2018 RMD to QCD

Submitted by Kim Gaston on Mon, 2017-12-18 19:08

Based on the Path Act of 2015, which made the QCD permanent, and the information from Checkpoint “2017 Tax Reform: Special Study on Individual Tax Changes in the ‘Tax Cuts and Jobs Act’”, it appears the Path Act of 2015 was not repealed regarding QCD.

Do you agree with my assumption?



Submitted by Alan - IRA critic on Tue, 2017-12-19 03:47

It appears that parts of the Path Act were superceded, but the entire Act was not repealed and QCDs remain in place.

Submitted by Marie Theilade on Thu, 2017-12-21 22:09

irs pUB 590 SAYS…You must be at least age 7012 when the distribution was made. My client turns 70 1/2 on December 27, 2018.  If we read this literally that would be tough to get it done in time.  We think that it is the year of 70 1/2 like the first time distribution.  How would the IRS know what day it is done?  My client read somewhere that is “You must be at least age 7012 when the distribution was made.”  is a unique rule.  Any thoughts?  Thanks in advance.  

Submitted by Alan - IRA critic on Thu, 2017-12-21 22:32

  • Yes, the IRA custodians know very well not to process a QCD until the IRA owner or beneficiary reaches 70.5 to the day, and the custodians know the date of birth. Like many of the IRA rules, the custodians operate on the front line. 
  • Note that the if the client has taken ANY IRA distributions this year, they would have been credited against the RMD and if the RMD has been completed a QCD now would not reduce taxes on the earlier RMDs. On the other hand, if no distributions have been taken, the client does not have to take any RMDs for 2017 prior to 4/1/2018, the required beginning date for RMDs. Client could forget the QCD for this year, and do it in January and it would apply to either the 2017 RMD if that RMD is not yet completed or the 2018 RMD if it has. Alot depends on timing and the amount of the planned QCDs vs. the size of the RMD in relation to the amount of the QCD.

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