Can You Make a QCD From an Inherited IRA Under the SECURE Act?

You can make a Qualified Charitable Distribution from an inherited IRA, but only if you personally are at least 70½ years old on the day the distribution is made. The IRS confirmed this in Notice 2007-7, and eligibility turns on the beneficiary’s age, not the age of the original owner at death.¹ For 2026, each eligible person can exclude up to $111,000 in QCDs from gross income.²

The Age Test Applies to You, Not the Person Who Died

Notice 2007-7, Q&A 37 is direct: the QCD exclusion is available for a distribution from an inherited IRA if the beneficiary has reached age 70½ before the distribution is made.¹ What the original owner was doing with the account, and how old they were when they died, does not matter for this test. The inherited IRA keeps its character as an IRA for QCD purposes; no conversion or re-registration is needed beyond the normal inherited-IRA titling.

The 70½ threshold is fixed by statute and did not move when Congress pushed the required minimum distribution age to 73.³ So there is a gap: a beneficiary between 70½ and 73 can make QCDs even though they may not yet be required to take distributions from their own IRAs.

The practical consequence is that many non-spouse beneficiaries cannot use this tool at all. An adult child in their 40s or 50s who inherits a parent’s IRA has to take fully taxable distributions and can only claim a charitable deduction if they itemize, which is a much weaker result. The people who actually benefit from a QCD out of an inherited IRA tend to be older siblings, friends, or others close in age to the person who died.

Why This Matters Under the SECURE Act’s 10-Year Rule

The SECURE Act eliminated the stretch IRA for most non-spouse beneficiaries. If you inherited an IRA after December 31, 2019, and you are not an Eligible Designated Beneficiary, you generally must empty the entire account by the end of the tenth year following the year of the original owner’s death.⁴

That compresses years or even decades of deferred income tax into a single decade. A 72-year-old who inherits a $400,000 traditional IRA from a sibling has to move all of that pre-tax money into taxable income within ten years. QCDs let you route some of that forced income to charity without ever picking it up on your return. If you were going to donate anyway, using inherited-IRA dollars is almost always better than writing checks from your bank account.

A narrow group of Eligible Designated Beneficiaries can still use life-expectancy distributions instead of the 10-year rule: surviving spouses, minor children of the account owner, disabled or chronically ill individuals, and beneficiaries not more than ten years younger than the deceased owner. Everyone else lives under the 10-year clock.

Using a QCD to Satisfy an Inherited IRA RMD

A QCD counts toward a required minimum distribution dollar for dollar. Whether you owe an annual RMD from an inherited IRA depends on when the original owner died relative to their required beginning date, which is April 1 of the year after they turn 73.⁵

If the owner died before their required beginning date, non-EDB beneficiaries do not have to take annual distributions in years one through nine; they only need to empty the account by the end of year ten. Voluntary QCDs during those years are still excluded from income, they just aren’t offsetting a mandatory RMD.

If the owner died on or after their required beginning date, the beneficiary must take annual RMDs in years one through nine, with the balance out by the end of year ten. This is where the QCD does its heaviest work. An eligible beneficiary uses the QCD to satisfy the yearly RMD without adding a dollar to adjusted gross income.

Order of operations matters. The first dollars out of the IRA in any year are treated as satisfying that year’s RMD. If you take a cash withdrawal first and it covers the full RMD, a later QCD is just an additional distribution; it no longer offsets the RMD. Make the QCD before any personal withdrawals.

Keeping distributions out of AGI has effects beyond the income tax line. Higher AGI can raise Medicare Part B and Part D premiums through IRMAA, push more Social Security benefits into the taxable range, and phase out other tax breaks. A QCD that satisfies an inherited-IRA RMD avoids those downstream costs.

Which Accounts and Charities Qualify

QCDs can only come from traditional IRAs, including inherited traditional IRAs. Section 408 excludes SEP IRAs and SIMPLE IRAs that are still receiving employer contributions.³ If you’ve inherited a SEP or SIMPLE that no longer receives contributions, ask the custodian whether it can be treated as a traditional IRA for this purpose.

The distribution has to go directly from the custodian to the charity. If the money passes through your hands, it loses its QCD status.⁶

The recipient must be a charity that would qualify for a deductible contribution under Section 170(b)(1)(A), with important exclusions: donor-advised funds, supporting organizations, and most private foundations do not count.³ If you normally give through a donor-advised fund, redirect the QCD to the operating charity itself.

Two Adjustments That Can Change the Numbers

Deductible IRA Contributions Made After 70½

If you deducted IRA contributions to any of your own IRAs after reaching 70½, those contributions reduce the amount you can exclude through QCDs, dollar for dollar and on a running lifetime basis.³ Publication 590-B includes a QCD Adjustment Worksheet that walks through the math.⁷ This mostly hits beneficiaries who kept working past 70½ and deducted traditional IRA contributions during those years.

Basis in the Inherited Account Works in Your Favor

If the inherited IRA contains after-tax (nondeductible) contributions, QCDs get special treatment. Normal IRA withdrawals follow a pro-rata rule that splits each dollar between pre-tax and after-tax money. Under Section 408(d)(8)(D), a QCD is treated as coming out of the pre-tax portion first.³ The QCD absorbs the taxable dollars and preserves your after-tax basis for later personal withdrawals.

Reporting It on Your Tax Return

A QCD that isn’t reported correctly is just a taxable distribution followed by a charitable gift, which is a worse outcome if you don’t itemize.

The custodian issues Form 1099-R showing the gross distribution. For an inherited IRA, Box 7 typically carries Code 4 for a death distribution. Beginning with 2025 distributions, custodians can add Code Y to flag a QCD from an inherited account, though not all of them use it yet.⁸

On Form 1040, report the total distribution on line 4a. If the whole distribution was a valid QCD, enter zero on line 4b for the taxable amount, then check box 2 on line 4c to indicate a qualified charitable distribution.⁹ Older guidance told taxpayers to write “QCD” next to the line; the current form uses the checkbox instead.⁷

Keep the written acknowledgment from the charity and the confirmation from your custodian showing a direct transfer. If the IRS questions the treatment, the burden of proof is on you.

Time the Transfer to Avoid a Penalty

Missing an RMD from an inherited IRA triggers a 25% excise tax on the shortfall, dropping to 10% if you correct it within two years.⁵ The same penalty applies to any balance still sitting in the account after the end of the 10-year window.

Because QCDs must be direct transfers, custodians can take weeks to process them, especially in December. A QCD that reaches the charity after December 31 does not count for the earlier year. Start the paperwork in early November rather than late December, and confirm receipt before year-end. A processing delay can convert a tax-free QCD into a missed RMD with a 25% penalty attached.

1
IRS. Miscellaneous Pension Protection Act Changes Notice 2007-7
2
IRS. 2026 Amounts Relating to Retirement Plans and IRAs, as Adjusted
3
Office of the Law Revision Counsel. 26 U.S. Code 408 – Individual Retirement Accounts
4
Internal Revenue Service. Retirement Topics – Beneficiary
5
Internal Revenue Service. Retirement Plan and IRA Required Minimum Distributions FAQs
6
Internal Revenue Service. IRS Tax Tip: Seniors Can Reduce Their Tax Burden by Donating to Charity Through Their IRA
7
Internal Revenue Service. Publication 590-B (2025), Distributions from Individual Retirement Arrangements (IRAs)
8
IRS. 2025 Instructions for Forms 1099-R and 5498
9
IRS. 2025 Instructions for Form 1040