 CFR 1.401(a)(9)-2 (eCFR point-in-time, 2024-01-01), Q-3/A-3An employee attains age 70 1/2 as of the date six calendar months after the 70th anniversary of the employee's birth. For example, if an employee's date of birth was June 30, 1933, the 70th anniversary of such employee's birth is June 30, 2003. Such employee attains age 70 1/2 on December 30, 2003. Checked 2026-10-09.

  7. 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.

  8. 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.

  9. 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.

  10. A qualified distribution from a Roth IRA is not includible in gross income (§ 408A(d)(1)).

    • 26 U.S.C. § 408A (LII), § 408A(d)(1)(A)Any qualified distribution from a Roth IRA shall not be includible in gross income. Checked 2026-10-09.

  11. A 401(k) plan may not distribute amounts attributable to an employee's elective deferrals earlier than certain events, including severance from employment, death, disability, attainment of age 59½ (profit-sharing or stock bonus plan), or hardship. So money in a 401(k) can't always be moved to an IRA while the employee still works there.

    • 26 U.S.C. § 401 (LII), § 401(k)(2)(B)(i)may not be distributable to participants or other beneficiaries earlier than— (I) severance from employment, death, or disability, (II) an event described in paragraph (10), (III) in the case of a profit-sharing or stock bonus plan, the attainment of age 59½, (IV) subject to the provisions of paragraph (14), upon hardship of the employee Checked 2026-10-10.

  12. QCDs count for the calendar year in which the trustee makes the distribution (exclusion is per taxable year). Under the RMD rules, the first amounts distributed in a year are treated as the RMD, so a taxable withdrawal taken earlier in the year satisfies the RMD and cannot be converted into a QCD by a later charitable distribution.

    • 26 U.S.C. § 408 (LII), § 408(d)(8)(A)made during any taxable year which does not exceed Checked 2026-10-09.
    • 26 CFR § 1.402(c)-2 (LII), § 1.402(c)-2(f)(2)(i) examplethe first $5,000 distributed will be treated as the required minimum distribution and will not be an eligible rollover distribution Checked 2026-10-09.

  13. The recipient must be a § 170(b)(1)(A) organization. Donor-advised funds and § 509(a)(3) supporting organizations are excluded by statute. Private non-operating foundations are excluded because they are not § 170(b)(1)(A) organizations (only foundations described in § 170(b)(1)(F) — operating, pass-through, and pooled-fund — are listed).

    • 26 U.S.C. § 408 (LII), § 408(d)(8)(B)(i)(other than any organization described in section 509(a)(3) or any fund or account described in section 4966(d)(2)) Checked 2026-10-09.
    • IRS Notice 2007-7, A-35other than supporting organizations described in § 509(a)(3) or donor advised funds that are described in § 4966(d)(2). Checked 2026-10-09.
    • 26 U.S.C. § 170 (LII), § 170(b)(1)(A)(vii)(vii) a private foundation described in subparagraph (F), Checked 2026-10-09.

  14. A 'charitable contribution' under § 170(c)(2) must go to an organization created or organized in the United States or a possession, or under US, state or DC law. Because a QCD must be one for which a deduction for the entire distribution would be allowable under § 170, a gift paid directly to a foreign organization generally cannot be a QCD.

    • 26 U.S.C. § 170 (LII), § 170(c)(2)(A)(A) created or organized in the United States or in any possession thereof, or under the law of the United States Checked 2026-10-10.
    • 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 2026-10-10.

  15. The § 170(b)(1)(A) class of organizations includes a governmental unit referred to in § 170(c)(1) — a State, a US possession, any political subdivision of either, the United States, or the District of Columbia — but only where the gift is made for exclusively public purposes. Because a QCD recipient must be a § 170(b)(1)(A) organization, a gift to such a government unit for exclusively public purposes is within the eligible class.

    • 26 U.S.C. § 170 (LII), § 170(b)(1)(A)(v)a governmental unit referred to in subsection (c)(1), Checked 2026-10-11.
    • 26 U.S.C. § 170 (LII), § 170(c)(1)A State, a possession of the United States, or any political subdivision of any of the foregoing, or the United States or the District of Columbia, but only if the contribution or gift is made for exclusively public purposes. Checked 2026-10-11.

  16. The private foundations referred to in section 170(b)(1)(A)(vii) are those described in section 170(b)(1)(F): a private operating foundation under section 4942(j)(3); a pass-through foundation that distributes 100 percent of the contributions it receives as qualifying distributions out of corpus by the 15th day of the third month after the close of its taxable year; and a pooled-fund foundation whose contributions are pooled in a common fund with the income and corpus required to be paid out to section 509(a)(1) organizations.

