QCD From an Inherited IRA in 2026: Heir Age 70½, $111,000 Limit, Counts Toward the Annual RMD

The three tests an inherited-IRA QCD has to pass

The existing guidance reads the same way for an owner and for an heir, with one change of subject. Publication 590-B (2025) puts it this way: “A QCD is generally a nontaxable distribution made directly by the trustee of your IRA (other than an ongoing SEP or SIMPLE IRA) to an organization eligible to receive tax-deductible contributions.” For an inherited account, “your IRA” is the account kept for you as beneficiary, and the age test moves to you.

Source: 26 U.S.C. 408(d)(8) (Cornell LII); IRS Notices 2007-7 and 2025-67; IRS Publication 590-B (2025).

A heir born on March 15, 1956 reaches 70½ on September 15, 2026 (our arithmetic), so a trustee payment on September 14 is too early and one on September 15 or later passes the age test. The statute counts from “the date” of attaining the age, not the year.

Why the 10-year rule and the annual RMD matter to the QCD

The 10-year rule is about when the account must be empty. The annual RMD is about how much must leave each year. A QCD is useful because it is one way to satisfy that annual amount without adding the money to income.

Does the heir owe an RMD this year? Publication 590-B (2025) says the 10-year rule applies to “a designated beneficiary who is not an eligible designated beneficiary” and that it means withdrawing the entire balance “by December 31 of the year containing the 10th anniversary of the owner's death”. Its example: an owner who died in 2025 means a full distribution by December 31, 2035. The regulation adds the annual part: where the owner died on or after the required beginning date, “the requirement to take an annual distribution … continues to apply for every distribution calendar year until the employee's interest is fully distributed” (26 CFR 1.401(a)(9)-5(d)(1)(i)). If the owner died before the required beginning date, Publication 590-B says no distribution is required for any year before the 10th year, and then there is no annual RMD for a QCD to count toward (it can still be paid; it just satisfies nothing).

What is the divisor? For an owner who died on or after the required beginning date with a designated beneficiary, the denominator is “the greater of” the beneficiary's and the owner's remaining life expectancy (26 CFR 1.401(a)(9)-5(d)(1)(ii)). The beneficiary's figure is the Single Life Table (Table I in Publication 590-B) at the heir's age in the first distribution year, reduced by one for each later year; it is not looked up again at the heir's current age.

Source: our arithmetic from IRS Publication 590-B (2025), Table I and the “reduce by one” method. Assumes the owner died in 2024 at 96, so the owner's own remaining life expectancy (3.7) is smaller and the heir's figure is the greater. The 10-year deadline in this case is December 31, 2034.

Which heirs are not under the 10-year rule? Eligible designated beneficiaries (the surviving spouse, a minor child of the owner, a disabled or chronically ill person, or anyone not more than 10 years younger than the owner) take life-expectancy payments instead, and a QCD works the same way for them once they are 70½ (Publication 590-B (2025)). A surviving spouse who treats the IRA as their own uses the spouse's own age and tables; see our inherited IRA 10-year rule page for who qualifies and what the penalty is.

What if the heir misses the RMD? The excise tax is 25% of the shortfall (Publication 590-B (2025)). Notice 2024-35 stated that “the IRS will not assert that an excise tax is due under” section 4974 for specified RMDs for 2024; the final regulations apply from 2025 (T.D. 10001). We found no later notice extending that relief in the documents we saved.

Worked example: a $500,000 to $1,500,000 inherited IRA (our arithmetic)

Facts, all assumed: the owner died in 2024 after the required beginning date; the heir, born in 1953, is the sole beneficiary and is aged 73 in 2026 (so 70½ since 2023); the 2026 divisor is 16.2 from the ladder above; balances are as of December 31, 2025.

Source: our arithmetic. The $111,000 cap does not bind in any of the three cases for a QCD equal to the RMD.

Three points the table does not show:

• Tax effect. A $25,000 QCD at an assumed 24% federal marginal rate keeps $6,000 of tax off the return (our arithmetic; the 24% is an assumption, not a figure from a source). There is no charitable deduction on top, because 408(d)(8)(E) denies it.
• Going above the RMD. A $40,000 QCD on the $500,000 case is $9,135.80 more than the $30,864.20 RMD. It still passes the exclusion (under the cap), but the excess gets no credit toward 2027 (26 CFR 1.401(a)(9)-5(a)(6)).
• One cap for the person. A $70,000 QCD from the inherited IRA plus a $50,000 QCD from the heir's own IRA is $120,000, which is $9,000 above the $111,000 cap (our arithmetic). A spouse on a joint return has a separate cap (Publication 590-B (2025)).

Which inherited accounts can make a QCD

Source: 26 U.S.C. 408(d)(8); IRS Notice 2007-7; IRS Publication 590-B (2025).

