Client made a QCD with the RMD from an Inherited IRA

[timtax]

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!

[abctax55]

You are correct.

Even with an inherited IRA, the beneficiary must be 70.5 years of age to do the QCD.

[qbteachmt]

Regarding the SECURE Act changes:

"However, the age for making QCDs has not changed. As before, individuals older than 70 ½ are still allowed to make QCDs in amounts up to $100,000 per year."

From: https://ceritypartners.com/thought-leadership/what-the-secure-act-means-for-qualified-charitable-dis...

[abctax55]

From IRS Notice 2007-7

Q-37. Is the exclusion for qualified charitable distributions available for
distributions from an IRA maintained for a beneficiary if the beneficiary has attained age
70½ before the distribution is made?
A-37. Yes. The exclusion from gross income for qualified charitable distributions
is available for distributions from an IRA maintained for the benefit of a beneficiary after
the death of the IRA owner if the beneficiary has attained age 70½ before the
distribution is made.