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Charitable IRA Rollover

Planned Giving Options

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The purpose of this Charitable IRA Rollover section is to provide general gift, estate, and financial planning information. It is not intended as legal, accounting, or other professional advice. For assistance in planning charitable gifts with tax and other financial implications, the services of appropriate advisors should be obtained. Consult an attorney for advice if your plans require revision of a will or other document.

The Charitable IRA Rollover allows individuals age 70½ and older to make direct transfers of up to $100,000 per year (and up to $200,000 per year for married couples) from individual retirement accounts to qualified charities without having to count the transfers as income for federal tax purposes. This remains the case after the passage of both the SECURE Act, which was signed into law on December 20, 2019, and the CARES Act, signed into law on March 27, 2020. Since no tax is incurred on the withdrawal, gifts do not qualify for an income tax charitable deduction, but are eligible to be counted toward an individual’s minimum required distribution for years during which the required minimum distribution is in effect. 

Because the minimum age for a tax-free charitable gift from your IRA remains at 70½ but the required minimum distribution age is now 72 (for those individuals who did not already reach 70½ by 2019), it is possible that there will be a short period of time when a given donor’s IRA rollover gift would be  tax-free, but there would also be no minimum distribution requirement against which the rollover amount could be applied. This will also be the case for IRA rollover gifts made in 2020 by those who reached 70½ prior to December 31, 2019, as the required minimum distribution was suspended entirely for 2020 by the CARES Act.

Provisions of the Charitable IRA Rollover:

  • Distributions must be made directly to a qualified charity by the plan administrator of an IRA. Retirement assets in 401(k), 403(b), SEP, or SIMPLE plans do not qualify but may be rolled into a new or existing IRA and transferred to the charity.
  • Distributions may only be made to 501(c)(3) tax exempt organizations and cannot be made to donor advised funds, private foundations, or supporting organizations.
  • Distributions may not be used to fund life-income gifts such as charitable gift annuities, charitable remainder trusts, or pooled income funds. 

How to Donate

Please have your IRA trustee make the check representing your QCD payable to United States Holocaust Memorial Museum and have them send it to the following individual and address:

Ms. Ra'chel Edison
Lead Management Analyst
United States Holocaust Memorial Museum
100 Raoul Wallenberg Place, SW
Washington, DC  20024-2126

Contact the Museum’s Office of Planned Giving and Endowments at 202.488.6591 or ghellman@ushmm.org for instructions on how to complete a Charitable IRA Rollover.

Frequently Asked Questions

What is a Charitable IRA Rollover?
The Charitable IRA Rollover, or qualified charitable distribution (QCD), is a special provision allowing certain donors to exclude from taxable income—and count toward their required minimum distribution—certain transfers of Individual Retirement Account (IRA) assets that are made directly to public charities, including the United States Holocaust Memorial Museum. Since it was first made available in tax year 2006, many Museum donors age 70 1/2 or older have used this popular option to support the areas of their choice with tax-wise gifts ranging from $100 to $100,000 (and up to $200,000 for married couples).

How does this help me?
A Charitable IRA Rollover makes it easier to use IRA assets, during lifetime, to make charitable gifts.

Why will lifetime IRA gifts be easier?
Under current law, withdrawals from traditional IRAs and certain Roth IRAs are taxed as income, even if they are immediately directed to a charity. The donor receives an income tax deduction for his or her donation, but various other federal, and sometimes state, tax rules can prevent the deduction from fully offsetting this taxable income. As a result, many donors have chosen not to use IRA assets for lifetime gifts. The charitable IRA rollover eliminates this problem.

What gifts qualify for a Charitable IRA Rollover?
A gift that qualifies, technically termed a “qualified charitable distribution,” is:

  • Made by a donor age 70 1/2 or older.
  • Transferred from a traditional or Roth IRA directly to a permissible public charity, such as the United States Holocaust Memorial Museum. (If giving in this manner, please tell your broker or fund manager to name you as the donor on the transfer, and if your gift is intended for a particular area have the broker specify that as well.)
  • Completed during the applicable tax year.

Is there a limit on the amount that can be given?
Yes, there is a limit. An individual taxpayer's total Charitable IRA Rollover gifts cannot exceed $100,000 per tax year. Married couples can donate up to $200,000 per year.

