Actually its kind of easy to get around the ubit issues.
The first issue is if you are running an active business by your trading.
Look at the Tax Court cases where the IRS has disallowed trader status. Don't do intraday trades. Hire someone to help with the trades. Skip a few days or weeks inside your IRA.
Just as its tough for taxpayers to get trader status, make it tough for the IRS to try to pin it on your IRA.
As for the idea of using foreign corps as blocker entities for UBIT, not sure why it would cost 30K. You can set up an IBC for about 1k, that's all you need. Also doubtful its going to be legislated away. Too many large endowments rely upon it heavily.
Just my 2 cents.
The first issue is if you are running an active business by your trading.
Look at the Tax Court cases where the IRS has disallowed trader status. Don't do intraday trades. Hire someone to help with the trades. Skip a few days or weeks inside your IRA.
Just as its tough for taxpayers to get trader status, make it tough for the IRS to try to pin it on your IRA.
As for the idea of using foreign corps as blocker entities for UBIT, not sure why it would cost 30K. You can set up an IBC for about 1k, that's all you need. Also doubtful its going to be legislated away. Too many large endowments rely upon it heavily.
Just my 2 cents.