RMD, 60-day rollover, and qualified charitable distribution (QCD)

[BonoConsilio]

IRA beneficiary already received her 2011 RMD 30 days ago. Now she would like to rollover a part of that RMD back to her IRA within the 60 day limit, and distribute that amount as a "qualified charitable distribution". I don't see a problem with this. For reporting purposes we would report:

1. original RMD distribution + additional qualified charitable distribution on 1099-R

2. part of RMD distribution in an amount equal to QCD on 5498 as rollover

She would still be meeting her RMD since the QCD and the rollover amount net zero.

Any problems with this?

[GMK]

Are you allowed to roll over an RMD if it's a 60 day rollover? or am I missing something?

[masteff]

Wow. Apparently your client is not the first to ask as the IRS specifically addresses this:

http://www.irs.gov/retirement/article/0,,id=234258,00.html

"IRA owners who have received their 2010 RMDs may not recontribute those distributions to an IRA to have them redistributed directly to a qualified charity as a QCD. However, if an IRA owner received a distribution in excess of his or her 2010 RMD, the owner can roll the excess to another or the same IRA within 60 days of receiving the distribution and then have the funds paid directly to the qualified charity as a QCD."