What about the required minimum distribution?
If you have not already taken your required minimum distribution in a given year, a qualifying rollover gift can count toward satisfying this requirement.

Is an income tax deduction also available?
No. The gift would be excluded from income, so providing a deduction in addition to that exclusion would create an inappropriate double tax benefit.

Why are Roth IRAs included? Aren't withdrawals from a Roth IRA tax-free?
Withdrawals from a Roth IRA may be tax-free only if the account has been open for longer than five years or if certain other conditions apply. Otherwise, withdrawals are taxed as if they came from a traditional IRA. Therefore, certain Roth IRAs could benefit from a Charitable IRA Rollover.

Can other retirement plans, such as 401(k) and 403(b) accounts, be used?
No. However, it may be possible to make a tax-free transfer from such other accounts to an IRA, from which a charitable rollover can then be made.

Is my IRA charitable rollover gift eligible for an income tax charitable deduction?
No. Donors of qualified IRA gifts do not receive a federal income tax charitable deduction for the IRA gift, as they are not being taxed on the withdrawal.

Can a gift be made to any charity?
No. Excluded are:

  • Donor advised funds;
  • Supporting organizations; and
  • Private foundations.

Who can benefit from using the charitable IRA rollover to make a gift?

  • People with significant assets in an IRA.
  • People making gifts that are large, relative to their income. (Because a charitable rollover is not included in taxable income, it does not count against the usual percentage limitations on using income tax charitable deductions.)
  • People who do not itemize.

Can a rollover gift be used to pay my pledged support to the United States Holocaust Memorial Museum?
Yes. You can honor your pledge to the Museum with one or more qualified Charitable IRA Rollover transfers of up to $100,000 per person (and $200,000 for married couples), per calendar year. 

Can a rollover gift be used to fund a charitable remainder trust or charitable gift annuity?
No. The donor cannot receive any benefits in return for the gift. This includes life income plan payments.

Are there any benefits that a donor can receive?
The only permissible benefits from a Charitable IRA Rollover gift are those that would not reduce the tax deduction for which the donor would have otherwise qualified. At the Museum, a charitable IRA rollover gift is allowed to count toward naming opportunities and toward recognition society memberships such as the Wings of Memory Society and Leadership Circle.

What if a withdrawal does not meet the requirements of a Charitable IRA Rollover?
It simply will be included in taxable income as other IRA withdrawals currently are.

Is the Charitable IRA Rollover right for everyone?
While this is a great option, other types of gifts may provide donors with more tax benefits. As with any gift planning question, donors should consult their tax professionals for specific advice.

Can I still make a gift with an IRA beneficiary designation?
Absolutely. Whether or not you choose to make a Charitable IRA Rollover gift, you can still designate the United States Holocaust Memorial Museum as a beneficiary to receive IRA assets after your lifetime. The lifetime Charitable IRA Rollover is simply another option for donors who would like to see their philanthropy at work now.

If I made a Charitable IRA Rollover gift in other tax years, can I do this again for the current tax year?
Yes. The current law extends the Charitable IRA Rollover provision indefinitely—with no expiration date—allowing individuals to make qualifying gifts every tax year.

May I make a gift from my IRA if I have already taken my required minimum distribution (RMD)? 
Yes. You can exclude up to $100,000 (per IRA account owner and up to $200,000 for married couples) from gross income for qualified charitable donations. The donation counts toward your RMD but is not limited by your RMD.

Are there other tax advantages to gifting through a qualified IRA? 
Yes. Qualified IRA gifts are not subject to percentage of adjusted gross income (AGI) limitations for charitable contributions and are not reportable as income for federal income tax or for Social Security income purposes. The amounts withdrawn are not subject to state income taxes in most states. Donors who do not itemize deductions on their federal income tax returns may benefit from qualified IRA gifts for their exclusion from gross income. Amounts withdrawn from an IRA account are removed from the donor’s taxable estate. Talk to your tax advisor to see which benefits apply to your specific situation.

Are IRA distributions already taken by me eligible to gift as qualified charitable distributions? 
No. However, you can make gifts from IRA distributions that do not meet the requirements of a qualified charitable distribution. In such cases, the IRA distribution would be recognized as income for income tax purposes and typically would be eligible for a federal income tax charitable deduction.

More questions?
Contact the Museum’s Office of Planned Giving and Endowments at 202.488.6591 or ghellman@ushmm.org.