My new client, who is age 67, has an inherited IRA from his father (who was age 95 when he passed away and was therefore taking RMDs before his death).  My client is then required to continue taking RMDs, which he has been, but for the 2021 tax year he made a QCD with the RMD that he was required to take and he IS NOT above age 70 1/2 years old. 

My initial thought was he is NOT allowed to make the QCD with that RMD because he is not above age 70 1/2.  Wouldn't that distribution be taxable to him and then he would take the charitable donation on Schedule A?

Thank you!