What exact language should a charity include in an acknowledgment to meet §170(f)(8) for a QCD?
Executive summary
A charity’s contemporaneous written acknowledgment for a qualified charitable distribution (QCD) must clearly identify the donor, date, amount and—critically—state whether any goods or services were provided in return; omitting the “no goods or services were received” language has led to Tax Court denials under §170(f) [1] [2] [3]. Practical guides for nonprofits list the same core items and advise labeling the letter as a QCD acknowledgment to avoid confusion with ordinary receipts [1] [4].
1. The legal baseline: what §170(f) requires and why wording matters
The statute and the IRS’s long-standing guidance require a contemporaneous written acknowledgment for contributions of $250 or more and specify that the acknowledgment must state whether goods or services were provided in consideration for the gift; courts have enforced that requirement strictly, disallowing deductions when acknowledgments lacked substantive language about benefits received [5] [3] [6]. QCDs are treated under the same substantiation rule even though the donor does not claim an itemized deduction—the QCD must still be documented so the distribution counts toward required minimum distribution rules [5] [1].
2. Minimum elements every QCD acknowledgment must include
Contemporary nonprofit guidance consistently lists the same minimal elements: the donee organization’s name and 501(c) status, the donor’s name (or that the letter is addressed to the donor), the date of the contribution, the exact amount received, and an explicit statement about whether any goods or services were provided in return—with a plain declaration that no goods or services (other than an intangible religious benefit, if applicable) were provided when that is the fact [1] [4] [2]. Practical systems and CRM vendors that help nonprofits acknowledge IRA gifts add that labeling the document clearly as a QCD acknowledgment and noting the IRA custodian can reduce administrative errors [7] [1].
3. The crucial sentence: “no goods or services were received” — and its limits
Multiple reports and Tax Court precedent flag one sentence as decisive: the acknowledgment must say that the donor received no goods or services in return; absent that substantive language, the tax benefit has been denied even where the gift was otherwise obvious [2] [3]. Some guides add the qualifier “other than an intangible religious benefit” when appropriate, since the IRS recognizes that narrow exception for certain religious organizations [2] [3].
4. Practical, defensible sample wording (based on statutory elements and practitioner guidance)
While sources do not provide an exclusive “official” template, synthesizing the statutory elements and nonprofit practice yields a defensible acknowledgment text including: the donee’s name and tax-exempt status, donor name, date and amount, and an explicit statement such as: “We received a distribution from [IRA custodian name] on [date] in the amount of $[amount]. The organization is a qualified 501(c) public charity. No goods or services were provided to the donor in whole or in part in consideration for this distribution (other than an intangible religious benefit, if applicable).” Nonprofit advisers recommend clearly titling the document “QCD Acknowledgment” and sending it promptly to satisfy the contemporaneous requirement [1] [7] [8].
5. Areas of disagreement, administrative friction and institutional incentives
Practitioner forums and nonprofit help desks report variability: some charities routinely include all required language, others omit parts because staff are unfamiliar with QCD nuances or because CRM templates aren’t tailored for IRA-origin gifts [4] [7]. Tax advisers urge conservatism because courts have been literal about wording, while some donors expect charities needn’t do anything special because a QCD isn’t a tax deduction—this mismatch creates risk if acknowledgments are incomplete [5] [9]. Nonprofits have an implicit incentive to avoid over-committing on technical tax language, but that caution can backfire by producing acknowledgments that fail judicial scrutiny [3] [1].
6. Bottom line for nonprofits building an acknowledgment process
Adopt a short, standardized QCD template that includes the donee’s tax status, donor name, date, exact amount, identification of the IRA custodian if known, and the explicit “no goods or services were provided” sentence (with the narrow religious-benefit exception if relevant); label it “QCD Acknowledgment” and issue it promptly to the donor to meet the contemporaneous standard [1] [2] [7]. Sources show this approach aligns with IRS statute, Tax Court precedent and nonprofit best practice; remaining gaps in practice mostly reflect administrative slip-ups rather than legal ambiguity [3] [4].