RMD check from custodian when sent or deposited?

If a custodian sends a check to a charity, is the day the money withdrawn considered the date of withdrawal for tax purposes?

Example:

Custodian mails check to charity on October 15, 2022. The charity does not cash check till Feb 15, 2023. The check would be considered a 2022 RMD withdrawal.



This check would be reflected on the 2022 1099R, and therefore credited toward the 2022 RMD. While a gray area relating to when the charity received the check, if the custodian’s documentation of mailing is clear the IRS has not been challenging the receipt date for the charity. However, if the charity is going to take 4 months to cash the check (particularly a QCD check), perhaps a different charity should be considered in the future. Charity should also be providing a written acknowledgement of the donation.

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