Loading resource...
A recent call with a financial advisor in California is representative of a common question on Required Minimum Distributions.
Welcome to the Retirement Learning Center’s (RLC’s) Case of the Week. Our ERISA consultants regularly receive calls from financial advisors on a broad array of technical topics related to IRAs, qualified retirement plans and other types of retirement savings and income plans, including nonqualified plans, stock options, Social Security and Medicare. This is where we highlight the most relevant topics affecting your business.
“A client has already taken a distribution for his 2026 Required Minimum Distribution (RMD) from his IRA but wants to do a Qualified Charitable Distribution (QCD) from his IRA. Because he has already fully taken his RMD, can he now do a QCD and roll the previously taken RMD amount back into his IRA?”
Unfortunately, once an RMD amount is distributed for a year, an IRA owner cannot undo it to turn it into a QCD or roll it over into another IRA. Once an RMD is taken, it is irrevocably distributed and included in the participant’s income to the extent it is taxable (see IRC §408(d)(3)(E)). While the IRA owner still could transfer a QCD from his IRA and exclude the amount from income, it would not go toward satisfying his RMD, since he has already distributed the RMD.
As background, an IRA owner age 70½ or older can satisfy all or part of an RMD by making a QCD directly from an IRA to an eligible charity, subject to the $111,000 per-person limit for 2026. For information on what constitutes a QCD, please see our previous Case of the Week: QCDs & RMDs. The benefit of a QCD is that the distribution is excluded from income for the participant. In contrast, an IRA owner must include the taxable portion of an RMD in income.
It is important to note that there is no separate charitable deduction allowed for making a QCD; the benefit comes from not including a QCD in taxable income and, potentially, being able to use the QCD to satisfy an RMD if properly transferred to a qualifying charity.
That being said, if an IRA owner wants to make a charitable contribution (that is not a QCD), they could use part of the RMD funds received (or another amount), donate it to a charity, and claim a charitable deduction on their tax return to offset some of the tax impact of the distribution. Note: There have been some changes to charitable deductions for 2026 and beyond. Under Public Law 119-21, enacted July 4, 2025, individuals who do not itemize may deduct up to $1,000 in qualifying cash gifts ($2,000 for married couples filing jointly) to eligible charities, beginning in 2026. For individuals who itemize, charitable contributions are generally deductible only to the extent they exceed 0.5% of adjusted gross income (AGI). Individuals must be aware of these new charitable deduction rules if they are considering taking a deduction for a charitable gift.
Because the client has already satisfied his RMD by taking the full distribution earlier in the year, he is unable to undo that distribution and substitute a QCD in its place. He must include the taxable portion of the earlier distribution in his income for the year. However, next year, he could utilize the QCD rules to both satisfy his RMD and avoid taxation on the amount within the rules.