effect of UDFI on distributions

[David Mcginnis]

If my SIDRA (regular/untaxed contributions) pays UDFI tax, what happens to distributions from the IRA? Do I have to pay tax on that income again or do I now have basis in the IRA?

Also, I think I understand that bonus depreciation is not used for IRA tax calculations, and straight line depreciation is used instead. Do I have that right? Seems that matters a lot in a syndicated leveraged investment, because a low basis results in a high debt ratio, and can make most of the profits taxable. Also, I think there is a real possibility of taxable operating profit in the early years of a syndicated leveraged multi-family investment as compared to outside of an IRA you get substantial shelter from bonus depreciation. Does that seem right?

Also wondering if IRA's facing UDFI have to pay the ObamaCare surchage of 3.8% in addition to ordinary income tax, cap gains tax, and recapture tax?

I know I need to rely on professional tax advice. Just trying to get a basic understanding so I am in position to evaluate the advice of my CPA.