When Should You Use an IRA/LLC or Checkbook IRA?

Welcome everyone to the Directed IRA Podcast. This is Matt Sorenson. I wanted to share with you today a special webinar we did for Directed IRA customers and clients at KQS Lawyers about the Checkbook IRA or IRA LLC strategy. I was joined by Ashley Burr, a senior attorney at the law firm KQS Lawyers, breaking down the structure and how you should be implementing it with your self-directed savings and investing. Please enjoy. Because we are going to talk about a legal strategy associated with your self-directed IRA, the IRA LLC or checkbook IRA, I decided to have Ashley Burr. She is a senior attorney at the law firm KKOS Lawyers here in our Phoenix office. She's joining me for today and she's going to be doing the legal stuff.

Yeah, that's Hello everybody, happy to be here. Yeah, I'm a tax and business attorney here at KKOS Lawyers, and my specialty is looking at a client's corporate structure, making sure they're set up best for both asset protection and tax savings. When I'm meeting with my clients, I'm taking this comprehensive approach, and I'm always hitting retirement.

Yeah, you can't avoid it. Yeah, you just can't avoid it, especially with the clients that we're trying to serve. And so, um, in our law firm KKOS Lawyers, and we work with many clients that are have accounts at Directed IRA that are customers at KQS Lawyers. You might have another law firm or CPA firm you're working with, um, but what we've gotten really good at is serving that entrepreneurial small business owner, real estate investor who loves also to self-direct their IRA. So we want to talk about the most popular strategy and structure someone's using with a self-directed IRA. It's called an IRA LLC, or also a checkbook control IRA. We're going to go through a number of ways you can structure this. I'm All right, well, let's dig into it. Before we get into anything, let's share the slides. I wanna give a disclaimer. Our malpractice provider makes us do this disclaimer. This is educational in nature, doesn't constitute an attorney-client relationship. Seek out your own specific advisors in your specific situation. Okay, the first thing, I just wanna get everybody up to pay, up to speed here. So many of you already have an account at Directed IRA, or you understand what a self-directed IRA is, but for anyone catching this that's new to this topic, We're talking about your IRA owning real estate, a rental property, crypto, a private company, a startup, SpaceX stock before it went public. Okay, now a lot of people hear that and they're like, well, how can I do that? Well, you need to use an IRA provider like Directed IRA that lets you invest in these assets. They're called self-directed IRA providers. Now a lot of people hear that like, well, now I heard that, you know, you said My IRA could own a rental property, like it could receive the income, it can receive the gain when I sell it and I pay no tax. And I called up Fidelity where my IRA is and they said I can't do it. Well, that's not because IRAs can't do it, that's because Fidelity IRAs can't do it. Okay, and we've got a lot of other content on like what the heck is a self-directed IRA to begin with. Let's drop that in a link. So if any of you are like, whoa, this is going fast, I'm trying to get to the IRELLC, the topic du jour here. So, if we, if we know what a self-directed IRA is, we're like, all right, now I want to do a real estate deal with my IRA. I want to buy that property and flip it and have the gains go back into my IRA. I want to own that rental and cash flow, have the rent go to the IRA, the cash flow, have the appreciation go into it. That's what we're talking about here with a self-directed IRA. So I'm going to set up a deal that I did, and then I'm going to have Ashley walk through the IRA LLC structure. So Let's go here to the slides. Um, and let's just talk about this. This was the first property I bought with my self-directed retirement account, right? This was a rental property in Indianapolis. It's a 3-bedroom, 2-bath rental. I bought it in 2017 for $85,000. Now, when I bought this property, I had monthly rental income of $950 a month. By the time I sold it, I was getting $1,200 a month. But that rental income was going to my retirement account. All that cash flow was building up in my retirement account, not paying tax. This is not going on my 1040, all right? And then later I ended up selling this property 5 years later for $184,000. And all of that gain went back into my retirement account, no tax. I didn't have to do a 1031 exchange or find a replacement property in 180 days and all that. Like it just went back into my retirement account. And I've actually been private lending this account and the money in this since this deal. But when I bought this property, I actually did not buy it in my self-directed retirement account. My retirement account owned an LLC and it was called Legend INRE LLC. Peter Thiel calls his LLCs after like Lord of the Rings, you know, places. I don't know if you, it's kind of interesting. I was like, I need a theme for my LLC names. So I did it off of great albums. Great, you know, and of course, the Bob Marley Legend album is, you know, is a favorite. So Jordan here, he's a music guy.

Yeah, no, I can almost name it track for track. Yeah.

Yeah. So it's a great, it's a great one. Anyways, so, but that LLC actually owned that property in Indianapolis, like on the deed was Legend INRE LLC. That was the name on the deed. When I bought the property, that was the name on the contract. It wasn't my IRA, but my IRA owned that LLC. So let me turn it over to you, Ashley. I'll let you explain the IRA LLC structure, how it works. We have some diagrams in the slides here, and we'll be sharing the deck. It'll be on the replay page at directedira.com/webinars. Um, but we'll be sharing the slides here. All right, Ashley, over to you.

All right, and I just kind of want to preface here that I love the Directed IRA and KQS Lawyers setup. Directed's on the 4th floor right below me. The law firm's on the 7th floor. And I think it's incredibly important that if you guys are looking into self-directed IRAs, LLCs, it is so important to talk to an attorney first. I have so many clients come to me that they've set up these LLCs themselves, these IRAs, without ever talking to an attorney. And it's just a lot of cleanup. There's a lot of maybe prohibited transactions that have happened, and it's just because they didn't get to talk to an attorney first. So I love this kind of setup where the clients go to Directed, they need help with an attorney, they get to come right back up to us. So always talk to your attorney first. And it's not just because I'm an attorney saying that. I just have seen the experience with my clients and it's super important.

Yeah. And I'll say, like, the fee when you set this up to set up the LLC includes a consult, right? You can talk to Ashley or one of the other attorneys at KQS Lawyers like it's included in that price. And we want it to be because we want you to have that conversation. I think the one thing when everyone self-directs their IRA, particularly when you do an IRA LLC out of the gate, is It's not that it's complicated, you're just new to it, right? So you can walk through the deal you're doing with Ashley, make sure it's structured properly for what you're trying to do in your situation, not what your friend did or what you read online or on some frickin TikTok social media account that was BS. So we can kind of get specific to your situation, make sure it's done right.

