Hard Questions About PTP (Publicly Traded Partnership) K-1 Income and UBTI Tax Treatment
Title: Hard Questions About PTP (Publicly Traded Partnership) K-1 Income and UBTI Tax Treatment 1 I've been holding several publicly traded partnerships (PTPs) in both my taxable accounts and IRAs, and I'm trying to understand some nuanced tax implications. These are specialized tax questions about PTPs and their K-1 reporting that I can't seem to find clear answers for anywhere. My specific questions are: 1. If I sell some or all of a PTP and don't repurchase within the same tax year, how does that affect the Line 1 (ordinary income) and Line 20V (UBTI) numbers on my final K-1? 2. What happens if I sell some or all of a PTP position but then rebuy within the same year? How would that affect the Line 1 and Line 20V numbers on my K-1? 3. How does death affect the tax treatment for PTP shares held in taxable accounts versus IRAs? Are there specific inheritance considerations for these investments? From my experience tracking several years of K-1s, I've observed that when no trades are made to PTP holdings in a year, the ordinary income (K-1 Line 1) and UBTI (K-1 Line 20V) amounts correlate to the capital account. On a per-share basis, I've noticed UBTI and income are actually lower if the capital account is higher (or less negative). I mention this because I've received contradictory information from various sources. I'm on the receiving end of 1065 K-1s and don't generate them myself. Any insights on one or more of these questions would be greatly appreciated. Feel free to get as technical as needed!
24 comments


Mohamed Anderson
8 These are great questions about PTPs! Let me tackle them one by one: For your first question, selling a PTP without rebuying doesn't change how the K-1 is calculated for the period you owned it. The partnership will issue a K-1 reflecting your ownership percentage for the portion of the year you held it. Your Line 1 and Line 20V will be proportional to how long you owned the units that year. When you sell and rebuy within the same year, it gets trickier. The partnership doesn't track your personal transactions, so they just know how many units you own on record dates. You'll receive income allocations based on those ownership snapshots, regardless of selling and rebuying activity. Regarding death, for taxable accounts, PTP units receive a step-up in basis to fair market value at death, which can eliminate built-in gains. However, the decedent's final tax return still includes K-1 income up to date of death. For IRAs, the tax treatment follows IRA inheritance rules - no step-up in basis since it's already tax-advantaged. Your observation about capital accounts affecting Line 1 and Line 20V is correct. As capital accounts grow, the ratio of income to your investment typically decreases because you're being allocated income based on a larger capital base.
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Mohamed Anderson
•17 Thanks for the detailed answer. Follow-up question - when selling without rebuying, does the K-1 actually report a different amount in Line 1/20V compared to if I had held it all year? Or do they just assign me the full year amount regardless of when I sold? Also, for death situations, does the step-up in basis affect how UBTI is calculated going forward for the heirs?
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Mohamed Anderson
•8 The K-1 will generally reflect your proportional ownership for the period you held the PTP units. Most partnerships use what's called "interim closing of the books" or a pro-rata allocation based on the number of days you owned the units. So yes, your Line 1 and Line 20V would typically be lower than if you'd held it all year. For heirs receiving PTP units, the step-up in basis doesn't directly affect UBTI calculations going forward. UBTI is based on the partnership's ongoing business activities. However, the step-up does reset the capital account for tax purposes, which can indirectly affect the ratio of UBTI to investment as the capital account balance is higher after the step-up.
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Mohamed Anderson
6 After dealing with PTP K-1 nightmares for years, I finally started using https://taxr.ai to analyze all my partnership documents. The thing that makes PTPs so complex is how they report income and UBTI differently depending on your holding period and transaction history. When I was trying to figure out if selling and rebuying affected my K-1 amounts, I uploaded my previous K-1s plus my trade confirmations, and it showed exactly how my proportional income allocations changed based on timing. It also flagged instances where UBTI exceeded income thresholds that would trigger reporting requirements. Unlike generic tax software, it specifically handles these complex PTP situations and compares K-1 numbers across years to identify discrepancies or potential reporting issues.
