The RMD: Timing Is Everything

Does the timing of the first RMD for a 73-year-old matter?

A question from a client came up about a donor who was turning 73 in the calendar year using their Individual Retirement Account (IRA) to fund a charitable gift. Would a qualified charitable distribution (QCD) taken in the year the donor turns 73 but before the donor’s actual 73rd birthday count toward the Required Minimum Distribution (RMD) for that year? For instance, can a donor turning 73 on December 31st establish a QCD charitable gift annuity (CGA) on December 1st and still have it count toward their RMD?

When we examine the rules around RMDs in the first year, it is easy to see why a donor would be concerned and confused. The first RMD is required during the calendar year the traditional IRA owner turns 73. Despite that, the IRA owner has until April 1st of the following year to take the first RMD. That gives plenty of time to make their first withdrawal from their IRA. The RMDs after the 73rd birthday year must be taken by December 31st each year. This could mean that someone who turned 73 in 2025 and waited to make their first RMD until March of 2026 is still on the hook for a separate 2026 RMD before December 31, 2026. No wonder some donors find the first year RMD rules as clear as mud.

When the donor reaches age 73, the QCD can satisfy the RMD. Donors can use a QCD to fund an immediate CGA or charitable remainder trust (CRT). Donors can use multiple QCDs in the same calendar year to fund a CGA or CRT as long as the aggregate amount does not exceed the limit for the year, which is $55,000 in 2026. Donors can only fund a CGA or CRT with a QCD in one year and only one year. This is a once-in-a-lifetime opportunity to use the QCD to fund a CGA or CRT.

Back to our original question: If the owner is turning 73 in the calendar year, can a withdrawal before their actual birthday in the same year count toward an RMD? Yes. “[A]ny amount distributed in the year you become age 73 will be credited toward the amount that must be distributed by April 1 of the following year.” [IRS Publication 590-B (2025), Page 12, Miscellaneous Rules for Required Minimum Distributions)] This includes QCD withdrawals.

The RMD is the required amount to be withdrawn during the calendar year. As mentioned above, the first year RMD withdrawal period is extended through April 1st of the following year. Therefore, the first RMD can be withdrawn starting January 1st of the 73rd birthday year through April 1st of the following year. The RMD age increases to 75 in 2033 under the SECURE Act 2.0.