And a corporation may retain the income, but it still pays federal taxes on it, and then when it is distributed to the shareholders, they pay tax on it AGAIN! 

Person A Makes 150,000 a year pays 28% income tax Person B and C make 30,000 a year pays 15% income taxOkay so what im trying to get at is could you make the argument that it is unfair for Person B and C because they could be taxed at a lower rate personally instead of having the whole trust taxed at the high 39.6 rate (note Person A, Person B, And Person C all have 33 percent shareholding and the get the same dividends)It just seems like the savings within the S CORP work out good for Person a since his income tax is already high and the s corp saves within itself.Is this all sound?

And the coop board process can take months, with lots of nonrefundable fees, just to be rejected with no reason given.Back in the 70's and 80's many of the corporations ran into financial trouble because the share holders stopped paying their mortgages so the corporations had to raise their maintenance fees to cover the interest payments.

As for how such a deal may look, you could have a new parent holding company with different individuals/LLCs as shareholders. 

Investors being the residents themselves theirfore (accredited; non accredited shareholders).

There will be a bank loan of $1,452,000.The money will be raised via a Shareholder Loan and we are offering 40% ownership for $500,000 for a $772,000 share value.

The difficulties arise when some of the underlying shareholders, partners or members of the multi-member entity wish to go separate ways and attempt to exchange their interests in that entity as part of a tax-deferred like-kind exchange.

Lots of courts are looking at single member LLCs as little more than expensive and complex DBA registrations.A corporation, even one wholly owned by a single shareholder is harder to pierce.

The biggest challenge is likely maintaining the separate identities of the company and its owners/shareholders.

@Chris A.Most international investors do not want to go through the hassle of having to file a US tax return.An international investor investing in real estate in the US, directly or indirectly through a partnership vehicle will require the international investor to apply for an ITIN and filing of a tax return.However, if the international investors pool the money together and become shareholders in a corporation that ultimately invests in real estate(directly or indirectly through a partnership) will not require the international investors to file a US tax return.