How to structure and manage foreign borrowings

[Michael Yu]

Looking for expert legal and tax advice - 

Just found out I could potentially borrow in another country with a very low rate and have been thinking about how to put this opportunity to use while having a proper legal and tax structure.

Considerations are:

- Loan can be under my name but would require my parents (with local assets as collatoral) as the guarantors.  Alternatively, my parents can borrow and loan me the money.  I assume I can avoid to be considered a "security" if I am borrowing for own use.

- Given the very low rate I am simply considering paying off existing higher-rate mortgages on my rental properties, essentially "refinancing" at a lower rate.  If there are left over I can put these to use in additional investments (rentals, bonds, etc).

- From a tax perspective I'm not sure how to properly structure to ensure I can deduct interest expense, as the foreign loan is considered general purpose and not secured by any of my US rental properties.  I understand interest on personal loans are not deductible.  If I establish a lending entity to lend to my rentals properties, will this do the trick?  Also, as the foreign loan will be under my name, will I be able to "contribute" the foreign loan to this lending entity?

- From a legal perspective obviously want to avoid being designated as a security in the above case.  I'm technically not raising money from other investors although my parents would have "skins in the game" as their asset will be collatorized.  

- I would love to be able to compensate parents in some legally appropriate way such as a fixed monthly amount for the life of loan.  But I am concerned this might lead to the "security" designation.

- I will personally bear FX risk but can hedge in many ways.  As US rates rise I expect dollar to strengthen so I'm bullish in near-to-mid term outlook but longer-term is anyone's call.

Appreciate any input and/or referrals to subject matter experts.

Thanks in advance!