Tax question on Self Renting- Single Member LLC to SMLLC

[Justin Summers]

I'm buying a campground and for liability protection reasons I'm looking at holding the real estate in a single member LLC and Renting the real estate to another SMLLC that I also own that will run the campground operations.

   I realize this is considered "Self Renting" and passive losses can't be offset by passive income ...  But my question is by doing this does  mean all the rental income received by my SMLLC that owns the property become Active and therefore I would have to pay FICA taxes on the rental income?  I plan to rent at Market value .. I'm really just doing it this way to protect the real estate from  lawsuits. People love to sue campgrounds. 

Any other disadvantages you can see to being setup this way from a tax standpoint? 

Thanks

Justin