Effect of depreciation recapture on UDFI calculation

[David Mcginnis]

I'm thinking about investing in some leveraged syndications in my SDIRA. The deals typically take full advantage of bonus depreciation, so my basis is substantially reduced during the first year. I'm not concerned with taxes on operating cash flows, as I expect to see very little taxable cash flow. But on sale there is the possibility of a substantial gain, subject to UDFI. Because of my low basis, I am concerned that the debt ratio will be quite high, resulting in the majority of the profit being taxable inside the IRA. Much of that gain will be applied to bonus recapture, but the pure capital gain part will be subject to UDFI at cap gains rates, based on the debt ratio. Seems like my basis should be adjusted upward before the "average basis" is calculated as part of the debt ratio calculation, but I can't tell how that calculation is actually done. Any insights on the impact of bonus depreciation and recapture on the debt ratio and udfi calculation? If you are going to tell me not to worry because IRAs are not taxed, don't bother to respond.