So,If I understand the mechanics of a 1031 correctly, your basis in the property (due to the carry forward basis in the 1031) is Lower than $170k.You are Liable for depreciation recapture while it was a rental, whether or not you declared the depreciation.Assuming the above is true, you will have taxes due.You definitely pay income tax on any interest received.For the Principal you receive (including the down payment) it will be allocated into three pro data portions of:Return of basis/costs-no taxCap Gain- cap gain taxDepreciation Recapture- ordinary income tax at up to 25%@Ashish Acharya When later converting an investment property, acquired by a 1031, into a primary residence, then selling, give you a partial, Qualified Use pro rata calculation for the 121 exclusion like when you do the same thing with a non 1031 acquired property? 

So any tax at that point went away. 

If the real estate entity is engaging in a trade or business such as new property development for immediate sale, or flipping of properties, that can generate exposure to taxation on UBTI, which can be more detrimental to the ROI. 

@Lance Lvovsky has some great advice from a taxation standpoint, and you will want to ensure you are across your tax laws in the UK as well, make sure you definitively know your exposure.Finding a location is more of a personal preference and depending on funding, but there are good and bad areas in most states/cities to watch out forBest regardsLindsay

If so, you open yourself up to a bigger pool of candidates.There are about 20 tax accountants and CPAs here on Bigger Pockets who specialize in real estate taxation and work with clients nationwide.Reach out to a few of us and see who you like.Good luck and let me know if I can be of assistance.

If so, you open yourself up to a bigger pool of candidates.There are about 20 of us tax accountants and CPAs here on Bigger Pockets who specialize in real estate taxation and work with clients nationwide.Reach out to a few of us and see who you like.Good luck and let me know if I can be of assistance.

You need to consult with a CPA experienced in cross border taxation.

In that case, the bite of the taxation can be significant, and there may be better approaches for putting IRA money to work.UDFI is created when an IRA uses leverage such as mortgage financing.  

Eventually, federal spending or taxation will have to adjust to compensate.

@Taylor WhylingsIf you can document original intent to hold as a long-term investment generally the gain would be capital in nature and not ordinary gain subject to SE taxes.Short-term capital gains = holding period of one year or less = subject to income tax at your marginal tax bracket.Long-term capital gains = holding period of more than one year = maxes out at 20%.If you're subject to the next investment income tax (NIIT) add another 3.8% on top.Plus state income taxes as well.