QCDs to Pooled Income Funds under SECURE Act 2.0

Are Pooled Income Funds also eligible under the SECURE Act 2.0 provision for up to a one-time $50,000 QCD to Charitable Remainder Trusts (CRTs) and Charitable Gift Annuities (CGAs)? If not, is there any reason why they got left out, since since they seem to be basically the same type of split-interest gift as the others?



Sec 307 of Secure 2.0 clearly defines and limits such QCDs to 3 distinct types of accounts created under specific sections of the tax code. All 3 of these accounts are individual contracts and must be funded exclusively by QCDs, and that is not possible with a pooled income fund.



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