"Qualified custodian" — это такой хранитель, который (в числе прочего) может реально хранить активы, а какое он лицо — неважно. Вот цитата из решения (выделения мои):
A qualified custodian or trustee is required to be responsible for the management and disposition of property held in a self-directed IRA. Sec. 1.408- 2(e), Income Tax Regs. A custodian is required to maintain custody of the IRA assets, maintain the required records, and process transactions that involve IRA assets. See sec. 408(h) and (i); sec. 1.408-2(e)(4), (5)(i)(2), (iii), (vii), Income Tax Regs. The presence of such a fiduciary is fundamentally important to the statutory scheme of IRAs, which is intended to encourage retirement savings and to protect those savings for retirement. Independent oversight by a third-party fiduciary to track and monitor investment activities is one of the key aspects of the statutory scheme. When coins or bullion are in the physical possession of the IRA owner (in whatever capacity the owner may be acting), there is no independent oversight that could prevent the owner from invading her retirement funds. ... While an IRA owner may act as a conduit or agent of the IRA custodian, she may do so only as long as she is not in constructive or actual receipt of the IRA assets.
Так что если она была единственным или контролирующим акционером С-корпорации, то нет, не могла.
no subject
A qualified custodian or trustee is required to be responsible for the
management and disposition of property held in a self-directed IRA. Sec. 1.408-
2(e), Income Tax Regs. A custodian is required to maintain custody of the IRA
assets, maintain the required records, and process transactions that involve IRA
assets. See sec. 408(h) and (i); sec. 1.408-2(e)(4), (5)(i)(2), (iii), (vii), Income Tax
Regs. The presence of such a fiduciary is fundamentally important to the statutory
scheme of IRAs, which is intended to encourage retirement savings and to protect
those savings for retirement. Independent oversight by a third-party fiduciary to
track and monitor investment activities is one of the key aspects of the statutory
scheme. When coins or bullion are in the physical possession of the IRA owner (in
whatever capacity the owner may be acting), there is no independent oversight that
could prevent the owner from invading her retirement funds. ... While an
IRA owner may act as a conduit or agent of the IRA custodian, she may do so only
as long as she is not in constructive or actual receipt of the IRA assets.
Так что если она была единственным или контролирующим акционером С-корпорации, то нет, не могла.