In reading previous comments in the IRA forum, there seems to be a wide difference of opinion when it comes to determining if the 1000 limit is reached when an MLP is held in an IRA account. One argument is that if there are 5 different MLP held in an IRA, then the reported UBTI can be netted out, and a 990 T is only required if the combined total exceeds a positive 1000.. The other argument is that a current positive UBTI can be netted out with prior UBTI losses for the same MLP.
To say the least, the IRC seems to be unclear, so what is the correct way to meet IRS reporting requirements. Is it combined netting, individual netting, or something else,
Also, I had a long discussion with my fiduciary, who claimed it was my responsibility to prepare and file the 990 T if required, but that if I sent a copy to the fiduciary along with an authorization letter, it would pay the treasury the tax due out of the IRA, as required, But it did admit that it realizes it will have to take a more proactive role in the future, as some of its competitors, like Schwab are doing,
Marvin Weiss