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I agree with IRA. Here is the link that I finally found:

I agree that's an interesting approach, and I hadn't heard of that ruling. But as Ira said, you have to be VERY careful.

And note that it only covers the particular transaction of the initial capital formation of the LLC, (and I would think a corporation would work as well,) where the IRA is the first investor to jump in. After all, before that, the LLC has no relationship to anyone, so you don't have a self-dealing transaction at that point.

But after that? I can think of a million pitfalls that could come into play, if you ever want to do another transaction of any sort with the IRA. Is the IRA going to be the sole owner forever? Is the IRA owner going to be involved in management, and get a salalry, or anything else in the way of compensation? You could have self-dealing taxes all over the place.

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