; increase in qualified charitable distribution limitation (a) Increase in limitation Section 408(d)(8)(A) of the Internal Revenue Code of 1986 is amended by striking $100,000 and inserting $130,000 . (b) One-Time election for qualified charitable distribution to split-Interest entity Section 408(d)(8) of such Code is amended by adding at the end the following new subparagraph: (F) One-time election for qualified charitable distribution to split-interest entity (i) In general A taxpayer may for a taxable year elect under this subparagraph to treat as meeting the requirement of subparagraph (B)(i) any distribution from an individual retirement account which is made directly by the trustee to a split-interest entity, but only if— (I) an election is not in effect under this subparagraph for a preceding taxable year, and (II) such distribution meets the requirements of clauses (iii) and (iv). (ii) Split-interest entity For purposes of this subparagraph, the term split-interest entity means— (I) a charitable remainder annuity trust (as defined in section 664(d)(1)), but only if such trust is funded exclusively by qualified charitable distributions, (II) a charitable remainder unitrust (as defined in section 664(d)(2)), but only if such unitrust is funded exclusively by qualified charitable distributions, or (III) a charitable gift annuity (as defined in section 501(m)(5)), but only if such annuity is funded exclusively by qualified charitable distributions and commences fixed payments of 5 percent or greater not later than 1 year from the date of funding. (iii) Contributions must be otherwise deductible A distribution meets the requirement of this clause only if— (I) in the case of a distribution to a charitable remainder annuity trust or a charitable remainder uni­trust, a deduction for the entire value of the remainder interest in the distribution for the benefit of a specified charitable organization would be allowable under section 170 (determined without regard to subsection (b) thereof and this paragraph), and