Only one $1,000 specfic deduction under Internal Revenue Code Section 512(b) is allowed in computing an IRA’s UBTI, regardless of the number of unrelated businesses in which it is engaged (Rev. Rul. 68-536, 1968-2 C.B. 244). Yet, multiple IRAs can serve to minimize UBIT exposure. When utilizing multiple IRAs, each IRA may claim a separate specific deduction of $1,000 when calculating the UBIT owed.
Additionally, an IRA with two or more investments with UBTI, may use the losses from one investment to offset the income of another when calculating UBIT. However, UBTI from multiple IRAs cannot be combined.