2014 QCDs extended

Congress has passed the extenders tax bill and it is on it’s way to the President for signature. He has indicated that it will be signed.

This year’s retroactive extension differs from the 2012 extension in two ways. First, the QCD and other provisions are only extended for 2014 instead of for two years, meaning we likely go through all this again a year from now. Second, the 2012 provision allowing RMD distributions made 12/1 or later in December to be rolled over by 1/31/2013 was omitted. Therefore, if you took your RMD before now, that distribution cannot be turned into a QCD. You have to complete your QCD between now and year end with no extension to January. The following from Michael Kitces explains the current extension further: https://www.kitces.com/blog/tax-extenders-reinstated-temporarily-but-able-act-of-2014-will-permanently-change-529-plan-landscape-for-special-needs-beneficiaries/



Does the QCD just have to be distributed by Dec 31 or does it have to be received by the charity by 12-31?

Thank you Alan!

Re QCD timing requirements – The distribution must be made by year end which will generate a 1099R. The check must also be mailed by year end in order to constitute constructive receipt by the charity. This is required by Sec 170 to justify a deduction and a valid QCD must meet the requirements of Sec 170 (along with other requirements) even though it will not be deducted on Sch A. Accordingly, you must allow time for the check to be issued by the IRA custodian, received by you in the mail, and in turn forwarded by you to the charity. If you hand deliver the check the contribution is made when you hand it over. You also need a receipt, but the receipt can be dated after the end of the CY.

Thanks!

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