In addition to possible UBIT (and UDFI upon sale), what are the other adverse consequences of IRA -owned real estate being used as security for a non-recourse loan? Section 408(e)(2)-(4) seems to be problematic for non-recourse loans. Does section 4975(c)(3) offer any relief/an exception?
Additionally, do the same disadvantages exist for other (401-k, P/S) retirement plans? I haven’t looked into section 401. Thank you.