2010 QCD prior to December 17, 2010

I would appreciate some clarification. If a distribution was made in November 2010 from a rollover IRA directly to a qualified charity, the distribution meeting all of the requirements of a QCD, would this count as a QCD for 2010 under the new rules or can a 2010 QCD only be taken after December 17, 2010?
Thanks for any help on this matter.



The law change for QCD payments was retroactive to the beginning of 2010. There was a last minute re-enactment in 2008 also. I tried to encourage people to make direct transfers to charity in 2010 without the legislation – assuming it would pass – but I couldn’t convince anyone.
Horray for someone who make a QCD in November – they were ahead of the curve.



Thanks so much for the clarification.



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