A qualified charitable distribution is the cleanest tax move available to an IRA owner over 70½. It moves money directly from the IRA to a 501(c)(3) public charity, never touches adjusted gross income, and requires no itemizing. For 2026, IRS Notice 2025-67 raised the cap to $111,000 per person — up from $108,000 — with $222,000 available to a married couple using both IRAs.
The IRS confirms the payoff plainly: "your qualified charitable distributions can satisfy all or part the amount of your required minimum distribution from your IRA."
The catch is not in the amount. It is in the calendar.
QCD Giving Peaks Exactly When It Helps Least
FreeWill's 2026 report, drawn from transaction data across 2,300-plus nonprofit partners, found that 56% of all QCD gifts raised on its platform in 2025 were completed in the final quarter of the year. The vehicle is growing fast — completed QCD gifts rose 56% in 2024 and 47% in 2025 — but the giving is bunched into October through December.
RMDs are not bunched the same way. Many retirees take theirs on an automatic monthly schedule, or in one lump in the spring. And that sequencing is the whole ballgame.
The First-Dollars-Out Rule
The tax code deems the first money leaving an IRA in an RMD year to be the RMD, until the RMD is fully satisfied. Andy Ives, an IRA analyst at Ed Slott and Company, states it directly: "The first dollars withdrawn from an IRA are deemed to count toward the RMD."
That deeming is one-way. A QCD done in December cannot reach back and untax a distribution already taken in March.
Consider a retiree with a $20,000 RMD who takes $10,000 in cash in April, then makes a $20,000 QCD in November. The QCD is valid and excluded from income. But the April $10,000 stays taxable forever. The RMD was already half satisfied by taxable dollars, and the November gift arrived too late to change what those dollars were.
Ives is explicit that QCDs carry no required sequence — they can be made any time in the year. The common "do it early" advice is not a rule. It is a hedge: "The only reason it is suggested to do QCDs early is to avoid ... mistakenly take a taxable distribution that cannot be retroactively offset with a future QCD."
The Deadline on the Other Side
Waiting has its own cost. RMDs are due December 31, and the excise tax on a shortfall is 25%, reduced to 10% if corrected within the correction window. Vanguard's research found 6.7% of its IRA investors missed an RMD in 2024, carrying roughly $1.7 billion in penalties on an average missed distribution of $11,600. Miss rates ran 56.8% for balances under $5,000 versus 2.5% above $1 million.
So the window is real on both ends: act before taxable dollars leave, but finish before December 31.
Practical Takeaways
- Check what has already come out this year. Pull your 2026 IRA distribution history before planning a Q4 gift. Dollars already distributed are locked in as RMD dollars.
- Pause automatic withdrawals first. Monthly or quarterly auto-distributions quietly consume the RMD all year. Suspend them before the QCD if you intend the gift to offset it.
- Build the QCD into next January. Giving early in 2027 preserves the full offset instead of racing the ordering rule in December.
- Mind the check-clearing trap. Ives flags IRA checkbooks specifically: a check written in late December may not clear until January, landing the QCD in the wrong tax year.
- Use the 70½-to-73 gap. QCD eligibility starts at 70½; RMDs begin at 73. Those years let you draw the IRA down tax-free before any distribution is mandatory.
- Insist on a direct transfer. The custodian must send funds to the charity. Money that passes through your hands is a taxable distribution, not a QCD.
A QCD's value is set the moment the first dollar leaves the account. By the time most of this giving happens, that moment has usually passed.
Sources: IRS Notice 2025-67 (Internal Revenue Bulletin 2025-49); IRS – Retirement Plans FAQs Regarding IRA Distributions and Withdrawals; IRS – Retirement Plan and IRA Required Minimum Distributions FAQs; Ed Slott and Company – QCD Timing (Andy Ives, CFP, AIF); FreeWill – 2026 Report: Giving from IRAs; PLANADVISER – Missing RMDs Cost Investors $1.7B in Penalties, per Vanguard