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Mohamed Anderson
•12 That sounds useful, but how does it specifically deal with UBTI calculations? My biggest headache is figuring out if my IRA holdings of PTPs will trigger UBIT, especially when I've done partial sales throughout the year.
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Mohamed Anderson
•19 I'm skeptical that any software can correctly analyze PTP K-1s with partial sales. Most PTPs don't actually track when individual investors buy and sell - they just look at who owns shares on certain dates. How does this tool account for that timing issue?
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Mohamed Anderson
•6 For UBTI calculations in IRAs, it analyzes your K-1s to identify potential UBIT exposure by examining the Line 20V amounts together with your transaction history. It flags when your UBTI might approach the $1,000 threshold that would require filing Form 990-T for your IRA. Regarding the timing issue with partial sales, you're right that partnerships don't track individual transactions. The tool doesn't claim to know information the partnership doesn't have. Instead, it compares your reported ownership percentages across K-1s alongside your transaction records to help identify if allocations seem proportional to your actual holding periods. It helps spot potential discrepancies that might warrant a closer look or questions to the partnership.
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Mohamed Anderson
19 Just wanted to follow up about my experience with https://taxr.ai after trying it with my PTP nightmare situation. I was skeptical (as you saw in my earlier comment), but it actually helped make sense of my complicated K-1 situation. I had sold half my position in Enterprise Products Partners mid-year, then rebought a smaller position before year-end. The analysis showed that my K-1 allocations were roughly tracking with my average ownership throughout the year, not just my year-end position. This matched what the previous expert said about partnerships using interim closing methods or pro-rata allocations. It also flagged that my UBTI in my IRA holdings was approaching the $1,000 threshold where I'd need to file Form 990-T, which I hadn't realized. Saved me from potential reporting issues with the IRS. For anyone dealing with multiple PTPs and trying to make sense of how sales affect K-1 reporting, it's worth checking out.
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Mohamed Anderson
11 After struggling with the IRS about my PTP K-1 reporting for months, I actually managed to get someone on the phone who could help using https://claimyr.com. They connected me to an IRS representative who specializes in partnership returns in like 20 minutes when I had been trying for weeks to get through. The agent clarified that for partial sales of PTPs, the partnership is supposed to use a specific method called "varying interests rule" that allocates income items based on how long you held the interest - though the reality is many partnerships use simplifications. He also explained why my UBTI amounts were inconsistent with my ownership periods. If you're dealing with complex partnership issues, especially with tax notices or questions about UBTI calculations, you might want to check out their service. They have a video showing how it works at https://youtu.be/_kiP6q8DX5c - basically puts you at the front of the IRS phone queue.
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Mohamed Anderson
•13 How does this actually work? The IRS phone system is a nightmare - I've spent hours on hold and given up multiple times. Are they just charging you to wait on hold for you or do they have some kind of special access?
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Mohamed Anderson
•19 Sounds sketchy. The IRS doesn't give special access to anyone. Why would they allow some company to skip the line when regular taxpayers have to wait?
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Mohamed Anderson
•11 They don't wait on hold for you - they use a system that monitors the IRS phone lines and calls you when an agent is about to be available. It's basically an automated system that keeps redialing until it detects a spot in the queue, then connects you directly. They don't have special access to the IRS. They're just using technology to work around the phone system limitations. I was skeptical too, but I was desperate after trying to resolve my PTP questions for weeks. The best part was getting connected to someone who actually understood partnership tax issues rather than a general representative.
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Mohamed Anderson
19 I want to follow up about my experience with Claimyr after expressing skepticism earlier. I decided to try it because I received an IRS notice questioning my UBTI reporting from PTP investments in my IRA. I was honestly shocked when I got connected to an IRS tax law specialist in about 15 minutes after trying unsuccessfully for days on my own. The agent walked me through exactly how UBTI is supposed to be allocated when partial sales occur mid-year. They confirmed that some of my partnerships weren't following the technically correct allocation methods, which explained the inconsistencies I was seeing. For anyone dealing with complex PTP questions that general tax preparers struggle with, being able to speak directly with an IRS specialist saves an enormous amount of time and confusion. The $25 I spent saved me hours of frustration and potentially incorrect reporting.
