Qualified Charitable Distributions

60yr old Business Owner realizing significant ($1M+) taxable income annually from 2 primary entities he operates.
Both Pass-Through entities. He has $25M+ estate currently.

What If –
During the remainder of his working career he establishes a qualified plan (either Defined Benefit or Cash Balance) for purposes of gaining current year tax deduction? The calcs for a 60yr old at his income level are well north of $300k. He may also realize the Trump QBID (Qualified Business Income Deduction) for Pass-Through entities of approx. $163,000 … If we can pare down the Pass-Through QBI to below $315k phaseout.

So, 10 years worth of contributions would be approx. $3M.

Obviously, he is subject to RMDs when he reaches Age @ 70.5.
What’s to keep him from executing qualified transfer from DB/CB Plan to IRA.
And subsequently make Qualified Charitable Distributions (QCD) from the
IRA so that ZERO income tax is paid annually during his lifetime… and when he goes on to Heaven…
he could have designated a DAF to be sole beneficiary of the IRA and sidestep ALL future income taxes.



Seems to be a workable plan. Although the QCD limit of 100k (no inflation adjustments apply as far as I know) will not cover his full RMD to start and the shortfall may increase.  

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