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Non-Tech : UAN - The variable distribution MLP that could go a long way
UAN 77.00-1.7%Jun 14 4:00 PM EDT

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To: Elroy who wrote (800)2/2/2024 11:39:24 PM
From: Area51  Read Replies (1) of 811
 
I would still be interested if you can glean a debt-ratio from any UAN 990-T. Also if anyone has a different mlp 990-t and the debt ratio is utilized in the 990-T I would be interested. I kind of think that some partnerships will include the debt ratio in the K-1 and in those cases the capital gain that is taxed on the 990-T will be reduced accordingly. UAN didn't include a debt ratio in the K-1 so the people doing the 990-T default to conservatively (as far as maximizing the tax due) using a debt-ratio of 1.0?

Regarding transferring shares to a taxable account to avoid the capital gains tax:
The link below considers the transfer of shares out of an IRA (see Q51 and Q53) to a taxable account. Seems like an in-kind distribution to me? If so maybe the transfer is not treated as an effective sale of the IRA shares so the capital-gain might escape the UBTI tax?

Q53: What happens if an in-kind distribution of the UBTI generating investment is taken? A53: IRA owners should determine with their external tax advisors whether the investment can and should be distributed from the IRA. The tax liability up until the date of distribution from the IRA will still need to be paid.

faq-ubti.pdf
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