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Mohamed Anderson
22 One thing nobody's mentioned about PTPs and UBTI - the reporting requirements between taxable accounts and IRAs are completely different. In a taxable account, you just report the K-1 income on your personal return. But if you hold PTPs in an IRA and the UBTI exceeds $1,000, the IRA itself must file Form 990-T and pay taxes separately from your personal return. I learned this the hard way when my IRA custodian sent me a letter saying I needed to handle the 990-T filing myself (most custodians don't do this for you).
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Mohamed Anderson
•1 That's a really important point about IRA-held PTPs that I didn't mention in my original post. Have you found any good resources for actually calculating the UBTI threshold when you've done partial sales during the year? My IRA custodian is equally unhelpful.
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Mohamed Anderson
•22 For calculating UBTI with partial sales, you need to look at the total Line 20V amounts from all your PTP K-1s held in the IRA. Even with partial sales, you'll use the amount reported on the K-1s for the portion of the year you owned them. The $1,000 threshold applies to the total UBTI across all investments in the IRA, not individually. So if you have multiple PTPs each generating $300 of UBTI, and together they exceed $1,000, you need to file Form 990-T. The complexity comes when you have both gains and losses from different PTPs, as they can offset each other for UBTI purposes. Most custodians provide no help with this because it's the IRA owner's responsibility to track and file. I use a tax professional who specializes in partnership taxation specifically for this issue.
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Mohamed Anderson
4 Another PTP quirk I've discovered: if you held a PTP in an IRA, sold it, and then rebought it in a taxable account in the same year, the K-1 won't distinguish between the portions held in different accounts. You'll get one K-1 showing total income, and you'll need to manually allocate what portion belongs to the IRA (potentially subject to UBIT) versus your taxable account.
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Mohamed Anderson
•14 So how do you determine what portion of the K-1 income to allocate to each account? Is it just based on the number of days held in each account? Or units multiplied by days?
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Sophie Hernandez
•The allocation between accounts should be based on unit-days - the number of units held multiplied by the number of days in each account type. For example, if you held 100 units in your IRA for 180 days, then sold and bought 100 units in your taxable account for the remaining 185 days, you'd allocate roughly 49% of the K-1 income to the IRA portion (180/365) and 51% to the taxable portion (185/365). This gets more complex if you held different numbers of units in each account. The key is maintaining detailed records of your transactions with dates and unit counts, since the partnership won't track this for you. The IRA portion of the income would be subject to UBTI rules, while the taxable portion goes on your regular return. Keep in mind that some partnerships use different allocation methods, so you may want to contact the partnership directly to understand their specific approach for mid-year ownership changes.
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Keisha Brown
This is an excellent thread on PTP complexities! One additional consideration that hasn't been fully addressed is the potential for audit risk when dealing with PTPs across multiple account types and partial sales. The IRS has been increasingly scrutinizing PTP reporting, especially UBTI calculations in IRAs. When you have transactions spanning both taxable and tax-advantaged accounts in the same year, it's crucial to maintain detailed documentation showing your allocation methodology. I've found that creating a spreadsheet tracking unit-days for each account type (as Sophie mentioned) is essential, but also documenting the specific allocation method used by each partnership. Some partnerships use the "interim closing of books" method, while others use daily proration - and this can significantly impact how you should allocate income between accounts. For those dealing with Form 990-T filings, remember that you can also claim deductions related to the UBTI-generating activity. This might include management fees or other expenses directly attributable to the PTP holdings in your IRA, which could help reduce the taxable UBTI below the $1,000 threshold. The death benefit question is also worth revisiting - while taxable accounts get step-up in basis, inherited IRAs with PTP holdings continue to generate UBTI for the beneficiary, which is often overlooked in estate planning.
