At present, Qualified Charitable Distributions (QCDs) cannot be made to donor-advised funds (DAFs).
If you are interested in the technical explanation, Internal Revenue Code (IRC) Section 408(d)(8)(B)(i) defines a qualified charitable distribution (QCD) as a distribution from a retirement plan “which is made directly by the trustee to an organization described in section 170(b)(1)(A) (other than any organization described in section 509(a)(3) or any fund or account described in section 4966(d)(2)).” The latter is a specific reference to a donor-advised fund, thus prohibiting a tax-free qualified charitable distribution (QCD) to a donor-advised fund (DAF).
However, a bill was been introduced in the House of Representatives (the IRA Charitable Rollover Facilitation and Enhancement Act of 2025, H.R. 2891) in April of 2025. It’s singular focus is to “strike” the reference to section 4966(d)(2) mentioned above and thus allow Qualified Charitable Distributions to donor-advised funds.
Unfortunately as of the writing of this post the bill has yet to pass the house making year-end relief highly unlikely.
It is reasonable to consider if the passing of this bill would offer attractive planning opportunities. My initial thought is that it would just make the process of charitable giving easier. A single lump sum could be directed to the donor-advised fund which is better equipped to make small and/or recurring grants directly to your church or charity.
Regardless of the outcome, the current and proposed legislation invites a conversation for those engaged in multi-generational planning. Specifically, should QCDs be directed only to the IRA owner’s desired charitable recipients or should the IRA owner also consider distributions to qualified charities supported by other members of the family?
Directing charitable gifts on behalf of others may be a creative and effective tax and estate planning technique as it reduces both the ordinary income to the IRA owner and size of their eventual estate. Further, it may provide additional liquidity to the next generation if their intended charitable giving is satisfied by the IRA owner.
A full analysis would also consider the marginal tax rates of the IRA owner and the other family member while recognizing that those claiming the standard deduction are likely to have a compromised tax benefit for their charitable deductions.