I know that if a client “earns” more than $1,000 in UBTI, they have to file form 990-T. I also know that the $1,000 threshold is an aggregate limit for all “like” accounts that, once met, 990-T must be filed.

What I am unsure of is when a client has both a traditional IRA and a Roth IRA, would that limit apply separately, or would it be aggregated? I ask this because the Form 990-T has a separate code for “IRA, SEP, or SIMPLE” and “Roth IRA”.

If the $1,000 applies on an aggregate basis, which account is responsible for the taxes and filing? Or, would this situation require two Form 990-Ts to be filed, one for the traditional IRA using code 408e and one for the Roth IRA using code 408A? Furthermore, if a 990-T is required for each account, would the client have to apply for a separate EIN for both the traditional and Roth?