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Ella Lewis
•This is incredibly helpful information about audit risk and documentation requirements! I hadn't considered that different partnerships might use different allocation methods (interim closing vs. daily proration). One question about the deductions you mentioned for Form 990-T - are there specific types of management fees that qualify? My IRA custodian charges various fees, but I'm not sure which ones would be directly attributable to the PTP holdings versus general account maintenance. Also, regarding the estate planning point about inherited IRAs continuing to generate UBTI - does this mean beneficiaries need to be prepared to file Form 990-T even if the original owner never had to? That seems like something most estate planners wouldn't think to warn about.
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Harold Oh
•Great questions about the deductible expenses! For Form 990-T purposes, you can typically deduct fees that are directly connected to the UBTI-generating activity. This would include management fees specifically allocated to PTP holdings, but not general IRA custodial fees. Some custodians provide detailed fee breakdowns that separate investment-specific costs from account maintenance fees - you'd want those specifics. Regarding inherited IRAs with PTPs - yes, this is a huge blind spot in estate planning! Beneficiaries absolutely can be caught off guard by UBTI requirements even if the original owner never filed Form 990-T. This happens because the beneficiary might inherit at a different time in the partnership's income cycle, or the inherited amount combined with their own investments might push them over the $1,000 threshold. I've seen cases where adult children inherited IRA accounts with energy PTPs and had no idea they'd need to file separate tax returns for the IRA until they got nasty letters from the IRS. Estate planners should definitely be flagging this during the planning process, especially since some PTPs are notorious for generating higher UBTI in certain years due to their business activities. The documentation piece Keisha mentioned is absolutely critical - I keep a dedicated folder with all transaction confirmations, K-1s, and my allocation spreadsheets specifically because PTP audits can go back several years.
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Katherine Harris
This thread has been incredibly educational! As someone new to PTP investments, I'm realizing there's a lot more complexity here than my financial advisor mentioned when recommending these investments for diversification. One thing I'm still unclear on from all the discussion - if I'm just starting out with PTPs and want to avoid the most complicated tax situations, would it be better to hold them only in taxable accounts to avoid the UBTI/Form 990-T complications? Or are there specific types of PTPs that tend to generate less UBTI that might be more suitable for IRA holdings? Also, for someone who hasn't dealt with K-1s before, are there any red flags I should watch for on my first K-1 that might indicate reporting issues or unusually complex allocations? I want to make sure I'm prepared before tax season hits. The documentation requirements everyone's mentioned sound extensive - is there a minimum level of record-keeping that would satisfy IRS requirements, or should I assume I need to track everything down to the daily unit counts like some of you have described?
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Caleb Stark
•Welcome to the PTP world, Katherine! Your questions are spot-on for someone just starting out. Regarding taxable vs IRA holdings - many investors do choose to hold PTPs only in taxable accounts initially to avoid UBTI complications. The tax treatment is actually more straightforward there, and you get the benefit of depreciation deductions that can sometimes create "phantom losses" offsetting the income. However, you'll miss out on tax-deferred growth. If you do want IRA exposure, look for PTPs with historically lower UBTI generation - some pipeline partnerships tend to have more predictable UBTI patterns than oil & gas exploration partnerships. Check the partnership's investor relations materials for historical K-1 data before investing. For K-1 red flags: Watch for late issuance (partnerships have until March 15, but chronic late filers can be problematic), amended K-1s (indicates poor record-keeping), and unusually complex schedules with lots of state-specific allocations. Also be wary if Line 20V (UBTI) amounts seem disproportionately high relative to Line 1 income. For documentation, at minimum keep: all trade confirmations with dates and unit counts, all K-1s, and a simple spreadsheet tracking your ownership periods if you make any mid-year transactions. The daily unit-day calculations only become critical if you're moving between account types or if you get audited. Start simple and expand your tracking as needed. The key is understanding what you're getting into before you invest heavily!
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