Exactly. And there it's really twofold why you would want an LLC for your IRA. Number one, it's for that checkbook control. So if you're just making investments with your IRA directly, that means anytime you want to move money to your investments or take money out, you're reaching out to your custodian. Your custodian, they have other clients. It might take some time for them to get to you.

And we love you. We love you. Yeah, but it's better for you too.

Exactly. Yeah. And, and it's going to cost a fee every time you reach out to your custodian. They're going to charge you a fee to move your money. So that checkbook control, if your IRA owns this LLC, you're going to be the manager of that LLC. You go and set up a bank account. You have that complete checkbook control. You don't have to reach out to your custodian every time you're moving money in and out. You just have that complete control. Write out a check, move the money, do whatever you got to do. You don't have to wait for anybody's time constraints or pay their fees.

Yeah. And like particularly real estate clients, that's where this strategy started, was we had so many real estate clients and there's other lawyers that set these up. Of course, we're the best. But, but, you know, is that that real estate client was the first traditional client. A lot of people use IRAs for other things. We'll talk about like a crypto use case here, but it could be for many things. But, but real estate's been the common. And even me, like that real estate deal I did, I used an IRA LLC structure. Like, I'm the CEO here, I can push the buttons and tell people what to do. I know every request that needs to be made. I could even waive some fees, you know. I use the LLC because it's easier, it's simpler. Um, I can take action right out of a bank account. I can send— what about— I mean, we'll get clients that are like buying property at auction, you know. Or they've got a rehab going where they're cutting a lot of checks and bills, or they got to hire a contractor.

Just—

there's just like a lot of convenience with that bank account and just going right out of the LLC.

Exactly. So checkbook control and then that asset protection. So the whole point of an LLC is that corporate veil, that imaginary layer of protection. When you're buying real estate, I never want you to be on title individually because if somebody slips and falls on your property, The first thing they're going to do is hire an attorney. The first thing that attorney does is look up the deed. Who owns this property? Because that's who we're dragging into a lawsuit. So if it's you individually, you get personally dragged in. That means all of your personal assets are at risk. So instead, an LLC owns this property to give you that protection because that LLC doesn't own your personal assets. So that principle is the same when we're talking the IRA realm. So it wouldn't be you personally on the hook, but it's your IRA that would be on title. I don't want some attorney looking up title to a property, seeing an IRA listed as the owner, and they try to drag your IRA into this lawsuit. It's just going to get crazy. Instead, I want your IRA to be protected. I want an LLC to be on title to that rental. So now if something goes wrong, it's this LLC. It's not your whole IRA. It's not you on the hook.

Yeah. And a lot of people have a misconception on the asset protection part. Because they'll hear, but Matt, I've heard that like IRAs and 401s are protected from creditors. Creditors can't come after your IRA or 401. Well, that's true for your personal creditors. So like there's laws in the Federal Bankruptcy Code and in states that protect your IRA or 401 in the event of a lawsuit or judgment. Like you can file bankruptcy and keep your IRA or 401 in most instances. Like you can totally wipe out, no judgment or creditor can come and get it. But that's creditors against you personally going against your retirement account. When it's your retirement account that made the investment and your retirement account that had the liability, it's not protected from itself. They could sue the retirement account to get the assets. They could also sue you as being the responsible person making decisions for your retirement account if there's negligence or something for the slip and fall situation. So you do leave yourself exposed even though it's your IRA. It could either be the assets in your IRA or yourself. So number 2 reason, I love it, asset protection. Let's just take that off the table. Make sure you're building wealth, your tenants or whatever that could be the potential plaintiffs. Let's just not have that risk.

Yep, exactly. In the process of setting up one of these LLCs, it's really not difficult. Like Matt said, it's not very different from setting up a regular LLC, but it's just the rules within the prohibited transactions, disqualified parties. That's where the consultation is really important. So when we're setting up one of these LLCs, let's just assume a single-member LLC, that single member is your IRA. It's not you. So you, so pretty simple process. You'll set that up with the attorney, get your bank package. You'll go to a bank, which we're typically recommending Titan Bank. They're an online bank. They work exclusively with entrepreneurs, super savvy to this industry. You can use your own bank. Just be careful. Sometimes Bank of America, Wells Fargo, they'll say, hey, in order for you to open up this account, you have to make a $100 deposit. Prohibited transaction. You wouldn't be able to do that. You'd say, hold on, can't do that, but directed, we'll be wiring money within 48 hours. So the process is super simple. Single—

let's pause there. That's a good pitfall to bring up. We've seen people fall into that.

Yeah.

When you're opening that bank account for the LLC, remember, you don't own the LLC. And like Ashley said, a lot of banks will be like, well, if we're going to open this account, we need an initial deposit. And a lot of people are like, okay, well, here's a check for $100 or here's $100 cash of their personal money. Or let me just transfer money from my personal bank account over here to this new business checking account. That is a prohibited transaction. Right. You don't own that.

Right.

That's you personally. You're a disqualified person. Putting money into an LLC your IRA owns, the money's got to come from the IRA. Mm-hmm.

Any funding that goes into this IRA-owned LLC, it has to come from your IRA. You always must use your IRA as a vehicle to get more money into your LLC and to take it out. So of course you guys are going to have your $7,500, $8,000 per year contribution. You cannot put that directly into your LLC. It has to hit your IRA first, and then you can push it into the LLC from there.. And then same thing when you're taking your distributions at 59 and a half, don't take them directly from the LLC, send them back down to your IRA first, take an official distribution from the IRA account. So always keep in mind that IRA has to be a vehicle. So once you set up that bank account, and remember you are the manager, and when I set up LLCs, I'm always setting them up as manager managed, which means the manager has all the signing power and control over the entity. So even though the IRA owns it, you still have that control because you are the designated manager of that LLC. It's very important to reflect on any contracts, agreements, lease agreements, subscription agreements, whatever it is. Your LLC must be listed as the purchaser, as the landlord, because it's not you, it's not your IRA. So when you have these purchase contracts, when you're making an offer on a house, You're going to be signing on behalf of your LLC. There's always going to be a signature line. You'll sign your name, comma, manager. But make sure that's clear. That's not you assuming liability. You're not personally guaranteeing anything. You're just signing because an LLC can't. But at the top of any contract, it must be this LLC listed as the purchaser, the investor, the landlord, whatever it is. And that helps you stay away from prohibited transaction issues as well.

