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C, a U.S. citizen, buys U.S. real estate for $500,000. C borrows $300,000 from Pablo, an unrelated nonresident alien and C agrees to pay Pablo

C, a U.S. citizen, buys U.S. real estate for $500,000. C borrows $300,000 from Pablo, an unrelated nonresident alien and C agrees to pay Pablo 5% interest annually for 10 years plus 30% of the appreciation (if any) after 10 years. Is Pablo's interest "an interest solely as a creditor" so as not to constitute a U.S. real property interest?

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