Q. Beginning in tax year 2022, partnerships with individual retirement account (IRA) partners receiving allocations of unrelated trade or business taxable income (UBTI) are required to include the IRA partner's EIN on Form 1065, U.S. Return of Partnership Income, Schedule K-1. Is there relief from this reporting requirement? A. Beginning in tax year 2022, partnerships are required to disclose on Form 1065, Schedule K-1, Line 20, Code AH, the unique EIN of the IRA partner if the IRA partner is receiving an allocation of UBTI. This EIN would be obtained from the IRA partner. If the IRA partner had UBTI in excess of $1,000 in any previous year, the IRA was required to file a Form 990-T, Exempt Organization Business Income Tax Return, reporting the UBTI and paying the applicable tax on that income. To file the Form 990-T, the IRA partner would have applied for, and received, a unique EIN. The IRS is aware that in some instances, the IRA partner may not know of a reporting requirement until after the Schedule K-1 is received, which would make it difficult for the partnership to include the EIN on the Schedule K-1. A partnership with an IRA partner that has never obtained an EIN or has not previously filed a Form 990-T is not required to list the IRA partner's EIN for on Form 1065, Schedule K-1, Line 20, Code AH for tax year 2022. This relief does not relieve the IRA partner of the requirement to timely file Form 990-T and pay any tax due. However, for all tax years subsequent to 2022, partnerships with IRA partners are required to include the IRA partner's EIN on Form 1065, U.S. Return of Partnership Income, Schedule K-1 if the IRA partner is receiving an allocation of UBTI.
