Hi,

I have a bit of a muddled situation in which I MAY meet the definition of a disqualified person relative to a private invesmtent I would I would like to make partially using funds in an IRA. I am putting up $X in non-IRA funds and .8X in IRA funds. I am not a manager or dorector of the business but will own a large % of the voting stock (circa 45%).

I came accross some infomraiton on the co-investment rule relaating to DQ persons. I think this fits my situation. Does this DOL opinion 2000-10A remain the most current advisory?

CO-INVESTMENT RULES (heavily paraphrased)

One of the important things to understand is that, in most cases, your IRA may co-invest with disqualified persons including yourself, friends, family, third parties (including entities) and any other IRAs or pension plans you may have. DOL Advisory Opinion 2000-10A outlines the caveats, however, including the fact that you have to be in a position to prove that you could have accomplished the transaction without the use of your IRA (to avoid a PT for enabling)……It is important that co-investment involving disqualified persons is executed simultaneously.