How can a Business Dev. Company that passes thru income be a “blocker” for UBIT for IRA investment.

I am looking at BDCs, most of which are publicly traded, but they distribute (pass thru) 90% of income to stay tax free. But IRA rules say investments in “trade or business” is UBIT for IRA and I believe these BDCs often invest in smaller companies that are also pass thrus- like LLC or Sub S. So there is no layer of tax before it gets to my IRA, which seems to me perhaps should make it all UBIT? But then I read an attorney’s article that they are “blockers” for UBIT? Doesn’t SOMEONE have pay some tax somewhere along the line?



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