Can I make a QCD?
While many IRAs are eligible for QCDs—Traditional, Rollover, Inherited, SEP (inactive plans only), and SIMPLE (inactive plans only)* —there are requirements:
- You must be 70½ or older to be eligible to make a QCD.
- QCDs are limited to the amount that would otherwise be taxed as ordinary income. This excludes non-deductible contributions.
- The maximum annual amount that can qualify for a QCD is $100,000. This applies to the sum of QCDs made to one or more charities in a calendar year. (If, however, you file taxes jointly, your spouse can also make a QCD from his or her own IRA within the same tax year for up to $100,000.)
- For a QCD to count towards your current year’s MRD, the funds must come out of your IRA by your MRD deadline, generally December 31.
Any amount donated above your MRD does not count toward satisfying a future year's MRD.
The CARES Act has nothing to do with this. Since you are over age 70½, you can make up to $100,000 in Qualified Charitable Distributions (QCD) from your IRAs per year, excludible from income. Beyond the amount that you are eligible to treat as QCDs, distributions transferred or given to charity would be includible in income but you could claim a charitable deduction on Schedule A.
To be a QCD, the money must be transferred directly from the IRA to the charity. If you have any amount paid to you personally which you later give to charity, you cannot treat it as a QCD.
You can't take a deduction on Schedule A for any amounts treated as QCDs.