If you obtain a nonrecourse loan then the leveraged portion of the net income generated from the property would be considered UBTI . The UBTI would be the leveraged portion of net income including the net profit made on the sale of the property. Any UBTI income in excess of $1,000 would be taxed at trust tax rates and the taxes would have to be paid from the IRA.
This link provides a sample calculation - http://newdirectionira.com/blog/bid/20712/Unrelated-Business-Income-Tax-UBIT-AKA-UBTI
See page 16 for tax rate schedule for trusts - http://www.irs.gov/pub/irs-pdf/i990t.pdf
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EA, QPA, CHFC, CEBS, CLU - 30 years experience providing financial advice