In determining whether an individual owns 50% of the profits interest

[EGB]

In determining whether an individual owns 50% of the profits interest of a partnership for purposes of determining whether a purchase by such individual in the partnership constitutes a prohibited transaction, would any interest held by the individual's IRA in the partnership be attributed to the individual? For example, assume that X, an individual, holds a 20% interest in a partnership and X's IRA holds 30%. In determining whether X's IRA can purchase an additional 10% interest without violating the prohibited transaction rules, would X be considered to own 50% (X's interest and the IRA's interest) or would X only be considered to own X's 20% interest? (This example makes the assumption that the IRA's initial purchase of the 30% interest in the partnership was not a prohibited transaction itself). More generally, is there attribution from an IRA to its owner in the world of prohibited transactions? Seems like this may be considered "indirect" ownership. I just can't find much out there about what constitutes an indirect holding in determining who is a party in interest. I did find one case where a trustee's holding of a company through a qualified plan was aggregated with his direct holding of the company in determining that the company was a party in interest. My scenario seems fairly analogous. Thanks in advance for any help.