I have a felling you are right that some taxes have to be paid even in a tradition IRA, but
I have called Fidelity twice and talke to two different people and they keep telling me no
tax on them in the IRA. They are the custodian so hope they know what they are talking about,
but have heard in the past from others there is a tax owed.
I also contacted Fidelity. They told me they discourage (and in many cases prohibit) holding such elements in an IRA but in any case it is not their responsibility (it is the IRA owner) to file the 990-T as they will not do it. Here is the exact exchange:
In an online chat with Fidelity I got this response:
Brian Pilling: From my understanding, this form is used to report things such as real-estate investments, or other non-publicly traded securities in an IRA. Fidelity has made a decision not to offer these types of securities with our IRAs, due to the complex nature of their valuation. Therefore, since we do not offer these securities in our IRA accounts, we do issue the 990-T.
CLIENT: I do not quite understand your last sentence
CLIENT: I am referring to MLPs within an IRA that may generate UBTI
Brian Pilling: Sorry, we do not issue...
Brian Pilling: So, we do offer these types of securities with our IRAs as they are typically publicly traded securities. However, I have checked with my help desk on this, and we do not issue 990-T forms.
Oh come on now, who are you going to believe? An internationally known brokerage service or an anonymous poster on a public message board?
You would be better off taking anonymous relationship advice than you would tax advice.