Does Vanguard’s Indirect Distribution Meet A QCD Requirement?
A TIRA owner requests a distribution check to a charity and plans to take it as a QCD (if extended to 2015) or else as an itemized deduction.
Vanguard will not mail the check directly to the charity but instead mails it to the IRA owner with check wording of “Pay To The Order Of: Charity, c/o IRA owner’s name and his address.” IRA owner in turn forwards the check to the charity’s address.
Q.: Does this still meet the “directly” to a qualified charity requirement for a QCD?
Permalink Submitted by Alan - IRA critic on Sun, 2015-11-15 19:41
Yes, it does. Of course, the QCD needs to be extended for 2015 retroactively at least to the date of the distribution to be reported as a QCD on Form 1040. This has always been done in the past as each QCD extension expired.
Permalink Submitted by tomd37 on Sun, 2015-11-15 20:20
In anticipation of 2015 QCDs being approved retroactively, as in some prior years, I made my 2015 QCDs in late September 2015. Vanguard specifically told me the checks would be made payable to the charity but must be mailed to me. Last year they told me that they were doing the same thing, but ended up inadvertently sending the checks directly to the charities. It caused some problems because a couple of the checks were in amount error and several of the charities had no knowledge of me and thus would have had problems acknowledging the donation. It turned out Vanguard stopped payment on all the checks, reissued them, and sent them to me. I then forwarded each check to the applicable charity indicating the donation was in memory of our son. I personally like the idea of Vanguard send the checks to me and allowing me to send them by cover letter. Tom D.