I want to pursue wholesaling opportunities but haven't been able to pull the trigger on a deal due to the fact that I don't have access to a HML, the best thing I have is a commercial lender that can include rehab in loan but he was kind of skeptical of me because I am OOS and haven't had any experience managing BRRRR, but from what I hear you need either cash or HML to lock down wholesale properties. 

Also add that while there is zero effort involved in this type of investing once you pull the trigger, there is actually quite a bit of education that you should do beforehand to make sure you are choosing wisely.

My understanding is that any disposition of property out of the S corp triggers a taxable event, and steps up the basis thereby exposing the owner to capital gains tax. 

That’s harsh but that’s what you gotta do

Execution is a bit harsh for a consequence, in my opinion.

The rehab work triggered the interest of getting involve in real estate.

Would putting it in my name trigger the due on sale clause?

I'm now at the point where I'm just about ready to pull the trigger on something in the USA.

Many of those issues you probably have not even considered.Meanwhile, assuming you are 50/50 with your partner (a Pandora's box itself), I recommend these steps:each of you transfer $50k from LLC A into your respective personal bank accountseach of you contribute $50k from your personal accounts into the LLC B accountLLC B uses these funds for the property acquisitionIt should not trigger any taxes, under normal circumstances.

A transfer to an LLC will trigger the clause and should therefore be avoided, even though banks are hesitant to ever foreclose as long as the note is being paid.