Yeah. Most people you're dealing with have no idea that an IRA owns this LLC, right? Like they're just going to see XYZ Investments LLC or whatever you wanted to call the LLC, right? And then you're signing as just manager. They don't know who owns it. You're manager of LLCs, like president of the corporation. It's like, like Ashley said, it's like you have the signing authority on behalf of the LLC to go do the things with the bank account or contracts or leases or sign at closing to buy or sell a property. So, so you, you have that control, but you have zero ownership personally. And this is not hitting your 1040. This has nothing to do with you. Your IRA owns this LLC. There's no tax return for the LLC because like I said, it's a single-member LLC or disregarded entity. What do you have to do to maintain it, though? Like, let's just think about that. On, on the IRA side, you'll have your annual account fee for the IRA because you still have the IRA that owns this LLC. And then the LLC will typically have a fee with the state, right? Be like, you know, $50. Arizona's zero, by the way. We love Arizona.

Yep.

Most states are like $50 or so.

Yeah, it's not too bad.

California, $800. Sorry.

Yeah.

Even if that LLC doesn't make any money.

Yep.

You gotta pay a minimum fee of $800 to the state of California.

But, and that, that state's important too, which again, consultation with an attorney's important because you shouldn't just pick any state willy-nilly, especially when you're buying real estate. It's got to be a state-specific LLC. So sometimes my clients will come to me in the very early stages, well, I think I want to own real estate with my LLC, let's just go set it up in California. And then I'll ask, well, do you plan on purchasing property in California? And they'll say, nope, I just, I just don't know where yet. I know it won't be California, but I live there, let's keep it easy, let's form it in California. Well, if you end up buying property in Arizona, that California LLC, that's not going to protect you in Arizona unless you get it registered here. And now you're paying Who states to keep an LLC in good standing? So that's important to note too. When you're buying real estate, the LLC always has to be established in the state that the property's located in. My crypto clients, we can have some fun, maybe a Wyoming LLC for some privacy and co-protection and things like that. But when we're talking real estate, it's always going to be state specific.

Yeah, that's a great point. And I think when you're starting that, I think the, the first takeaway for real estate clients is set up the LLC in the state where you're buying the property. It doesn't matter where you live. Don't worry about that. Now, you might be someone that's like, well, man, I might buy in a few states. I might buy, you know, real estate in a few states. I want to get it going because I need to start making offers. And if you're in a state like Colorado or Arizona or states that are really cheap, I'm like, cool, we can start there and we'll register it foreign when you go. But if you're in California, like, like Ashley said, or some of these other states that are really expensive every year, just wait.

Yeah.

Or let's set it up in the state you're most likely to buy a property, right?

Exactly.

Um, as long as that's not also in a very expensive state.

It's important too, when you do start making these offerings, make sure you kind of get your stuff together. If you think you're going to be using your retirement accounts in an IRA LLC, you don't want to start making offers with personal funds, your personal name, your personal LLCs, and then bring your IRA LLC in later. Again, we're skirting around the prohibited transactions. So really think about these things and plan. If you think you're going to be using retirement money, get that LLC going so you can start using that on any offer contracts and things like that.

All right, let's talk about, if you could go over like, let's say I'm the manager of the LLC, what can I or can't I do as manager of the LLC?

Yeah. So as the manager of your LLC, think of it, you're the supervisor. You're making sure that your investment is going as planned. You can play that supervisor role. You just have to be careful. You can't really get your hands too deep into that property. According to the prohibited transaction rules, you literally cannot pick up a hammer and hammer a picture frame in the wall. You can pick out the picture frame, but you have to hire somebody to go put that up. So even though you're the manager, be careful. You aren't putting any sweat equity into this property. You're just managing. Kind of think of a general contractor. You're just making sure all the moving parts are being put together. Um, and then two, make sure you don't pay yourself as a manager. Even though you're managing this LLC, you cannot pay yourself any management fees. If you hired a property manager and they're taking everything, of course you can pay them management fees, but never yourself when this is your IRA LLC.

Yeah, and I think, um, there is a case, it's on the slides too, it's called Ellis versus Commissioner. This was a guy that had an IRA LLC and was paying himself like $30,000 a year as a salary to be the manager. He got audited, IRS alleged a prohibited transaction, IRS won. So it's very clear that you cannot pay yourself a salary. We have always restricted it. And that's one of the main things I'll say in the IRA LLC documents, you will have, like, walk through the documents, if you will, like what's going to happen that you'll get in the IRA LLC. And let's talk about maybe a couple things that are in those that are different from a regular LLC.

Yeah, of course, yeah. So with an IRA LLC, you're going to be getting this corporate book. Within this corporate book, there's going to be your articles, your EIN. That's what you need to take to the bank to open up that bank account. You're gonna have your operating agreement, your seals, your minutes, all of your organizational documents comes with the IRA LLC.

Yeah, and the IRA custodian, Directed IRA, you know, in this example, like we're gonna request those documents. Like the bank's gonna want most of those documents for the bank account. One of the documents in there is called the operating agreement. And in that operating agreement, every IRA custodian that allows for IRA LLCs is going to have a checklist to make sure that that operating agreement touches on a couple of IRA issues. And one of them is that if a disqualified person, you, the IRA owner, is manager of the LLC, are you properly restricted on what you can and can't do and you can't take salary or compensation? There's about 7 or 8 things in the operating agreement that are unique to an IRA LLC that you won't see in a regular LLC operating agreement. And the reason I say that is Don't go set this up on LegalZoom or on your own using some regular LLC operating agreement. We reject those, sadly, more than we should, because somebody paid some other lawyer to do it or did it on some online service thinking that the IRA LLC is just an LLC they list the IRA as the owner of. It kind of is, but the operating agreement for the LLC must have specific restrictions in it. So Now, you don't have to use a lawyer to do this. You don't have to use a mechanic to replace your transmission either, okay? Or to fill your own cavity. I'm sure you could figure it out, but wouldn't it be better to spend an hour with someone that's done it before and has already figured it out and is actually licensed and authorized to do that? So, we can help you get there. It's not just, I think the advice is big as you emphasized earlier, but making sure the documents are done properly is really the next piece that's important.

Yeah, our goal is keeping you out of hot water with the IRS. So that's everything that we're doing, setting up the documents, the advice. We're just making sure that the IRS isn't going to come knocking at your door. Yeah.

