Self-directed IRA owner wants to loan funds from the IRA to an LLC.  His son owns 41.5% of the LLC.  The IRS deems any entity that is owned 50% or more by a disqualified person as a prohibited transaction.  A child is a disqualified person. However, would the attribution rules would apply here and therefore cause this to be a prohibited transaction?  The IRA owner would also be deemed to own 41.5% of the LLC and he as the IRA owner is a disqualified person.