Client attains age 72 in 2021. She is still employed. In addition, she is self employed. Her employee contributes 100% to a Keogh plan for her. She also contributes to a Keogh plan established for her self employment income.

As of year end 2020 she also has a traditional IRA with a zero balance. She has been contributing, then rolling to a Roth. Her income is too high to contribute to the Roth directly.

She would like to contribute to the Traditional IRA in January, then roll over to her Roth. Once that transaction is complete she would like to move funds to the Traditional IRA in order to make Qualified Charitable Distributions during the year. Plan would be to continue this process annually.

We do not want to have the non taxability of the QCD impacted by the fact she is making a deductible contribution to her Keogh plan. We understand that if her contribution to her traditional IRA were deductible the benefit of the distribution would be reduced pursuant to the “anti abuse” provisions of the SECURE Act.

The question is whether funds may be moved from neither, one, or both of the retirement funds to the traditional IRA for these QCD purposes.

Thanks.