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Banking — Tokyo Star Bank (Renfroe Holdings GK, Japan)

Account snapshot

  • Holder: Renfroe Holdings GK (Godo Kaisha)
  • Institution: Tokyo Star Bank (株式会社東京スター銀行)
  • Currency: JPY
  • Role: Primary operating bank for the GK. Holds the Mita Garden Hills 1009 mortgage, receives rent, pays local expenses.
  • Strategy: Austin explicitly wants to keep money in Japan to avoid FX conversion costs and tax friction from repatriation. The Brex GK conduit (0593) is used only for narrow cross-border flows.

Activity visibility

Limited — no Japanese bank statements have been shared yet. Activity is only partially visible through: - Brex 0593 history (23 transactions over the life of the account) — shows occasional cross-border flows, notably a $1.155M sweep from GK to Primary in one transaction (related to the Mita purchase financing flow) - Japanese accountant's deliverables (pending)

Mita Garden Hills 1009 — mortgage

Tokyo Star Bank provided 100% LTV financing on the Mita purchase. Reconciled total economic cost paid to seller side: ¥835,355,900 (= ¥813,905,500 adjusted contract price + ¥21,360,200 closing fees + ¥90,200 net buyer stamp duty), per accounting/mita-purchase-price-reconciliation.md and decisions/log.md 2026-05-08. Real estate acquisition tax of ¥4,130,000 (estimated) was paid separately to the Tokyo authority post-delivery.

TSB advance to GK 2025-07-28: ¥780,000,000 base. GK converted ¥780M → $5,238,766.88 USD at FX 148.89 and wired out from TSB head office account 100-12-01-7997469.

Amortization terms, rate, and term still need to be documented here. Per accounting/mita-purchase-price-reconciliation.md the line-item buildup is canonical; cite that file for Mita basis in advisor-facing output.

Acquisition history

See context/entities.md under Renfroe Holdings GK for the full purchase sequence (personal signing → contract rewrite to GK → second deposit → PNFP bridge → Tokyo Star Bank permanent financing → PNFP repaid → original Austin deposit refunded).

Open items

  • Provide Tokyo Star Bank mortgage documents (loan terms, amortization, interest rate)
  • Provide Mita closing statement (for basis calculation for US tax — depreciation, potential cost seg study)
  • Provide PNFP bridge loan documents (historical, for completeness and in case of any retained balance)
  • Japanese accountant to provide monthly GK financials (rental income, expenses, mortgage amortization)
  • Monthly summary journal into Xero GK tracking category (USD translation via Bank of Japan rate or similar)

US tax considerations

  • GK fiscal year ends October 31 — first full fiscal year ended Oct 31, 2025
  • Form 5471 first required with Austin's 2025 US return (extending to October 2026)
  • PFIC risk: rental income must be treated as a real estate trade or business, not passive. If PFIC applies, tax treatment becomes severe. This needs analysis by a CPA with international expertise — see tax/2025-filing-prep.md.
  • Check-the-box election for GK: status unknown, needs to be clarified with Pearce Bevill
  • FBAR: any US person with signature authority or financial interest in foreign accounts totaling >$10K triggers FBAR. A Japanese bank account holding mortgage payments and rent for a $14.5M property clearly triggers this, and likely has been for tax year 2025.