I'm a long-time owner of ETP and nine other MLP's. Some of these are in my IRA.
I do not buy a large position in any of these in my IRA because of the UBTI issue. I figure if I don't have a large position in any of them, then the chances of going over $1000 UBTI in any single one is minimal.
Here's the question: If you have an MLP that has consistently shown a loss on this line, is there a carry-back provision to reduce the effects of a weird (positive) year?
The accounting on MLP's is almost impossible to grasp. I do understand the reason for the UBTI provision, but I can't transfer the reasoning of the tax law to something I can understand from an accounting view.