And the, and the law firm does an opinion letter on the LLC as part of your documents that says this was set up in compliance with retirement plan rules. Make sure you operate it this way. There's a dos and don'ts guide. There's a lot of resources that were giving you to make sure that you're successful in the structure. Because Mark, you know, our partner in the law firm, I mean, he's always talking about how an IRA LLC is kind of like a loaded gun and that like you need to take a gun safety class and to like make sure you're operating it right. Because you're in control now. Like you've got the bank account. You're not running the transactions through us where we can be like, oh, you shouldn't do that, you know? Not that that's our job, but like, you know, when you have the LLC and the bank account, you can screw something up if you don't know what you're doing. So just make sure you're getting educated on it. We have all the resources. We're here to help you. The law firm and Ashley and the attorneys there, they're doing the consult to go over it with you in the first instances. And we're here with you along as it goes. Now, my experience with most clients, and I'm curious yours, if you agree, is they kind of need that help on the first deal. And like, can I do this? Can I do that? Okay. And then they kind of know what they're doing, right? It's not like you're going to be talking to us every time you're doing something. Right.

Yeah. Unless, so yeah, my real estate clients, I would say the 3 biggest investments that my clients make with the IRA is real estate, lending, or crypto. So a lot of the times my clients will just start out with maybe real estate. And so we'll kind of have our consultation very focused. All right, this is everything you need to know about real estate. But I'll kind of let my client know, hey, if you're ever going to pivot into these other investments, let's chat again. Certain investments have certain nuances and rules. Again, just want to make sure that you're keeping compliance with everything. So yeah, so you're not going to be reaching out to an attorney every time you invest in a new real estate deal. But if you ever run into any nuances and things like that, that's where the support's helpful.

Yeah. All right. Well, let's see if anyone has any questions, Jordan, on the IRA LLC. We've got a couple other structures we'll get into. Different uses for the IRA LLC, something called the multi-member IRA LLC. Let's see if we can hit any questions out of the gate.

Yeah, so Michelle's been doing a great job answering a lot of these questions. We have about 8, uh, ready to go, so stop me, okay, uh, when we want to move to the next section.

All right, let's do them.

First one, uh, anonymous attendee asks, if I have a checkbook LLC in Wyoming but live in California, can I do staking?

Of course.

Yeah, why not?

Yeah, yeah, yeah, absolutely.

Easy enough.

Yes, staking does not have to be state-specific.

Okay, uh, this question is from Jack Evans. How is depreciation realized and taken advantage of in an IRA, uh, for a SF rental? Without it, we remove one big advantage of rental property.

I can answer that. I I appreciate the perspective of we have— we've removed one benefit of real estate. I'm a tax lawyer, guys, like by training. Ashley is too. I buy real estate. I do not buy it for depreciation. Yeah, I think that's— I like that's the tax benefits. But here's— keep this in mind. When you sell that property, you're recapturing the depreciation. And the best way to grow wealth in real estate in the long term is the appreciation of the property. Now I get you're depreciating it over time and it's the cash flow is nice, but the main people— way people are growing and building wealth in real estate is owning the assets over time, letting the cash flow cover the expenses and getting the upside of the appreciation over 10, 20 years, whatever it may be. When you're doing that personally, that depreciation number or that recapture is going to hit you eventually. But also, I will say, IRAs don't pay tax. You can take depreciation in an IRA, there's just nowhere to put it because you don't pay tax. So it's interesting, people like, well, I'd rather live in a world where you pay tax and you, you can have depreciation loss to offset it. Wouldn't you just live in a world where there's no tax? Who gives a shit about depreciation? No offense. If I'm in a place that doesn't charge me taxes, but then people are like, but I need the depreciation. For what? You don't pay taxes in the retirement account. Well, but I want the— I better just buy it personally then, and I'll pay taxes. Now maybe you're a real estate professional and you're taking those losses to offset other income. That's less than 5% of our clients. I get it there. But frankly, if you're a real estate professional and we've got a lot of them that are clients that buy real estate in their IRA, they're buying their best deals in their retirement accounts, particularly their Roth accounts, because they pay zero tax on those deals. So I get that that is a thing and we like depreciation personally. But I think the pro of I live in a world where there's no tax, so who cares about depreciation is more compelling to me.

Yeah. And listen, guys, we aren't saying only buy real estate in your retirement. I tell all of my clients, if you're into real estate, do both. Buy real estate within your retirement and outside. Outside because you get the immediate cash flow, the depreciation, the tax benefits. But if you're using especially a Roth IRA, you're building a tax-free ATM because all of that rental income and appreciation goes back in totally tax-free. So do it both. We're not saying just do it with retirement. So get those outside benefits, but be building up your tax-free ATM at the same time.

Yeah, and that's what I do. And then frankly, that's what most of the clients at Directed IRA do that are real estate investors. They're doing real estate outside their IRA and inside their self-directed IRA or even solo 401. And so they're using these tax-advantaged accounts, like I said, for that long-term wealth building. We're compounding and growing it over time in a world where you don't pay tax on it, particularly if you're using the Roth. Which is the most popular account, by the way, at Directed IRA. So, but they're also doing real estate personally, you know, like I might, you know, I'm 46, maybe I want to exit a property in 5 years, in 10 years, and take that wealth out. Um, and so it's not either, it's not either or, it's frankly for 9 out of 10 clients they're doing both.

Actually, my clients are investing in what they know. So if they've already been investing in real estate in their personal life, they're going to come and do it inside their retirement too.

Yeah. Um, yeah, it's, yeah, it's interesting. I was talking to a client, real estate broker, invests in real estate personally, and she was wanting to start using her self-directed, do a self-directed IRA to, uh, buy her next rental property instead of buying it personally. And it's like, I have money already in a retirement account. I know nothing about the stock market or about mutual funds. I know real estate. I know how to analyze what's a good deal. Like, why would I even— I don't even want to learn that other stuff. I do this every day.

Right.

And it's like, okay, that absolutely makes sense. You should do this. Okay, next question. Sorry, we got a little passionate on that one. No, no problem.

Tangents are okay.

I don't know. Robert Kiyosaki's the guy. He's always been like, why would you buy real estate in your IRA? You don't get depreciation. I'm like, you don't pay any tax.

Right.

Who cares about appreciation?

John McDaniels asks, how do I use an SDIRA and IRA LLC to invest in real estate overseas in Dubai?

Ashley.

