At what age can my 401K QCD be also used towards my RMD? Turned 70, July 2024. In February 2025, I'll start making QCD distributions. When will these count for my RMD?

[turbineinfo]

Can someone clarify the age provision how and when QCD's can be treated as an RMD? The legal language is unclear to me.

[DaveF1006]

It depends. Required Minimum Distributions (RMDs) are minimum amounts that IRA and retirement plan account owners generally must withdraw annually starting with the year they reach age 73. Once this age has been attained, you may then treat a QCD as a RMD.

RMD FAQs

[VolvoGirl]

@turbineinfo   I've been taking QCD from my IRA.  I turned 71 in 2024.  I don't have to start taking RMD until 2026.  Then the QCD will count toward my RMD. 

Oh you can't take a QCD from a 401k, only from a IRA.   You may have a problem!  @dmertz 

RMD AGE

IRS Pub 590B  https://www.irs.gov/pub/irs-pdf/p590b.pdf   says…….
Your required beginning date. The date you must begin receiving RMDs is determined by the date you reach age 72. See the following to determine your applicable required beginning date.

Age 72 after December 31, 2022. If you reach age 72 after December 31, 2022, you must begin receiving required minimum distributions by April 1 of the year following the year you reach the age 73.

[dmertz]

QCDs can only be made from an IRA, not from a 401(k).  The taxable amount of a distribution from a 401(k) paid to a charity must be included in your AGI and can be claimed as a charitable contribution on Schedule A.

QCDs from an IRA can be made anytime after you reach age 70½ to the day (183 days after your 70th birthday).  Since you reached age 70 in July 2024, you will reach age 70½ sometime in January 2025.  QCDs will count toward your RMD if you have not already completed all of your RMDs for your IRAs by making other distributions.  However, in your case you are not yet subject to RMDs, so before 2027, the year that you reach age 73, any QCDs will just be distributions that are excludible from income.

To address you specific question, any normal distribution, including QCDs, from your traditional IRAs in a year that you are subject to RMDs is treated as an RMD until the total of your RMDs for IRAs has been completed.