I 
116TH CONGRESS 
1ST SESSION H. R. 3832 
To amend the Internal Revenue Code of 1986 to expand tax-free distributions 
from individual retirement accounts to include rollovers for charitable 
life-income plans for charitable purposes. 
IN THE HOUSE OF REPRESENTATIVES 
JULY 18, 2019 
Mr. BEYER (for himself, Mr. KELLY of Pennsylvania, and Ms. SEWELL of 
Alabama) introduced the following bill; which was referred to the Com-
mittee on Ways and Means 
A BILL 
To amend the Internal Revenue Code of 1986 to expand 
tax-free distributions from individual retirement accounts 
to include rollovers for charitable life-income plans for 
charitable purposes. 
Be it enacted by the Senate and House of Representa-
tives of the United States of America in Congress assembled, 
SECTION 1. SHORT TITLE. 
This Act may be cited as the ‘‘Legacy IRA Act’’. 
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SEC. 2. TAX-FREE DISTRIBUTIONS FROM INDIVIDUAL RE-
TIREMENT 
ACCOUNTS 
FOR 
CHARITABLE 
PURPOSES. 
(a) IN GENERAL.—Paragraph (8) of section 408(d) 
of the Internal Revenue Code of 1986 is amended to read 
as follows: 
‘‘(8) DISTRIBUTIONS
FOR
CHARITABLE
PUR-
POSES.— 
‘‘(A) IN GENERAL.—No amount shall be 
includible in gross income by reason of a quali-
fied charitable distribution. 
‘‘(B) LIMITATIONS.— 
‘‘(i) IN
GENERAL.—The aggregate 
amount excluded from gross income under 
subparagraph (A) with respect to all quali-
fied charitable distributions for a taxable 
year shall not exceed $400,000. 
‘‘(ii) 
SPLIT-INTEREST
ENTITIES.— 
The aggregate amount excluded from gross 
income under subparagraph (A) for a tax-
able year with respect to distributions de-
scribed in subparagraph (C)(i)(I) shall not 
exceed $100,000. 
‘‘(C) QUALIFIED
CHARITABLE
DISTRIBU-
TION.—For purposes of this paragraph, the 
term ‘qualified charitable distribution’ means 
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any distribution from an individual retirement 
account— 
‘‘(i) which is made directly by the 
trustee— 
‘‘(I) to a specified charitable or-
ganization, or 
‘‘(II) to a split-interest entity, 
and 
‘‘(ii) which is made on or after the 
date on which the individual for whose 
benefit the account is maintained has at-
tained— 
‘‘(I) in the case of any distribu-
tion described in clause (i)(I), age 
701⁄2, and 
‘‘(II) in the case of any distribu-
tion described in clause (i)(II), age 
65. 
‘‘(D) SPECIAL RULES RELATING TO DIS-
TRIBUTIONS.—For purposes of this para-
graph— 
‘‘(i) DISTRIBUTION MUST BE OTHER-
WISE
INCLUDIBLE.—A distribution from 
an individual retirement account shall be 
treated as a qualified charitable distribu-
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tion only to the extent that the distribution 
would be includible in gross income with-
out regard to subparagraph (A). 
‘‘(ii) LIMITATION ON INCOME INTER-
ESTS.—A distribution from an individual 
retirement account to a split-interest entity 
shall be treated as a qualified charitable 
distribution only if— 
‘‘(I) no person holds an income 
interest in the split-interest entity 
other than the individual for whose 
benefit such account is maintained, 
the spouse of such individual, or both, 
and 
‘‘(II) the income interest in the 
split-interest entity is nonassignable. 
‘‘(iii) CONTRIBUTIONS MUST BE OTH-
ERWISE
DEDUCTIBLE.—A 
distribution 
from an individual retirement account to a 
specified charitable organization shall be 
treated as a qualified charitable distribu-
tion only if— 
‘‘(I) in the case of a distribution 
to a charitable remainder annuity 
trust or a charitable remainder uni-
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‘‘(F) SPLIT-INTEREST ENTITY.—For pur-
poses of this paragraph, the term ‘split-interest 
entity’ means— 
‘‘(i) a charitable remainder annuity 
trust (as defined in section 664(d)(1)), but 
only if such trust is funded exclusively by 
qualified charitable distributions, 
‘‘(ii) a charitable remainder unitrust 
(as defined in section 664(d)(2)), but only 
if such unitrust is funded exclusively by 
qualified charitable distributions, or 
‘‘(iii) a charitable gift annuity (as de-
fined in section 501(m)(5)), but only if 
such annuity is funded exclusively by quali-
fied charitable distributions and com-
mences fixed payments of 5 percent or 
greater not later than 1 year from the date 
of funding. 
‘‘(G) SPECIAL RULES.— 
‘‘(i) 
CHARITABLE
REMAINDER 
TRUSTS.—Notwithstanding section 664(b), 
distributions made from a trust described 
in clause (i) or (ii) of subparagraph (F) 
shall be treated as ordinary income in the 
hands of the beneficiary to whom the an-
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nuity described in section 664(d)(1)(A) or 
the 
payment 
described 
in 
section 
664(d)(2)(A) is paid. 
‘‘(ii) CHARITABLE GIFT ANNUITIES.— 
Qualified charitable distributions made to 
fund a charitable gift annuity shall not be 
treated as an investment in the contract 
for purposes of section 72(c). 
‘‘(iii) APPLICATION OF SECTION 72.— 
Notwithstanding section 72, in determining 
the extent to which a distribution is a 
qualified charitable distribution, the entire 
amount of the distribution shall be treated 
as includible in gross income to the extent 
that such amount does not exceed the ag-
gregate amount which would have been so 
includible if all amounts in all individual 
retirement plans of the individual were dis-
tributed during the taxable year and all 
such plans were treated as 1 contract for 
purposes of determining under section 72 
the aggregate amount which would have 
been so includible. Proper adjustments 
shall be made in applying section 72 to 
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other distributions in such taxable year 
and subsequent taxable years. 
‘‘(iv) 
DETERMINING
DEDUCTION 
UNDER SECTION 170.—Qualified charitable 
distributions shall not be taken into ac-
count in determining the deduction under 
section 170. 
‘‘(v) REQUIRED
MINIMUM
DISTRIBU-
TIONS.—The entire amount of a qualified 
charitable distribution shall be taken into 
account for purposes of section 401(a)(9). 
‘‘(H) TERMINATION
WITH
RESPECT
TO 
SPLIT-INTEREST ENTITIES.—Subparagraph (A) 
shall not apply to a distribution to a split-inter-
est entity in taxable years beginning after the 
date which is 4 years after the date of the en-
actment of the Legacy IRA Act.’’. 
(b) EFFECTIVE DATE.—The amendment made by 
this section shall apply to distributions made in taxable 
years ending after the date of the enactment of this Act. 
Æ 
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