Yeah, and that's you. So that can be tricky because LLCs, that— it's not a thing in every single country. LLCs, that's a law that was created here in the United States. Not every country has LLC laws. So we can do— we can set up a maybe a Wyoming LLC to own your property in Belize, But just know that you might not have any asset protection because that's the point of the LLC is to provide your, you with asset protection. So sure, you have this LLC on title over there, but unless you talk to somebody local and get confirmation, we have no idea if this LLC is actually going to protect you if anything happens there. So as far as asset protection, that's something you definitely need to chat with somebody local in that foreign country to kind of see what we can do to make sure you're protected.

Yeah, and we definitely have clients that do that. We're just kind of limited on how we can help you because we don't know the rules in Belize, right? Or in Dubai or all these other countries.

Yeah.

And, and also, like, I don't know what's the tax ramification going to be in Dubai. Now, I know Dubai is very tax neutral and that's one reason people go there. And I'm sure we have a tax treaty in the U.S., but like, is Dubai going to care that this is an IRA? Making money there, are they going to make you pay taxes there? I don't know. And we don't know that for the hundreds of countries that are out there. So but we still have clients that do that. So what you would do is we would do the LLC in the US. It could be Wyoming or— I've done them. I've had a lot of clients in Florida buy stuff, you know, in the Caribbean or in Belize, actually.

Yeah.

And they'll do a Florida LLC, let's say, that owns the— I think Belize has like an IBC or something is what it's called. So it owns the Brazilian or the company in Belize. So the Florida LLC— your IRA owns a Florida LLC, Florida LLC owns the IBC. It's— that's the LLC corporation name naming convention in Belize, and that owns the property in Belize. So it's a, it's a couple steps to get there, but it's definitely possible. And you want local counsel or advisors in those specific countries. We'll see it in Mexico too. We'll see clients that have, we have a lot of Arizona clients that own like rental properties in Rocky Point or Cabo and places like that. And then you get into some of these trusts that they have in Mexico where the IRA is the beneficiary and you're there authorized as manager, but you need a bank involved. And this is very common. So, but you're going to need some help from a professional down in Mexico too. We'll help you on the US side. We just have zero jurisdiction outside the United States, right?

So, all right, we have a question from Craig Luman. When doing real estate transactions, you often have your LLC entity pay you for your time and services. Would that be seen as a taxable distribution? What tax consequences or penalties might that be for that income event?

Yeah. So it wouldn't be a taxable distribution. That would be a prohibited transaction. So worse. Yeah, even worse. Yeah. So that's black and white prohibited transaction. You cannot transact with yourself, your IRA, your LLC cannot transact with you or any entity you own 50% or greater of. So if you were to be managing this LLC that your IRA owns, that's untitled to a property and you pay yourself management fees. Prohibited per se. The IRS finds out, they deem it as though you no longer own that IRA. So anything that IRA owns, including that property, gets dispersed to you personally, which means if you're under 59 and a half, you're paying that 10% penalty. And depending on what type of IRA, there could be significant tax consequences.

Yeah, so don't do that. So if you, if you need to take money and you're 59 and a half where you could take a non-early withdrawal penalty type distribution. You're 59 and a half, so, um, just send the money from the LLC back to your IRA and take a distribution from your IRA. Don't send it right from the LLC to yourself and call it like a reimbursement or a management fee or a salary or whatever, right?

All right, Jack Evans has a question. Can a rental and an IRA perform a 1031 exchange?

Ooh, good question. Do you know this one? I do. I know the answer.

I've never had a client try that before. I mean, I guess, but I feel it wouldn't be as beneficial, right?

Yeah, 'cause it doesn't matter. There's no tax on a gain. There is one instance where it matters, okay? So if you're familiar with the UDFI and that tax, if you use debt to leverage a property, let's say you bought a $300,000 property, you put $100,000 in from your IRA and you got a mortgage loan for the other $200 grand to buy the property, which you can do. These are called non-recourse loans. We have 5 or 6 banks on our website that lend to IRAs buying single-family rentals, duplexes, commercial properties, whatever, and they'll lend on those properties. Well, when your IRA gets a loan to buy property, what the IRS does is they say that $300,000 property and that 2/3 of it was a loan that was not IRA funds, they tax 2/3 of the profits and say, well, that wasn't retirement account dollars, you don't get the non-tax on that. So that piece gets taxed under this tax called UDFI. We have some webinars and other content, a chapter in my book on this as well. But basically, if you sold that property, you can do a 1031 exchange to avoid the UDFI tax and roll it into the next property. And I have had clients do that strategy and use a 1031 exchange to basically defer that. So there would be no tax due on it. And essentially that gain is rolling into the next property, into the IRA, which you can eventually— you could pay off the debt and avoid having that UDFI at all.

Yeah. And it's not the end of the world, the UDFI, because again, it's not tax on all of the income, it's just tax on the leverage part. So just run the numbers. If there is debt, just make sure you're calculating the UDFI, make sure that rate of return is as big as you were hoping. Yeah.

All right. Robert Duran has a two-part question, which is kind of three questions really. So if I need to repeat it, I totally can. How many properties can I flip with my SDIRA LLC per year without triggering UBIT? Assuming efforts are to limit the total number of flips per year to avoid UBIT, can I partner with another investor on a flip and call it a private loan? What distinguishes a private loan on a flip versus a partnership on a flip?

Yeah, and I mean, to answer the first part of it, so, and there isn't kind of a black and white case law that says this. The IRS, you know, they don't like to be straight up with things. So, but we're kind of looking at what we're seeing in the rulings and the case law. And our general rule is if you're doing greater than 3 fix and flips in a year, the IRS deems you as in the business of fix and flips. Because if you're only doing 1 or 2, it's more passive for you. You don't necessarily have to worry about the UBIT implication. But if you're doing greater than 3, now it's really looking like you have this business, this fix and flip business. This is going to look more operational to the IRS. That's when that UBIT is going to start coming into play.