An inherited Roth IRA is the case where a QCD is rarely worth the effort. Publication 590-B (2025) says the minimum distribution rules for a Roth IRA apply as if the owner died before the required beginning date, so there is no annual RMD to satisfy, and a qualified distribution is not taxed anyway. A QCD would exclude nothing that was taxable and would give up the deduction an itemizer could take on a normal gift (our reading). A non-spouse cannot roll money into or out of an inherited IRA, only transfer it trustee to trustee to another IRA kept in the decedent's name for the heir (Publication 590-B (2025)); that matters if the current custodian will not pay charities directly.

How a QCD from an inherited IRA is reported

The custodian files Form 1099-R. The 2026 Instructions for Forms 1099-R and 5498 say: “To report a QCD, use code Y with” code 7 for a non-inherited IRA, “Code 4 for a QCD from an inherited (death distribution) IRA”, or code K for assets with no readily available fair market value. For tax year 2026, using code Y is optional, so a 1099-R may arrive with code 4 alone and the heir must claim the QCD on the return.

On the return, the 2025 Form 1040 instructions (the latest issued as of November 8, 2026) say: “If all or part of the distribution is a qualified charitable distribution (QCD), enter the total distribution on line 4a. If the total amount distributed is a QCD, enter -0- on line 4b.” If only part is a QCD, the part that is not goes on line 4b, and the instructions say “Check box 2 on line 4c.” The one-time election to a split-interest entity needs a statement and box 3 on line 4c with “SIE” written in (Publication 590-B (2025)).

Source: IRS Instructions for Forms 1099-R and 5498 (2026); IRS Instructions for Form 1040 (2025); IRS Publication 590-B (2025).

One-time gift to a split-interest entity

Section 408(d)(8)(F) lets a taxpayer make a single election, from an individual retirement account, to fund a charitable remainder annuity trust, a charitable remainder unitrust or a charitable gift annuity, up to $55,000 for 2026 (Notice 2025-67). The statute requires that no one hold an income interest except the individual for whom the account is kept and that person's spouse, and that the income interest is nonassignable. It counts inside the $111,000 cap. The election is for “an individual retirement account”, so check with the custodian whether an inherited account qualifies before relying on it (our reading). For the gift annuity mechanics see our charitable gift annuity page.

Dates

• December 31, 2026: the QCD must leave the IRA in 2026 for the 2026 return, and the 2026 RMD is due the same day. Custodians set earlier cut-offs for checks and paperwork; ask yours in writing (our reading).
• 2027: the 2027 QCD limit is not published as of November 8, 2026. The IRS page we read, last reviewed August 24, 2026, lists Notice 2025-67 as the latest annual notice and no 2027 notice.
• Heir's 70½ date: the day the age test is met, not the 70th birthday and not January 1 of the year.

Verdict: what to settle before December 31, 2026

1. Confirm your 70½ date and the account type. An inherited IRA (not a plan) kept for you.
2. Find the RMD for 2026. Balance at December 31, 2025, divided by the divisor, using the date of death and the required beginning date to decide whether an annual RMD exists.
3. Decide how much of the RMD to give. The excluded amount cannot exceed the $111,000 cap across all your IRAs.
4. Ask the custodian how it pays charities directly (check or wire from the trustee) and its cut-off date.
5. Keep the charity's acknowledgment. Publication 590-B says you need the same acknowledgment you would need for a deduction.

What a reader can do with this

• Compute your own line. Balance at last December 31, divided by the divisor from the ladder (first-year Table I figure for your age, less 1 for each later year). The CSV has Table I for ages 70 to 96.
• Ask the custodian three questions in writing: whether it pays charities directly from an inherited IRA, its December 2026 cut-off, and how it will code the 1099-R.
• Check the rest of the file. Read our QCD page for IRAs with illiquid holdings if the IRA holds a non-traded REIT or fund, and our inherited IRA page for the penalty and the year-10 deadline.
• Do not count on a carry-forward. Giving more than the RMD does not shrink next year's RMD.

The penalty for a missed annual RMD is 25% of the shortfall. This is analysis of public documents, not investment, legal or tax advice.

FAQ

Sources, read and saved on November 8, 2026: 26 U.S.C. 408 (Cornell LII); 26 CFR 1.401(a)(9)-4 and -5 and 1.408-8 (eCFR, current to November 1, 2026); T.D. 10001, Required Minimum Distributions, 89 FR 58886 (July 19, 2024); IRS Notices 2007-7, 2024-35 and 2025-67; IRS Publication 590-B (2025); Instructions for Forms 1099-R and 5498 (2026); Instructions for Form 1040 (2025); the IRS page on cost-of-living increases for dollar limitations on benefits and contributions (last reviewed August 24, 2026). Worked examples and the divisor ladder are our arithmetic; the script is saved with the page.