Hmm, now you've confused me.
The first response says "an in-kind distribution from an IRA is equivalent to selling the investment within the IRA, distributing the proceeds, then repurchasing the investment outside of the IRA."
The second response says "I suspect that an in-kind distribution is a transfer of ownership without a sale ..."
The only reason I asked the question was to learn about the UBTI effect (if any) in the Roth of an in kind transfer of an MLP from my Roth account to my regular account.
If a withdrawal of an MLP from a Roth is the equivalent of a sale in the Roth, then there may be UBTI resulting from the sale in the Roth. On the other hand, if a withdrawal of the MLP is NOT (for tax purposes) a sale of the MLP, then there would be not UBTI in the Roth from the withdrawal.
I have asked the MLP, and they decline to answer. They suggest I ask a tax advisor, thus I've asked the question here.
So I guess I should disregard your first answer which says an in kind withdrawal from a Roth to a regular account is the equivalent of a sale and repurchase? Whether or not the Roth considers the withdrawal a "sale" is the key question (because sales of MLPs inside of a Roth can produce UBTI).
