If the rates are dropped to 4% and it doesn't stimulate the housing market consumer confidence will plunge more.

@Jay Hinrichs most LPs are allocated losses but many LPs may not be able utilize them in the current year

., sale of goods and services).Business activity is not substantially related to exempt status.Business is regularly carried on by organization.Generally, IRA investments that can generate UBIT include: Limited Partnerships (LPs),Limited Liability Companies (LLCs), andAny investment that incurs debt financing and/or is involved in an unrelated business.I suspect that you problem occured because you bought an LLC and did business inside of it. 

We hold an apartment complex in ours (we're LPs and GPs in the deal)

They now have less money to pay the rent because of job layoffs or cut backs and now cannot stimulate the local businesses as much with their incomes.I tend to find more affluent areas even if they have a layoff with a down turn have built up significant reserves to live on.

I'll be chasing my own dream, actively building my own personal cash flow business, planning for and hopefully retiring at 50, enjoying special tax breaks, stimulating my mind....and the list goes on and on.It's a calculated risk.

If so, they are members and ther is a member manager, if you are talking about LPs, in a corporate charter, you'll have the general partner and limited partners.If you're starting out, tax wise, you're probably better off with the LLC and it's easier, IMO, to set up.

They are forming standalone LPs operating on a private equity model.

To me the downside is lack of control, and transparency (not that they are hiding anything, but you just can't track the numbers like you can with your private portfolio), and possibility to lose it all due to financing and LPs position on debt structure.Just my 2 cents.

This almost always necessitates the NRA file a 1040NR to reclaim the excess withheld, further adding to the compliance structure and cost.A lot of hedge fund managers don't like to have NRAs come into their LPs specifically because they find out about these obligations during tax time and don't like what it does to their compliance bills.A "blocker", i.e. establishing a US C Corp between the NRAs and the US investments, does solve this problem, but again, all factors need to be considered for a holistic approach -- minimization of US tax liability, Canadian tax liability, and compliance fees in both countries.