I am so use to working in the other direction, I cannot recall of the US would tax the income in your hands as well (the IRSs approach to world-wide income is a little different than Canada's).If your company is a Canadian holding company, then having the company hold your share of the partnership would see the proceeds taxed in the company's hands (at the highest corporate tax rate) bout would allow the retained earnings to be retained in Canada or repatriated to your hands at your discretion.  

Long term, I want to create rental housing company that runs rentals so amazing that people would rather live there than own a home and deal with the work themselves, and it be cheap enough to help people afford comfortable living world wide.

Many of us accountants have clients worldwide.

This gives us creative ways of offering funding opportunities for projects worldwide.

It seems as if the powers that be, not only here in the US but worldwide really have a disdain for Airbnb.

CA taxes residents on worldwide income but may provide a credit for taxes paid to other states.

I have students worldwide closing deals.

Sometimes I forget how easy the internet has made communications worldwide.

Also my company invest in airbnb worldwide let me know if you would be interested in making some money together. 

From the article you mentioned:"Liability for US income tax on worldwide income."