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Thanks for the reply Wradical. Some follow-up questions and thoughts:


Yes, but I hope you're aware that's only half the story. Your basis is also adjusted by your share of the partnership's income/gains/losses, etc. (increased for income, decreased for losses.)


I am aware...just using expositional expedience! ;)


But beyond that, a gain on the sale of the shares themselves should not be UBTI.


That's what I understand too: the difference between my sale price and my "original" basis is considered capital gains. And the IRA is exempt from capital gains taxes.

But, upon the sale of units, the difference between my "original" basis and the "adjusted" basis (which, of course, subtracts distributions but adds back in the "taxable income" part of the distributions) is taxable income to the IRA. And this taxable income is classified as UBTI.

As I've held my units for some time this difference between my "original" and "adjusted" basis is steadily creeping close to $1K. I want to retain my interest in this MLP. But, I also want to manage the taxes effectively. So, I figured that if I sold my units into the market, then quickly re-bought units out of the market, that I could reset the recapture to $0, while still staying under the $1K UBTI limit.

If that strategy is permissible it would even work for taxable accounts. And it's quite tax efficient because the marginal rates on UBTI are progressive. So, it would surprise me if the IRS lets you do it! ;)


I think an easier approach is to keep LP shares in your personal/taxable account, and keep the IRA for stocks, bonds, and even REITS should be OK.


Perhaps. And I see this advice in many places. But, I think that's just because holding MLP units requires some non-standard book-keeping and takes a little time to wrap one's head around the strategy space. That said, holding the units in a taxable account is not a panacea...you still have to keep track of your adjusted basis and keep an eye on UBTI (and pay taxes if it gets over $1K), especially if you've held your units for a while and your adjusted basis gets down to $0.
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