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Dingus as an accountant you're far more qualified in dealing with the ATO than I ever will be. My feeling is that using an offset account in this manner could just be waiving a red flag at them, even when you're doing everything right.

Strictly speaking I think what you're planning is okay. If the offset account is never used for anything other investment purposes it should be fine. In practice though I'd discourage it. It's way too easy to muck something up and compromise the detectability of the loan. If you're...