-Operates a trade or business.
-Receives certain types of rental income.
-Receives certain types of passive income from a business entity it controls.
-Invests in a pass-through entity, such as a partnership, that conducts a business.
-Uses debt to finance investments.
A "trade or
business" is any activity carried on for the production of income from the
sale of goods or performance of service. Any business is considered unrelated
to the exempt purposes of an IRA or other retirement plan. Fortunately, the tax
code specifically excludes certain types of income from the definition of trade
or business income for UBTI purposes. The exempt types of income include
interest, dividends, capital gains, and profits from options transactions.
Royalties also are generally exempt. Even exempt
income, however, can be converted into UBTI. Real estate rental income
generally is exempt from UBTI, but becomes UBTI if the amount of rent is
computed as a percentage of the tenant's profits.
Controlling a
business entity also can convert exempt income into UBTI. When an IRA has
greater than 50 percent control of a business entity, any rent, interest, or
royalties paid by the entity to the IRA is UBTI if the payments have the effect
of reducing the business income of the entity. Another way to look at this rule
is that if the business entity deducts the payments to the IRA, they are UBTI
to the IRA.
When an IRA owns
an interest in a pass-through business entity (partnership or limited liability
company), the IRA's share of the entity's income is UBTI. Pass-through entities
generally do not pay federal income taxes. Instead, their income and expenses
are passed through to their owners' income tax returns.
This rule most
often trips up individuals who invest in master limited partnerships (MLPs) or
real estate partnerships in their IRAs. MLPs are traded on major stock
exchanges, and many people think of them as being the same as corporate stock.
In fact, these are partnership units, and the income and expenses of the
partnerships pass through to the owners at tax time. Individuals generally are
urged not to purchase MLPs through IRAs.
It is not illegal
to own an MLP through an IRA. The ownership, however, triggers the UBTI rules
and the requirement to possibly file a version of Form 990 and pay estimated
taxes. There is no tax advantage to owning MLPs through an IRA. Some tax
advisors recommend taking the easier and cheaper route of reporting any
IRA-owned pass through items on the individual tax return instead of filing a
separate Form 990 for the IRA.
An IRA also has
UBTI when debt is used to finance investments. Any type of income can become
UBTI when debt is used to finance the property that generates the income. For
example, if an IRA receives a margin loan from the custodian or broker, income
generated by the securities purchased with the loan proceeds would be UBTI.
Real estate mortgages also are debts that convert exempt income into UBTI. An
IRA can own real estate and earn rental income, and that rental income will be
tax deferred. If the real estate is financed with a mortgage, however, the
rental income becomes UBTI.
The prohibited
transaction rules are the final category of taboo investments. The rules are
fairly detailed and can get complicated. Generally they prohibit transactions
between the IRA and its owner or a person related to the owner (including
businesses). The penalty for
violating the prohibited transaction rule is severe. The entire IRA will be
considered fully distributed when the prohibited transaction was made. The IRA
owner must include its full value in gross income, regardless of the amount of
the prohibited transaction. If the owner has multiple IRAs, only the IRA that
engaged in the prohibited transaction is penalized. Other IRAs escape the
penalty unless they also engaged in prohibited transactions.
It is easy to
state the prohibitions in clear, plain English: No deals are allowed involving
the IRA and the owner or a person related to the IRA or its owner. Yet, there
are some "prohibited transactions" allowed by IRS regulations and IRA
owners can receive waivers from the Department of Labor for specific
transactions. IRAs do not have
complete investment freedom. IRA owners who prefer investments other than
publicly-traded stocks and bonds and mutual funds need to be wary of the
potential pitfalls. And while it is possible for an IRA to engage in
transactions with the owner’s small business, real estate, or other interests,
such transactions should not be considered without sound tax or legal advice.
Retirement Watch, a monthly financial advisory and web site, is the only publication covering all the financial aspects of retirement and retirement planning: investments, estate planning, income taxes, IRAs, annuities, medical and long-term insurance, and much more. Editor Bob Carlson, trained as an attorney and accountant, bases his advice and recommendations on independent, original, and objective research. His most recent books are The New Rules of Retirement and Invest Like a Fox…Not Like a Hedgehog. He holds a B.S. from Clemson University and M.S. and J.D. degrees from the University of Virginia. Since 1995 he has served as Chairman of the Board of Trustees of the Fairfax County, Va., Employees’ Retirement System and in 2000-2005 served on the Board of Trustees of the Virginia Retirement System.
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