Repayment of RMD already taken to make a 2014 QCD?

Individual took his RMD in early December. Can he repay the RMD under the 60 day rule and now make a QCD for 2014 now that the legislation is in place?



He should have waited a couple more weeks. Unlike the 2012 retroactive extension, this year’s does not include the ability to essentially roll a December RMD distribution over to the charity and have it count as a 2012 RMD. For 2014, any QCD must be paid directly to the charity from the IRA custodian and be completed before the end of the year. Individual can still do a QCD, but it would only be in addition to the RMD already distributed in early December.



It is my understanding that the President has not signed yet!  Correct?



Don’t think he has signed yet, but indicated he will. Odds are extremely slim that he would not sign. Of course, if you are going to donate anyway, you can go ahead now and have the distribution issued as a QCD. That would avoid the year end rush and eliminate the chance that you would fail to complete the QCD by year end.



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