Yeah, and where this gets at, just so you know, is there's an exemption to UBIT for capital gain income from real estate, whether it's long-term or short-term gain from selling real estate. There's an exemption for that that says that's not UBIT. But the exemption says as long as your IRA is not doing this in the ordinary course of business. So that's where we're concerned with— if every year you're flipping 3, 5, 6 properties a year in your IRA, I'm going to look at that and say, you might have UBIT. Now, if you're like, man, I flip 1 or 2 properties a year, I'm like, I don't— don't worry about it. Or maybe I flip 4 properties this year and next year I did 1. I'm like, I wouldn't worry about it. Yeah, but it's like, it's the person that's doing consistently a lot of properties. Your, your IRA will be looked at as being in the business of real estate and as opposed to investing in real estate and just getting capital gain. And you'll run into this UBIT. So So I don't know if that helps. Let me answer the second part because the second question was partnering with people. The problem with partnering with people is it's still, it's still going to come through as a, is like a short-term flip or hold, presumably. By the way, we're talking about something you hold for less than 12 months. If you hold it, if you hold it over 12 months, I'm not worried about it. Maybe there's a rehab that takes a while or it's on the market for a long time. That's actually good for this analysis. Any of those ones you've got, I'm not counting those in your 3 deals a year that don't stress about. But let's say that you partnered on 5 deals and they're all less than a year and you got a gain on it. I'm like, ah, that's just as bad as if you just did 100% of the deal. It doesn't help you to partner on a deal. Now, if you lent on the deal and you're just the private lender just getting interest and points, that's fine. Don't worry about that. You can do 1,000 loans a year on getting interest income in points and you don't have to worry about UBIT. It's the gain and the equity stake in the property. Now I know the next question this guy's probably asking, which is in the third question, which is, well, what if it's a loan but I get a share of the profits on the deal too? Well, that share of the profits is what's going to lead you into, are you in the business of making money on buying and selling real estate? Because you're getting a piece of the gain. If you've got a lot of deals that way, I just worry that you're going to run into that. Are you in the business first? Now, there's not that many cases. In fact, there's no cases on IRAs and real estate like this in UBIT. But the UBIT rules for IRAs are the same UBIT rules for nonprofits. And there are cases on nonprofits buying and selling real estate, which are tax-exempt as well, just like retirement accounts, but they get subjected to UBIT in the exact same way. And there are some cases there. So that's where we're leaning on. And trying to take guidance. So if you want to be safe, like I said, 3 deals or less a year and you're not going to stress about it. You don't need to call your tax lawyer or your accountant. If you're doing 4 or 5, you're kind of in a gray area. And if you've done more than 5 short-term deals in a year, just plan on having to do it.

And it doesn't matter if you have 3 separate LLCs doing 3 flips, they're going to look at the one IRA. So having multiple LLCs does, doesn't prevent that.

But it is different analysis. Let's say that you and your spouse are both doing— have a separate self-directed account and you're both doing flips. You could be doing 3 in your account a year and your spouse does 3 account or 3 in theirs, and that you could be doing 6 deals a year between the two of you. Even your traditional IRA and your Roth IRA, they're actually technically separate accounts, account types. So you could be doing 3 deals in your traditional, 3 deals in your Roth, 3 deals in your Solo K., and you would get, you could be doing more flips. And we definitely have those clients that have got multiple accounts between them and their spouse. They got a Roth IRA, they got a Solo K, and they're just, they do a lot of deals and they're running them through their retirement accounts. You will get separate treatment. You do not get separate treatment, and this is on the UBIT. Sorry, we're going a little long on this price shit. Let's say you're like, well, Matt, I did 5 Roth IRAs all in my name. Do I get 3 per deal? No. They have to be separate account types or you know, it's a separate person like your spouse or maybe one of your kids, right? Okay, let's go to multi-member IRA LLC, and I'll let, uh, Ashley set that up. Then we'll hit the crypto use and then come back for final questions.

Yeah, and so what we talked about in the previous slide was a single-member LLC. That's one IRA account that wants to take ownership of an LLC. Now we'll be talking about multi-member IRA LLCs, an LLC that maybe has multiple IRA accounts, because we were talking about prohibited transactions. Remember, you are a disqualified party to your IRA, which means you cannot transact with your IRA or IRA LLC, which means you cannot go stay on any property that your LLC owns. So you can't transact between each other, but you can partner with your IRA. Maybe you have personal funds that you want to put into this deal. Maybe you have a really high traditional IRA, but you want to get your Roth growing too. So you want to combine these different accounts together. If you're combining multiple IRA accounts or multiple retirement accounts or you're partnering with individuals, you will be establishing this multi-member IRA LLC. Same thing, just an LLC with multiple different members attached to it rather than just your one IRA account.

Yeah. And another good use case for this is let's say there's a property you want to buy and it's $300 grand. This is a rental property, right? We're talking about investment properties, of course. And let's say you have $100,000 in your account, in your IRA account, but your spouse has $200,000 in theirs. You're like, well, I can't buy it on my own, but if we put them together, we would have $300,000 in the LLC and we could go do that deal and buy the property. Now, when you do that, we always allocate the ownership in the LLC based on the dollars invested. So that LLC would be owned 1/3 by your IRA because it put in $100,000. 2/3 by your spouse's IRA because there's put in $200K, and then that $300,000 that's in the LLC bank account would go and buy the property. Now, you could both be managers of the LLC. Only one of you could be manager if you wanted. You could do it either way. Um, and I, and I like the multi-member IRLC when we're trying to combine funds to do a specific deal. Um, because we can— you can combine multiple sources of funds, even individually it like, um, Ashley said. The downside though to the multi-member LLC— there's two downsides. Downside one is you're doing a partnership tax return for the LLC. There's no tax due on a partnership return, right? It's what's the income, what's the expense, and here's the K-1s to the IRA, and there's typically no tax. But you do got to file the partnership return every year. So that's downside one. Downside two is once you set that initial ownership— take that example of your IRA owns a third, your spouse's owns a third. Whenever money, more money is going into the LLC, it's got to go one-third from you, two-thirds from your spouse's. Whenever money is coming out of that LLC, it's going one-third back to your IRA, two-thirds your spouse's IRA. So let's say you want to put $10,000 into the LLC next year. You make new contributions in each of your IRAs and you want to put $10,000 in the LLC. Okay, well, $3,000, $3,300, I should say, is going to come from your IRA. $6,600, you know, the balance is that it's going to be this 1/2, 2/3, $6,600 will come from your spouse's IRA. So, and you can't just be like, well, I want to put $7,500 in and then $7,500 for my spouse's. Well, you're not 50/50. That would be 50/50. So you've, so you get a little stuck there on the ownership percentages when you're trying to put more money in every year. If you want to do equal amounts and you don't have exactly equal ownership. So just a little heads up.

And that's when you're partnering with disqualified parties to kind of keep that in mind. You're locked into these percentages only if you're partnering with yourself or one of your disqualified parties. If you're partnering with one of your non-disqualified parties, you don't have to be worried about being locked into these percentages.

