Post Death QCD question

Bev died this year ( 2021 ) and took $22,000 of a $50,000 RMD and did a QCD with the $22,000. Her 40 year old heir will be responsible to take out the remainder $38,000 for 2021.

The question is can she do a QCD with the amount owed in 2021.

Side note – I know she needs to be 70 1/2 to do a QCD on her distribution. And given her age, she would not qualify to do the QCD until she turns 70 1/2. But what about the remainder for 2021 owed based on Bev’s ( now deceased ) RMD?



While the IRA beneficiary is responsible to complete her year of death RMD, the beneficiary cannot do a QCD due to the age requirement. Q&A 37 in Notice 2007-7 confirms that a beneficiary can do a QCD but the age requirement appears in both the question and the answer, therefore if there were any exception such as completing the decedent’s RMD, it would have been so stated.

Thank you.

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