Under the IRA RMD aggregation rules, you can satisfy your total RMD in any combination from the accounts, so you would need to determine if you took out more than the RMD for any other account, and that includes amounts donated as QCDs. If so, your RMD is completed.
If you still have several accounts, what you should do is first determine the RMD amount for each. Then add the RMDs together and determine how much you want to donate as a QCD. Then do that QCD from just one account before taking any other distributions. After the QCD is done you can them take the remainder of your RMD in any combination from the remaining accounts. There would be fewer transactions to complete. If you have very small accounts, I would actually surrender them entirely as part of your RMD and that way you will also reduce the number of accounts you have left.
If you find that you fell short in total RMD for a prior year, you should make up the delinquency and file Form 5329 to request that the penalty be waived. The IRS almost always grants the waivers. There is only 4 lines on the 5329 to be completed, but they are tricky to interpret without reading the last page of the 5329 Inst.
- This reply was modified 2 years, 11 months ago by Alan S..