Yeah. For example, it's just you and a friend that are invested and you used your IRA, your friend used their IRA, or they were individual in an LLC. You can do whatever you want. You don't have to follow those rules. But if it's your IRA, your Roth IRA, your traditional IRA, your IRA, your spouse's IRA, those are disqualified. And the reason you have to put based on your ownership percentages is if you put more money in than you're supposed to, you're technically buying ownership from your spouse's IRA to your IRA. And now we're transacting and it's causing this. And even if you don't transfer the ownership, you've over-contributed for the value. And now there's like this self-dealing issue between you where you've put more money in, your spouse's IRA is benefiting and it, It just gets into problems. So, so just be careful there.

Yeah.

Um, all right, let's talk about fees on these. Multi-member IRA LLC fee versus single-member LLC of what the law firm's charging. What, you know? Yeah.

Yes.

You're a bargain.

So for, yeah, for an LLC setup, you get an hour of consultation time with an attorney. You get your articles, your EIN, complete formation with the state. You get that really nice corporate book that you get to put on your shelf with your operating agreement. All of your organizational documents. For a single member, it's $1,195 plus state filing fee. For multi-member, $1,495 plus state filing fee. Yeah, yeah.

And that includes everything. So, um, all the consultation, the opinion letter, documents, and then everything stays coordinated, uh, with Directed IRA. Okay, let's just hit crypto. I just want to talk about this briefly for a second. Let's say that you're someone who likes investing in crypto. Maybe you do it exclusively, or you're— you have the LLC structure and you want to do crypto So as many of you guys know, we have our crypto IRA product at Directed IRA with Gemini, where you have a, a crypto IRA with us, and that IRA owns a wallet and an exchange account with Gemini where you can buy and sell. It's not in your personal name, it's in the name of your IRA at Directed. We are all coordinated with them, and you can buy or trade 60 different cryptocurrencies, but you're on exchange with Gemini, and they have, you know, they're regulated, audited, hundreds of millions of insurance and all that, and You can go read up on how your crypto's protected at Gemini. But a lot of people are like, ah, I don't want my crypto there, Matt. I want, I'd rather use an LLC and hold my crypto off exchange. Or I may want to, I may on-ramp with Gemini, but I might want to exchange or exchange crypto and buy stuff not on Gemini. Or maybe I want to use Kraken. We've had many clients use Kraken. Well, what you can do is this LLC structure, use the same IRA LLC, but instead of buying real estate, You'll have an institutional account with Gemini, and that'll be linked to your business checking account, and it will fund this institutional account at Gemini. And then you can buy and sell with Gemini. In this structure with an LLC, you can actually go off exchange as well. You could hold your crypto on an external hardware device. You could go to some other exchange besides Gemini. You can basically get off exchange, when you're using our crypto IRA product, you're at Gemini. That's it. It's a lockdown. You can't move crypto off. It's, it's controlled because of the regulatory requirements. When you do this LLC, you get a little more freedom. If you want to do crypto, go off exchange, you could even use, like I said, Kraken, someone we've worked with too. We've just had some clients like, why, there's a crypto I want to buy that Gemini doesn't have, but it's on Kraken. Okay, well, we can do this LLC structure and get the institutional account set up at Kraken. You want to go off exchange to store the crypto, again, you could, um, use this. You have to on-ramp with Gemini, and then you basically off-ramp. So there's specific use cases. If you're not a crypto person, don't stress about this.

If you—

I would just start here if you're trying to get a little exposure to crypto. But if you're a little more serious person and those other strategies, I'd say more advanced or protective strategies, this could be an option. We've definitely used it there. Anything you add for crypto though?

Yeah, I was just gonna say, going back to the— if you do set up that LLC, as far as the state, again, it doesn't matter for the state. This doesn't have to be state-specific where you're living or anything like that. 99% of my crypto clients do use Wyoming. That's personal favorite of mine too, just for the privacy, because anybody can look up the Wyoming Secretary of State and it will not list who owns or manages that LLC. So we're going to have your LLC name be something inconspicuous. It isn't going to say Roth IRA Crypto LLC. It's going to be kept private in the name and then it's completely private with the state.

Yeah. And I think Wyoming gets oversold. I've had YouTube videos on people setting up Wyoming LLCs for the wrong reasons. But like when you have an operational business, you're going to set that operational business up in the state where you're— for you business owners, like where you're conducting business. When you're a real estate investor, we're setting up the LLC in the state where the property is located. When you have some freedom of where to set it up, we will go to Wyoming really for the privacy issue, right? Because Wyoming's unique like that. And in that instance, the law firm is actually being listed as like the organizer, right, or the person filing. So your name's not even on it, right? Um, no one knows that it's there. And Wyoming is one of the few states where you don't have to disclose a member or a manager with the state on the filing. So, um, so we've definitely found that helpful. And a lot of crypto clients particularly in particular value their privacy.

So, yep.

Okay, let's take some final questions. We got 5 minutes for questions. All right.

We've gotten some very specific scenario-based questions. Let's get some broad-based ones here. And then we'll go back to— we'll end with those. So Srini Madala asks, what size of IRA would justify setting up an LLC?

I don't think there's really a size. It's just when you have an investment that comes across your lap that you want to use retirement for. Because again, I don't want you to jump and set up these self-directed IRAs too soon, because these custodians, they aren't going to move your money, invest your money for you unless you ask them. So I don't want you to just park your money at a custodian, rack up their fees before you know what you want to do with it. It's not really an amount, but it's just once you come across a deal that you want to use retirement for, that's when you make the move over to a custodian who allows that self-directed IRA, and then you can take control of your retirement from there.

