To minimise tax exposure most of the revenue for the Philippine company was redirected to the HK company because of a loophole that allows foreign derived profits to be exempt from taxation in HK.

So long as the terms of that note will allow you to execute the subject to transaction, there should be nothing related to the IRA that would create an issue for you or the IRA account holder.The IRA as it stands should be subject to UDFI taxation on any of the income derived from the debt financing.  

I was under the impression that you pay less taxes with an LLC because you would choose corporate taxation. 

It is true it is paid back after tax, but the only true double taxation is on the interest paid into the plan, not the entire payment.

You have great taxation folks here like @Amanda Han and @Brandon Hall and @Steven Hamilton IITreated as regular income unless you buy it and held for 366 or more days.From Steven Hamilton II```You need to realize the two are separate things and you DO NOT want to have flips and rentals in the same entity.

Partnership or sole-prop taxation is generally better for rentals.

If you leverage that can lead to some high taxation.

First and foremost define all the legal aspects associated with global REI, verify taxation and partnerships that exist between the (2) countries.

That prevents piercing the veil.If you are the sole owner of both LLCs there are no tax implications as the IRS will disregard the entities for taxation anyhow.

The top end contributions are the same as the SEP, but you can get there on less earned income due to the combination of employer profit sharing and employee contributions.A Solo 401k is also not subject to taxation on debt-financed investments which an IRA is.The structure that provides you checkbook control in the 401k is more direct and therefore generally less expensive than the comparable IRA owned LLC.For the most part, if you qualify for the Solo 401k, it is the best overall solution.