Posted by John K Haslach, CPA, MST on April 23, 2006 at 19:58:46:
You should consult with a professional who is very comfortable with IRC Section 704 and the UBIT sections. This is not a simple question and not for anyone who is not expert in the area.
John K Haslach, CPA, MST
Income allocation in partnership? - Posted by John
Posted by John on April 22, 2006 at 13:32:22:
I’m considerting doing a p’ship deal to buy a property, using my SDIRA to fund my part of the deal.
If I were to have the p’ship agreement state that any & all income that might be generated during the time we’re rehabbing & preparing for resale at higher price would belong to the non-IRA partners, and my SDIRA would not own any of that income…would that be a legal allocation of income, or not?
If I could do so, this would eliminate my having to figure and pay UBIT tax on that income.