Another IRA question

[Chris Christianson]

I have a scenario I'd like to toss out there for the SDIRA experts on the IRS definition of "benefit". 

My girlfriend of 17 years and I were looking over some of her investment vehicles the other day. She has been corporate her whole life so has a 401k, 403b, IRA's and a few cd's out there. One of the CD's was maturing and she was wondering what to do next. I take a look at her papers and she's making less than 1% on this CD. Her IRA which is invested in mutual funds is returning under 4%. Simultaneously, I'm borrowing money at 8-12% to do real estate deals. Get's me thinking the obvious.

So the plan is to convert her IRA to a SDIRA and she then can loan me the money I need at, say 10%. I write off that 10% as a business expense and dump it into her IRA at a significant increase in yield for her. Since we're not married, I'm not a disqualified person.

Anybody see anything I might be missing?