Retirement News 

 for Employers
 

Tax Information for Sponsors of Retirement Plans 

Internal Revenue Service Tax Exempt and Government Entities 

Qualified Charitable Distributions for 2010 and 2011 

The qualified charitable distribution provisions were renewed for 2010 and 2011, allowing individuals age 

701⁄2 or over to exclude from gross income up to $100,000 that is paid directly from their individual retirement

accounts (excluding SEP or SIMPLE IRAs) to a qualified charity. The excluded amount can be used to satisfy 

any required minimum distributions that the individual must otherwise receive from their IRAs for 2010 and 

2011. The deadline for making a 2010 QCD is January 31, 2011. The election to treat a January 2011 QCD as 

having been made in 2010 is made by including the QCD on the individual’s 2010 income tax return. 

To qualify as a QCD, the IRA trustee must make the distribution directly to the qualified charity. Any 

distributions, including any RMDs, which the IRA owner actually receives cannot qualify as QCDs. Likewise, 

any tax withholdings on behalf of the owner from an IRA distribution cannot qualify as QCDs. 

IRA owners who have received their 2010 RMDs may not recontribute those distributions to an IRA to have 

them redistributed directly to a qualified charity as a QCD. However, if an IRA owner received a distribution 

in excess of his or her 2010 RMD, the owner can roll the excess to another or the same IRA within 60 days of 

receiving the distribution and then have the funds paid directly to the qualified charity as a QCD. 

Form 1099-R Reporting 

Any distributions from an IRA in 2010, including any 2010 QCDs made on or before December 31, 2010, 

should be reported on a 2010 Form 1099-R, Distributions From Pensions, Annuities, Retirement or ProfitSharing Plans, IRAs, Insurance Contracts, etc. 

Any distributions from an IRA in 2011, including any 2010 QCDs made on or before January 31, 2011, should 

be reported on the 2011 Form 1099-R. 

2010 QCDs Made in January 2011 

Satisfying 2010 RMD 

A 2010 QCD made by January 31, 2011, will satisfy a 2010 RMD for the IRA owner. For example, if Joe had 

not taken his 2010 RMD by December 31, 2010, a QCD he makes no later than January 31, 2011, that he elects 

to treat as being made in 2010, will count towards satisfying Joe’s 2010 RMD. However, if Joe had already 

taken his 2010 RMD, he will need to take another RMD for 2011 (the 2010 QCD made in January 2011 does 

not count towards satisfying Joe’s 2011 RMD). 
Retirement News for Employers 

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Calculating 2011 RMD 

To determine the amount of the 2011 RMD, subtract the full amount of the 2010 QCD made in January 2011 

from the total of the individual’s December 31, 2010 IRA account balance(s). 

Reporting on the 2010 tax return 

Instructions in Publication 590, Individual Retirement Arrangements (IRAs), will provide that IRA owners must 

report a 2010 QCD made in January 2011 on their 2010 Form 1040 as follows: 

1. report the full amount of the QCD (even if in excess of $100,000) made in January 2011 on line 15a; and 

2. do not include any amount on line 15b, but write “QCD” next to line 15b. 

IRA owners may have to file Form 8606, Nondeductible IRAs, with their 2010 tax return if the IRA owner made 

the QCD from a traditional IRA in which the owner had basis and received a distribution from the IRA in 2010, 

other than the January 2011 QCD. If a Form 8606 needs to be filed for 2010, the value of all IRAs reported on 

Form 8606, line 6, must be reduced by any 2010 QCD made by January 31, 2011 

New Requirements for Tax Return Preparers 

FAQs updated for Notice 2011-6. The notice provides guidance about the implementation of new Treasury regulations 

governing tax return preparers on the requirement to obtain a preparer tax identification number; forms that qualify as tax 

returns or claims for refund; and interim rules that apply to certain PTIN holders during the implementation phase