340k across three lanes, and the allocation keeps collapsing into one
I have 340k across a traditional IRA and an old profit sharing plan, both movable. The plan was three lanes: 40 percent first-position private notes, 40 percent unleveraged passive equity through funds that hold cash-flowing residential, 20 percent held as dry powder for a distressed note buy that I keep expecting to appear.
Every time I run the after-tax math the allocation wants to be all notes. Interest income sits on the exempt side of UBIT, so an 11 percent note compounds at 11 inside the wrapper. The equity funds I have looked at are all 55 to 65 percent levered, and once I price the debt-financed portion of the income as taxable at trust rates, the effective yield drops enough that the diversification I wanted costs me two or three points a year. Unleveraged residential funds exist but the ones I have found are targeting 6 to 7 percent.
So the honest state of it is that the tax mechanics are pushing me into a single-strategy book, and I don't love a 340k position that is entirely one borrower type in one part of the credit cycle.
The decision in front of me: accept the concentration and diversify by borrower and geography instead of by strategy, or eat the UBIT and take the levered equity for genuine strategy diversification. I have not found a third answer.