It amazes me that such false information is mass produced and sold.The fact is, flipping properties in either a traditional or ROTH IRA Will incur UBIT.

You can make an argument that one strategy is better than the other (in your case, you feel that direct ownership is better), but saying that direct ownership is passive is completely false.

So while the notion of not participating may provide a false sense of security on the liability front, it runs smack into a SEC reg violation.To address your specific question, let me say my thinking runs counter to conventional wisdom in regards to liability protection provided through the use of LLCs.

That is patently FALSE! 

Bank fraud is the easiest to prove, show and prosecute, no loss needs to be suffered by a bank, only the fact that they were given false information in a loan application needs to be shown.

They have made a lot of false advertising claims that their contract you sign with the program specifically negates so you cannot sue for any reason.

And if your CPA is taking your actual expenses and inflating them to create a false sense of worth, then they are not a good CPA.

I do not believe the law allows any guru to hold you to a contract they have not performed or may not be able to perform, especially if they falsely promised you things that are not true.If I have a copy of your contract, I can show you how to go after the guru or the company without spending any more money than is necessary.I am not doing this to solicit your business, I just want to help and hopefully help sanitize the industry for newbies that really need help breaking into the investment world.Good luck. 

The stuff being sold is generally in marginal areas, at low cap rates, with false underwriting.

Because of this false sense of security you have been duped into believing you are actually setting your self up for trouble, not avoiding it.Ca recognizes this risk and slaps you with an $800 annual filing charge for each and every LLC you report under for BOTH in state formed LLCs AND out of state formed LLCs if you are a Ca reporting resident.