Completed RMD

Eg. A person has to do a RMD for $!0,000, and taxes $9,000 out, and gives $1000 in QCD to the church on Dec. 1 2020. The check has still not been cashed, has he met his RMD requirement even if the check was not cashed?



The RMD requirement has been met since the IRA custodian will record the 10,000 distribution on the 1099R, regardless of whether the check has been cashed. But the other question here is whether the person has been a valid QCD to be claimed on the tax return which reduces the taxable distribution to 9000. The IRS has not issued specific guidance on that question and therefore would likely treat the QCD as any other non QCD donation. For other donations to be deducted, one IRS Reg. indicates that the check only needs to be mailed (postmarked) by 12/31 to qualify. Therefore, while this question has not been firmly settled, therefore it is not known what the IRS would tend to decide in an audit situation. Since 12/1 provides plenty of time for the charity to cash the check, I would suggest that the individual advise the charity that they need to deposit the check promptly in the future.
The dynamics change for the rapidly increasing practice of IRA checkwriting for QCDs being pushed by IRA custodian for those who do several QCD donations. In these cases, the IRA custodian is not aware of the distribution until the check is returned to their bank for payment. Therefore, there is increased risk with check writing that the custodian does not know the QCD check was written and the 1099R would fall short of the RMD.  This might result in having to stop payment on the check, reporting the distribution as falling short of the RMD, and having to make up the late RMD in the following year, then filing a 5329 requesting the penalty waiver from the IRS. This all adds up to a hassle, so for those with check writing, it is even more important to get the checks delivered by Thanksgiving with the notation that they really need to be cashed within 10 days. That provides a couple weeks for unexpected delays at the charity, since year end is normally a very busy time for them.

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