It is technically possible, but carries serious risk
A multi-member IRA LLC where two IRAs held by different individuals each own a membership interest is a structure some providers offer. This becomes problematic as spouses are disqualified persons to each other under IRC Section 4975(e)(2), which means any transaction between the two IRA owners within the shared entity must be handled with extreme care to avoid a prohibited transaction. The structure can be set up legally, but it requires precise execution and ongoing attention to remain compliant.
The administrative burden alone is significant. A multi-member LLC is classified as a partnership for tax purposes, which means the entity must file a Form 1065 partnership tax return each year. This is an added cost and complexity that two single-member LLCs do not carry.
Where it breaks down
The deeper problem is rigidity. Life events that are entirely normal create structural crises in a shared IRA LLC.
Divorce requires unwinding a jointly held investment entity at what is already a complicated time. Death triggers questions about the surviving spouse's membership interest and its interaction with beneficiary and inherited IRA rules. Reaching Required Minimum Distribution age at different times, which is commonly the case between spouses, forces distributions from a shared entity on a timeline that may not align with the investment.
Any of these events can require dissolving the partnership, which may mean liquidating investments on an unfavorable schedule.
If you are committed to this structure
If, after understanding these risks, you wish to proceed with a multi-member IRA LLC, do so only with direct involvement of a qualified tax attorney for initial setup, annual administration, and consultation before making any significant changes to the plan or its investments. This is not a structure to manage without specialized professional guidance.
The better path
Two separate self-directed plans accomplish everything a shared LLC is intended to do, without the partnership tax filing, complexity, and structural fragility. Both plans can invest in the same assets side by side. Each plan remains independently managed, independently distributed, and independently transferable.
That is the structure Self-Directed Plans recommends and supports.