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It showed me that a few positions will essentially never be sold (i.e. basis is essentially zero) unless other tax situations happen that allow them to be....but in general I have the time to gradually reduce the other positions by small annual sales that generate less than $1000/year in UBTI

The issue is, because your IRA is still a partner in the MLP, you may not be able to realize the gain unless you sell out of the entire position, or, if you purchased in smaller lots, the entire lot. I would suggest consulting a UBTI tax specialist before embarking on this path.

Do you happen to know if negative UBTI (i.e. UBTI losses) can be used to offset UBTI gains?

You can carry forward UBTI losses to help offset gains, but only if the 990-T is filed for the year(s) in which the losses occur. Losses in the same account in the same year can also offset gains.

AJ
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