Roth IRA Income from Canadian Distributions

I friend of mine has several Master Limited Partnerships and Limited Partnerships that are Canadian Petroleum based(either they are pipelines or production) in his Roth IRA. He saw somewhere in his readings that distributions from these Partnerships in excess of $1,000 created some form of problem for the Roth IRA. He asked me to research the validity and circumstances surrounding this scenario. From the research sources I have, I was not able to turn a “hit” on this aspect. I was hoping that someone may have heard of this and could cite the code, tax treaty, or notice that would apply to this set of circumstances. I understand that the government withholds a certain amount in tax, and there is not a way to claim this, as to recover it, as you would do on your personal 1040.



They may be referring to Unrelated Business Income Tax/UBIT.

If the IRA earns $1,000 or more in Unrelated Business Taxable Income , taxes will be owed on the Unrelated Business Income Tax. The IRA custodian is required to debit the taxes from the IRA and deliver the amount to the IRS as UBTI.

These should help
http://www.irs.gov/charities/charitable/article/0,,id=123293,00.html, http://www.irs.gov/pub/irs-pdf/p598.pdf and http://www.irs.gov/pub/irs-pdf/i990t.pdf



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