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Thank you MTR for the clarifications on more than one front. :p. If I can ask one more question I assume the loans had to be "located" in Australia rather than being "located" in the US because you are only being charged interest withholding tax and not full income tax on the loan in the...

I think he is using his own money to lend to a US corporation (owned by him) that owns the properties. He charges the company a high enough interest rate that it does not make any money hence no US tax payable by the corporation. I do wonder why he is not being hit with US tax on the...