Yeah, and I think for the LLC, it just depends on the deal. Like, let's say you— let's look at that crypto use case. Like, well, I want to do $10K of crypto off exchange, or I want to use someone besides Gemini, and I'll do the institutional account with, let's say, Kraken or something. Um, cool, that, that can work. Like, let's go to that structure and your deal you want to try to use $10 grand. Or maybe you're going to wholesale a property or something and it's low dollar amounts. For me, I didn't do mine until I had the $85,000, you know, to put in, which I started at zero like everyone. I was contributing, trying to get enough money to do a deal. So, um, it just depends on, on your situation and the deal. I will say you kind of have to, like Ashley said, is like, you know, don't get the account set up until you have something you want to do. You also got to get ready. So another way to look at it, we've had a lot of clients do this, and I I prefer this approach too, is let's hear like, well, Matt, I want to do a real estate deal, but I don't know what deal it is. I don't even know what state the property's in, but I'm shopping, I'm being active, I'm looking at different deals. I'm interested in San Antonio and Kansas City, but I don't know which state I'm going to go in. I'm kind of— I made offers or I'm looking at stuff. Is, well, let's get the IRA going. Let's get at least $500, $5,000, $10,000, enough to at least get an earnest money deposit going on a deal. So that you can start moving quickly once you find the deal. The best deals that you find are deals you kind of got to get moving on quickly. So now if you already found that deal, then just move the whole account over here or the amount you need for that deal. But if you're still in like shop and wait and see mode, let's get the account going. I would probably say get $5,000 over here because it's enough to do earnest money if you're doing a real estate deal. But you can leave the rest. Maybe you've got $400,000 you're planning to do in the real estate deal or $200,000, whatever it is. Leave the other $195,000 over there at Fidelity, and you can move the $5,000. The other thing, you can actually buy mutual funds, index funds, at Directed too while you're in your account. So, um, if you know again you're going to do a self-directed deal and you need to be ready for it, um, you can just move that amount of money over here and invest in an index fund or a mutual fund or even an individual stock while you're waiting to find that deal, and then you can sell it. So But be a little proactive on the dollar amount and the deal. And you want— because you want your money working for you best you can. Now you're going to be in cash for a certain period of time until that deal closes because you need to get ready. And who knows, maybe the market goes down between this or it goes up. Yeah, it's always tough.

But all right, we have a question on anonymity and privacy. What is the downside of this LLC being in your name versus anonymous? Should I try not to name my self-directed IRA LLC with my name?

Yeah, and it's just a good idea because remember, kind of treat this IRA, this LLC, as this separate thing that you can't transact and, and really interact with other than being a manager of the LLC. So yeah, I want the name of your LLC— I want it to be private and conspicuous. Again, I don't want to see crypto in it. That makes banks funny sometimes. I don't want to see Roth or say Roth IRA LLC. We don't want people to know that you're using retirement money for these deals. So yeah, just good rule of thumb, always keep things private. Don't have your first and last name in there and nothing that can really tie things to you.

Yeah, that's why I like, you know, I was giving the— your favorite music album name, maybe it's Octoon Baby LLC, you know. I don't know, you know, maybe it's— that's just a cool name.

You know, U2 fans out there.

Yeah, yeah, that's for you U2 fans. Do you know Octoon Baby?

I know U2.

Okay.

Yeah.

Oh, that's an album from U2.

Okay.

Oh, yeah.

Okay.

Yeah. Had Zuropa on it.

Yeah.

Lemon. It's a forgotten— it's a forgotten album. Yeah. Maybe you're more familiar with Joshua Tree, maybe.

Yes, I do know that.

You know that one?

Okay. Okay.

All right. Anyways, I got to think of my next LLC name. I need a new one. Actually, I've done boring ones. I've done— I've kind of got off my band names. Footloose. You know, Angel, he turns out Angel's a Footloose fan. I didn't know that. Which is, it's hot. Yeah, it's, it's a, it's a good listen. Yeah.

I have a pet tortoise, so I have a Tortoise Capital LLC.

Oh, that makes sense. Okay. What's the tortoise's name again?

Tortilla.

Tortilla. Wasn't this Kevin's?

Yeah, he just donated. Yep.

Yep.

I adopted him.

Such a good home.

Yep.

All right, uh, okay, what— maybe one final question. Okay, are we good? If you're good and Michelle's answered them, I want to wrap it up.

Uh, no, let's get one more in. Let's get one more in.

I shouldn't have gone there. Yeah, I threw it, you know.

We'll do it. We'll do an easy one. How about we'll do this one because I think we know the answer to this one. Okay, from Ken: Can you buy a property from a friend for pennies on the dollar? Through an IRA LLC.

So your friend, not a disqualified party, so not prohibited per se, but could be considered self-dealing. So there are these other transactions that can come into play that maybe aren't prohibited per se, but if the IRS snoops around and they're looking at all the facts and circumstances and they think maybe you're benefiting from your IRA in some way, your IRA is benefiting from you in some way, or even somebody who isn't disqualified to you, they're benefiting because of what you're doing, that can be raised to a self-dealing, which can be escalated to a prohibited transaction. So when you're transacting with your IRA, and even if it's with non-disqualified parties, those transactions always have to be arm's length transactions.

Yeah, well said. And I think like the question would be, would that friend sell that property to me? And if the answer is no, then I'm like, then why are they selling it to you? Because if there's some like, well, I'm gonna kick them back money somehow, right? That's where we start becoming— that's going to be a problem, right?

So, right, that—

don't do that.

Yeah.

All right, uh, let's get to the slide here. We do have a promo right now for any of you that don't have a self-directed IRA, direct IRA, or need to open another one. You want to get going in an IRA LLC, you can save $200. Use SUMMER200. The promo code. Um, it'll save on opening a new account right now. And Ashley's contact has been shared in the chat. Um, so let's just say it here now, just in case somebody's watching the replay. And I don't know if the chat goes on the replay. Does the chat show up? Okay, how do they get a hold of you, Ashley? Maybe drop your email if they want to work specifically with you. Of course, people can go to kqs-lawyers.com. You can learn more about the law firm and the services there, and you can schedule a call with one of the attorneys. But what's your specific—

yeah, feel free, shoot me an email. I'm super responsive, and I'll get you taken care of. But my email is my name, Ashley, A-S-H-L-E-Y, dot B-U-R-R, at kkoslawyers.com.

And I've already asked, she is not related to Aaron Burr.

I am not, as far as I know.

Even though you're from New York? Yeah, maybe you are. Have you done your family history?

I haven't. I haven't done a genealogy, but I must admit, in that situation, I am Team Hamilton.

So, okay, so It's true, Amber was the bad guy.

Yeah, so sorry, Aaron, if you're listening, but yeah, sorry.

Yeah, but it'd be cool.

It would be cool. It would be cool.

Now you won't forget her name, Ashley Dot Burr. A.Burr. Yes. Isn't that in Hamilton?

Uh-huh.

That's what I'm saying.

Wow.

I know.

Okay, that— we should change your email address.

Yeah, we can.

All right, well, thanks everybody for tuning in. Make sure you get over to direct@ira.com/webinar where you can watch the play. We will remind you when the replay is up and available. The slide deck will be there as well. Thank you for any of you who are customers of Directed IRA and of KKS Lawyers. If you're both, we appreciate your business, and hopefully this was educational today. We'll see you next time.

Thank you.