fb-rmd-0025
{
"person": "Traditional IRA owner, age 76, with a $30,000 required minimum distribution for the calendar year",
"facts": "During the year the owner directs the custodian to pay $30,000 from the IRA directly to a qualified public charity as a qualified charitable distribution under section 408(d)(8). The QCD is excluded from the owner's gross income. No other distributions are taken from any IRA that year.",
"question_context": "The owner's tax preparer worries that because the QCD was not includible in income, it cannot count toward the required minimum distribution."
}Does the $30,000 qualified charitable distribution satisfy this owner's required minimum distribution for the year? Answer with exactly one option id.
yes-counts-toward-rmd— Yes — all amounts distributed from the IRA count toward the RMD regardless of income inclusion, and a QCD is expressly taken into accountno-not-includible— No — only distributions includible in gross income count toward the RMDhalf-counts— Only the portion exceeding the standard deduction counts toward the RMD
yes-counts-toward-rmd
26 CFR 1.408-8(g)(1) states that all amounts distributed from an IRA are taken into account in determining whether section 401(a)(9) is satisfied regardless of income inclusion, and names a qualified charitable distribution under section 408(d)(8) as its own example. The $30,000 QCD therefore fully satisfies the $30,000 RMD; includibility in income is irrelevant to the 401(a)(9) test.
Selects yes-counts-toward-rmd, citing 1.408-8(g)(1).
“all amounts distributed from an IRA are taken into account in determining whether section 401(a)(9) is satisfied, regardless of whether the amount is includible in income. Thus, for example, a qualified charitable distribution made pursuant to section 408(d)(8) is taken into account in determining whether section 401(a)(9) is satisfied.”
Each quoted passage is exact-matched, after typographic normalization, against the corpus text fetched from the issuing authority (hashes in the corpus manifest). An item whose quote stops matching fails the build.
“all amounts distributed from an IRA are taken into account in determining whether section 401(a)(9) is satisfied, regardless of whether the amount is includible in income. Thus, for example, a qualified charitable distribution made pursuant to section 408(d)(8) is taken into account in determining whether section 401(a)(9) is satisfied.” — cfr-1-408-8
The answer key correctly identifies that a qualified charitable distribution (QCD) counts toward the required minimum distribution (RMD) for the year, regardless of the fact that it is not includible in gross income. The cited regulation explicitly uses a QCD under section 408(d)(8) as an example of a distribution that satisfies the section 401(a)(9) RMD requirements.
“all amounts distributed from an IRA are taken into account in determining whether section 401(a)(9) is satisfied, regardless of whether the amount is includible in income. Thus, for example, a qualified charitable distribution made pursuant to section 408(d)(8) is taken into account in determining whether section 401(a)(9) is satisfied.” — cfr-1-408-8
The cited regulation expressly provides that all IRA distributions count toward satisfying section 401(a)(9) regardless of income inclusion, and it specifically gives a QCD under section 408(d)(8) as an example of an amount taken into account. Therefore the $30,000 QCD satisfies the $30,000 RMD; the key is correct.
v1; no errata. Demonstrate a key error and the correction is published here, credited — challenge policy.