Direct IRA Transfers to Charity: Advise Clients Soon
Estate Planning and Philanthropy columnist Conrad Teitell writes: Now is the time for lawyers to tell their clients about direct IRA transfers from IRAs by individuals 70½ or older. IRA administrators generally can't make the direct transfers to the designated charities at the eleventh hour.
August 23, 2019 at 12:30 PM
6 minute read
Tax-free direct transfers from IRAs to charity are now especially taxwise because fewer clients can deduct their charitable gifts. The increased standard deduction reduces itemizers from over 30% to under 10% of taxpayers. And the $10,000 SALT (state and local taxes) limitation also results in few itemizers.
The tax benefit for charitable IRA gifts isn't a charitable deduction. Rather, otherwise taxable income—including Required Minimum Distributions (RMDs)—isn't taxable. Not being taxed on income is the equivalent of a charitable deduction. This makes an IRA charitable gift a WMD—a Weapon of Mass Deduction.
Now is the time for lawyers to tell their clients about direct IRA transfers from IRAs by individuals 70½ or older. IRA administrators generally can't make the direct transfers to the designated charities at the eleventh hour. And you'll want to tell clients about this smart way of giving before they make gifts to charity that won't be deductible.
Here are the rules for tax-free direct charitable/IRA distributions (tax-free charitable IRA rollovers). An individual age 70½ or older can make direct charitable gifts annually of up to $100,000 from an IRA, to public charities (other than donor advised funds and supporting organizations) and not have to report the IRA distributions as taxable income on his or her federal income tax return. Most private foundations are ineligible donees, but private-operating and passthrough (conduit) foundations are. There is no charitable deduction for the IRA distributions. However, not paying tax on otherwise taxable income is the equivalent of a charitable deduction. Tax-free distributions are for (direct) gifts only—not life-income gifts.
Traditional and Roth IRAs only. Distributions from traditional and Roth IRAs are the only ones that are tax free. Distributions from employer-sponsored retirement plans, including SIMPLE IRAs and simplified employee pensions (SEPs) aren't qualified charitable distributions; nor are distributions from Keoghs, 403(b) plans, 401(k) plans, profit sharing and other plans.
Doing a two-step to qualify: (1) Roll over a non-qualified pension plan into a qualified IRA. That's generally tax free (make sure that's so). (2) The qualified IRA then makes the distributions directly to the charity.
Pointer on donor-advised funds of community foundations. As noted, IRA distributions to those funds don't qualify. But IRA distributions to a community foundation's endowment and field-of-interest funds do qualify—as long as the donor has no advisory rights.
Distributions from a qualified IRA must be made directly by the IRA's administrator or trustee to a qualified charity. A payment to the donor who one honko-second later gives it to the charity doesn't qualify (a honko-second is the shortest measure of time—the time that elapses between a traffic signal turning green and the driver of the car behind honking his horn).
The entire distribution must be paid to the charity with no quid pro quo. The exclusion applies only if a charitable deduction for the entire distribution would have been allowable (determined without regard to the generally applicable percentage limitations). Thus if the donor receives (or is entitled to receive) a chicken dinner in connection with the transfer to the charity from the IRA, the exclusion isn't available for any part of the IRA distribution.
Example. $100,000 from a donor's IRA is distributed to the charity. He receives (or is entitled to receive) a benefit worth $25. The entire $100,000 will be taxable to the donor.
Substantiation required. The exclusion won't be available if the IRA distribution to the charity isn't properly substantiated. The charity must give the donor a timely written acknowledgment that it has received the IRA distribution and that no goods or services were given in connection with the IRA distribution.
Your client turns 70½ for purposes of qualifying for the IRA/charitable distribution when he is actually 70½. Play it safe. No distributions should be made to charity until at least one or two days after the donor reaches age 70½.
Caveat on year-end charitable distributions. A donor who by U.S. mail sends checks and securities to a charity this year that are received by the charity next year has made a charitable gift this year. Will a distribution mailed by the IRA trustee/custodian to the charity this year, but received by it next year, qualify for tax-free treatment? Unless clarified by the IRS, make sure that the charity actually receives the distribution this year.
Death-time distributions to charity from IRAs. The law allows tax-free distributions to charities at death for both outright and charitable remainder gifts. Income in respect of a decedent (IRD) isn't taxable to charities and CRTs. When a CRT beneficiary receives payments, he or she will be taxable on the IRD.
Pointer. Bequeath appreciated stock outright to family members who will get a stepped-up basis, and give the IRA and other IRD "items" to charity. The charity being tax exempt doesn't pay tax on the IRD.
Other IRD items include: salary and wages earned before death but paid after death; accounts receivable; unpaid royalties; commissions and partnership income earned before death but paid after death; unpaid royalties; payments under installment obligations paid after death; and interest or dividends earned before death but paid after death.
For death-time transfers from IRAs, there isn't a ceiling or limitation on the types of charitable donees. Thus distributions to all private foundations and public charities (including supporting organizations and donor advised funds) qualify. To avoid IRD concerns, the gift must be properly structured.
Reminder. It won't be a qualified charitable distribution if the IRA donor gets a chicken dinner or any other benefit. So don't fowl up an IRA distribution with a quid pro crow.
For donors not to be taxed on the IRA transfers, the donee-charity must properly and timely acknowledge the gift from the donor's IRA. And this is NOT the usual receipt for gifts of other contributions to charities.
Conrad Teitell is a principal at Cummings & Lockwood in Stamford, Conn.
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