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title holding trusts

Posted by todd-wa on July 07, 2001 at 9:31 AM

Ward,I'm interested in using a self-directed IRA to buy property in. One potential drawback is the "unrelated business tax" potentially incurred by leverage. Below is a definition. Could a title holding trust avoid this problem?

Definition Of Debt-financed Property

"For purposes of section 514 and the regulations thereunder, the term debt-financed property means any property which is held to produce income (e.g., rental real estate, tangible personal property, and corporate stock), and with respect to which there is an acquisition indebtedness (determined without regard to whether the property is debt-financed property) at any time during the taxable year. The term income is not limited to recurring income but applies as well to gains from the disposition of property."


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