    • 26 U.S.C. § 170 (LII), § 170(b)(1)(F) introductory text and cl. (i)The private foundations referred to in subparagraph (A)(vii) and subsection (e)(1)(B) are— (i) a private operating foundation (as defined in section 4942(j)(3)), Checked 2026-10-11.
    • 26 U.S.C. § 170 (LII), § 170(b)(1)(F)(ii)any other private foundation (as defined in section 509(a)) which, not later than the 15th day of the third month after the close of the foundation's taxable year in which contributions are received, makes qualifying distributions (as defined in section 4942(g), without regard to paragraph (3) thereof), which are treated, after the application of section 4942(g)(3), as distributions out of corpus (in accordance with section 4942(h)) in an amount equal to 100 percent of such contributions Checked 2026-10-11.
    • 26 U.S.C. § 170 (LII), § 170(b)(1)(F)(iii)a private foundation all of the contributions to which are pooled in a common fund and which would be described in section 509(a)(3) but for the right of any substantial contributor 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. 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.

  21. 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.

  22. 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.

  23. 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.

  24. 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.

  25. 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.

  26. Neither the QCD statute nor fetched IRS guidance limits a QCD to cash; the statute covers 'any distribution' from an IRA that meets the conditions. The Form 1099-R instructions provide a code combination (Y with K) for a QCD of traditional IRA assets that do not have a readily available fair market value, so the IRS reporting rules contemplate non-cash QCDs.

    • 26 U.S.C. § 408 (LII), § 408(d)(8)(B)means any distribution from an individual retirement plan Checked 2026-10-10.
    • Instructions for Forms 1099-R and 5498 (2026), Box 7a, Qualified charitable distributions (QCDs)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 2026-10-10.

  27. The excludable QCD amount is reduced by the total deductible IRA contributions made for years ending on or after the owner reached 70½, less amounts already used to reduce prior years' QCDs (effective for tax years after 2019, SECURE Act). The reduced amount is taxable but may be deductible as a charitable contribution if itemizing.

    • 26 U.S.C. § 408 (LII), § 408(d)(8)(A), second sentencethe aggregate amount of deductions allowed to the taxpayer under section 219 for all taxable years ending on or after the date the taxpayer attains age 70½ Checked 2026-10-09.
    • IRS Publication 590-B (2025), Ch. 2, Offset of QCDs by amounts contributed after age 70½Beginning in tax years after December 31, 2019, the amount of QCDs that you can exclude from income is reduced by the excess of the aggregate amount of IRA contributions you deducted Checked 2026-10-09.

  28. Starting in 2026, itemized charitable deductions are allowed only to the extent total contributions exceed 0.5% of the taxpayer's contribution base (AGI). Disallowed amounts may carry forward only in limited circumstances (new § 170(d)(1)(C) — not reviewed).

    • 26 U.S.C. § 170 (LII), § 170(b)(1)(I)shall be allowed only to the extent that the aggregate of such contributions exceeds 0.5 percent of the taxpayer’s contribution base Checked 2026-10-09.
    • 26 U.S.C. § 170 (LII), Effective date note, P.L. 119-21 § 70425(c)shall apply to taxable years beginning after December 31, 2025 . Checked 2026-10-09.

  29. The 0.5% floor applies to charitable contributions 'otherwise allowable (without regard to this subparagraph)' as a deduction, i.e., read here as the amount allowable after the percentage-of-AGI limits. This ordering is the reviewer's reading of the statute text; no IRS worked example was located.

    • 26 U.S.C. § 170 (LII), § 170(b)(1)(I)Any charitable contribution otherwise allowable (without regard to this subparagraph) as a deduction under this section shall be allowed only to the extent that the aggregate of such contributions exceeds 0.5 percent of the taxpayer’s contribution base for the taxable year. Checked 2026-10-09.

  30. The 0.5% floor is applied first against 20%-limit capital gain gifts, then 30% capital gain gifts, then 30%-limit (other) gifts, then conservation gifts, then 50% gifts, and last against 60% cash gifts.

    • 26 U.S.C. § 170 (LII), § 170(b)(1)(I)(i)first, by taking into account charitable contributions to which subparagraph (D) applies to the extent thereof, Checked 2026-10-09.
    • 26 U.S.C. § 170 (LII), § 170(b)(1)(I)(vi)sixth, by taking into account charitable contributions to which subparagraph (G) applies to the extent thereof. Checked 2026-10-09.

  31. 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.

  32. 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.

  33. 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.

  34. 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.

  35. 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.

  36. 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.

  37. 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.

  38. 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.

  39. 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.