January 2011

Qualified Charitable Distribution
Renewed for 2010 & 2011
   

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January/February 2011

The Qualified Charitable Distribution (QCD) provision introduced in 2009, allowing individuals age 70½ or over to exclude up to $100,000 from their gross income if paid directly from their individual retirement accounts (excluding SEP or SIMPLE IRAs) to a qualified charity, has been renewed. The excluded amount can be used to satisfy any Required Minimum Distributions (RMDs) that the individual must otherwise receive from their IRAs for 2010 and 2011.

2010 QCD  

The deadline for making a 2010 QCD has passed (January 31, 2011).  The election to treat a January 2011 QCD as having been made in 2010 would be made by including the QCD on the individual's 2010 income tax return. The IRA owner would report the full amount of the QCD (even if in excess of $100,000) made in January 2011 on line 15a; but would not include any amount on line 15b. Instead they should write "QCD" next to that line.

Disclaimer

To qualify as a QCD, the IRA trustee must make the distribution directly to the qualified charity. Any distributions, including any RMDs, which the IRA owner actually receives cannot qualify as QCDs. Likewise, any tax withholdings on behalf of the owner from an IRA distribution cannot qualify as QCDs.

Important Note

IRA owners who have received their 2010 RMDs may not recontribute those distributions to an IRA to have them redistributed directly to a qualified charity as a QCD. However, if an IRA owner received a distribution in excess of his or her 2010 RMD, the owner can roll the excess to another or the same IRA within 60 days of receiving the distribution and then have the funds paid directly to the qualified charity as a QCD.

Reporting

  • Distributions from an IRA in 2010, including any 2010 QCDs made on or before December 31, 2010, should be reported on a 2010 Form 1099-R.
  • Any distributions from an IRA in 2011, including any 2010 QCDs made on or before January 31, 2011, should be reported on the 2011 Form 1099-R.
  • To determine the amount of the 2011 RMD, subtract the full amount of the 2010 QCD made in January 2011 from the total of the individual's December 31, 2010 IRA account balance(s).
  • Important: If the IRA owner made the QCD from a traditional IRA in which the owner had basis and received a distribution from the IRA in 2010, they may have to file Form 8606, Nondeductible IRAs, with their 2010 tax return.
 

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