I can only speculate about the answer to the UBTI question, I don't really know. I suspect that an in-kind distribution is a transfer of ownership without a sale and that the only UBTI that would be realized is the amount that there would be in the absence of a sale. The IRA would be responsible for the UBIT realized through the date of the distribution and you would be responsible for UBTI afterwards. I think the question is best posed to the MLP to see how they will report UBTI on the Schedule K-1 issued to your IRA and the Schedule K-1 issued to you.
I've modified my original reply to indicate that it ignores UBTI.
