Qualified Charitable Distributions

Client has a solo 401(k) and an IRA annuity that is RMD age. I know you are have to satisfy RMDS from each account since one is an IRA and the other is a 401k. However, the plan is to rollover the solo 401K to an IRA after the client takes the RMD before the rollover. Once, the 401k funds are in the new IRA can the client do their qualified charitable distribution from the new IRA to satisfy for the IRA annuity? or is the funds in new IRA still consider a 401k until year 2022.

thanks
Larisa



Yes, this can be done in 2021. The new IRA would distribute the QCD and the QCD would count toward the IRA annuity RMD under the IRA RMD aggregation rules. 

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