Simple IRA and QCD

Submitted by Amanda Minter on Wed, 2020-06-10 21:08

Have a client that has a simple IRA and is 70 ½ and an active participant. Understand can’t do a QCD out of the simple IRA if active. My 3 questions are-

1) However can they make a QCD out of their unrelated IRA acct.?
2) Does funding the simple IRA limit their ability to do a QCD out of IRA?
3) Any issues with rolling over simple IRA assets to the IRA, in order to be able to do the QCD?



Submitted by Alan - IRA critic on Wed, 2020-06-10 21:39

  1. Yes, a QCD can be done from the non SIMPLE IRA account, and the RMD aggregation rules apply.
  2.  Not for the non SIMPLE IRA, just eliminates QCDs from the SIMPLE account.
  3.  No issues for a direct transfer other than the SIMPLE 2 year waiting period. However, a distribution would be applied to the SIMPLE IRA RMD and therefore would not be rollover eligible up the amount of the SIMPLE RMD. That would destroy the QCD benefit if the SIMPLE IRA was by far the largest account. Move the SIMPLE money to the other IRA by direct transfer to avoid these issues.

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