QCDs on form 5329

2 replies
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My QCDs were less than my RMD, so I'm using form 5329. Line 53 asks "Amount actually distributed to you", TT asks "Actual Amount Received". Should I include QCDs go here? Not rec'd by me, though naturally they count toward RMD.

macuser_22

Alumni - Champ

Are you saying that you did not take a distribution of at least your 2019 RMD amount? It is immaterial what the money was used for on the 5329 if you are requesting a wiavor of the penalty. Line 53 should be the total amount actually taken which would be box 1 on your 1099-R.

From 5329 instructions:
Quote:
"Waiver of tax. The IRS can waive part or all of this tax if you can show that any shortfall in the amount of distributions was due to reasonable error and you are taking reasonable steps to remedy the shortfall. If you believe you qualify for this relief, attach a statement of explanation and file Form 5329 as follows.
1. Complete lines 52 and 53 as instructed.
2. Enter “RC” and the amount of the shortfall you want waived in parentheses on the dotted line next to line 54. Subtract this amount from the total shortfall you figured without regard to the waiver, and enter the result on line 54.
3. Complete line 55 as instructed. You must pay any tax due that is reported on line 55.
The IRS will review the information you provide and decide whether to grant your request for a waiver. "

**Disclaimer: This post is for discussion purposes only and is NOT tax advice. The author takes no responsibility for the accuracy of any information in this post.**

riverbookAuthor

Level 2

Thanks to macuser_22. I appreciate your quick interpretation. Your understanding is right. I did not have enough QCDs to cover the 2019 RMD, and had nothing received directly by me, so there's a shortfall. Interesting your saying they want the "amount actually taken", even though they say "amount actually distributed to you." QCDs are common enough that I'd expect IRS knows there can be thousands of dollars difference between "distributed to you" and Box 1 "gross distribution" which certainly includes QCDs. As you point out, instruction package just says "Complete lines 52 and 53 as instructed" without resolving any ambiguity.