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.

Quoting a recent news report (link at bottom of post): "The existing guidance, IRS Notice 2014-21, said that for the purposes of federal taxation, virtual currency is property.

This can be quite complex and you are in essence getting taxed on a tax deferred account (defeating the purpose).As Dmitriy pointed out, having your partner use their IRA to fund the deal as a note and deed of trust will avoid this taxation to his/her IRA so all you will need is loan docs drafted and executed.