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Posted

Individual lends money to company that invests in distressed properties.

Individual's IRA also lends money to same company.

Company issues a note and gives mortgage to each individuals and individual's IRA.

Company is independent third party - not owned by individual or his family.

Neither investment was conditional on the other (i.e. Company would have accepted only IRA investment without individuals' investment and vice versa)

Did a prohibited transaction occur?

To me it has the look of one, but I am having a hard time fitting it within IRC 4975 and ERISA 406.

Any thoughts?

Posted

From the look of it I would say no PT. They look like separate independent arms length transactions to me from the facts you describe. But IANAL nor are PTs my area of specialty.

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