The index adjustment uses the average Chained Consumer Price Index for All Urban Consumers (C-CPI-U) for each calendar year with 2022 as the base year. The average for a calendar year is taken from 9/1 of the previous year through 8/31 of the current year. Indexing starts with 2024, so the first adjustment will include 9/1/2021 - 8/31/2023. A fair estimate is that there will be an inflation adjustment of 10% to 15% for that period. If that is correct, the limit on outright QCDs would be between $110,000 to $115,000 and the limit on QCDs to a CGA would be between $55,000 to $58,000 (rounded $57,500 to nearest $1,000).
IRC Sec. 408(8)(G) Provides:
‘(G) INFLATION ADJUSTMENT.— ‘‘(i) IN GENERAL.—In the case of any taxable year beginning after 2023, each of the dollar amounts in subparagraphs (A) and (F) shall be increased by an amount equal to— ‘‘(I) such dollar amount, multiplied by ‘‘(II) the cost-of-living adjustment determined under section 1(f)(3) for the calendar year in which the taxable year begins, determined by substituting ‘calendar year 2022’ for ‘calendar year 2016’ in subparagraph (A)(ii) thereof. ‘‘(ii) ROUNDING.—If any dollar amount increased under clause (i) is not a multiple of $1,000, such dollar amount shall be rounded to the nearest multiple of $1,000.’’.
IRC Sec. 1(f)(3) Provides:
(3) Cost-of-living adjustment.
For purposes of this subsection —
(A) In general. The cost-of-living adjustment for any calendar year is the percentage (if any) by which—
(i) the C-CPI-U for the preceding calendar year, exceeds
(ii) the CPI for calendar year 2016, multiplied by the amount determined under subparagraph (B).
(B) Amount determined. The amount determined under this clause is the amount obtained by dividing—
(i) the C-CPI-U for calendar year 2016, by
(ii) the CPI for calendar year 2016.
(C) Special rule for adjustments with a base year after 2016. For purposes of any provision of this title which provides for the substitution of a year after 2016 for “2016” in subparagraph (A)(ii) , subparagraph (A) shall be applied by substituting “the C-CPI-U for calendar year 2016” for “the CPI for calendar year 2016” and all that follows in clause (ii) thereof.”
C-CPI-U Defined:
(6) C-CPI-U For purposes of this subsection— (A) In general The term “C-CPI-U” means the Chained Consumer Price Index for All Urban Consumers (as published by the Bureau of Labor Statistics of the Department of Labor). The values of the Chained Consumer Price Index for All Urban Consumers taken into account for purposes of determining the cost-of-living adjustment for any calendar year under this subsection shall be the latest values so published as of the date on which such Bureau publishes the initial value of the Chained Consumer Price Index for All Urban Consumers for the month of August for the preceding calendar year. (B) Determination for calendar year The C-CPI-U for any calendar year is the average of the C-CPI-U as of the close of the 12-month period ending on August 31 of such calendar year.
