CGAs and QCDs

Hi all,

I understand that under the Secure Act 2.0 that someone age 70.5 and older may make a once-in-a-lifetime distribution directly from their IRA to a charitable gift annuity, and that in 2025 that maximum amount is $54,000.  My questions are: (1) may they split that amount among charities so that the total amount of CGAs equals $54,000? Or do they have to limit that $54,000 or less to only one charity? And (2) Is that $54,000 limit subtracted from the $108,000 QCD limit for 2025?

I have a client who wants to distribute $27,000 each to two charities from his IRA in the form of charitable gift annuities. He would also like to distribute QCDs to other charities from his IRA. I don’t believe the two kinds of gifts (CGAs and QCDs) will exceed the $108,000 QCD limit for 2025, but I would appreciate clarification how they coordinate with one another.

TIA for your help.



Multiple distributions can be made to CGAs in a single year up to a total of 54k and other QCDs can be made, but the total of split interest donations and other QCDs cannot exceed 108k.

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