You are purchasing a property for $4M with a 75%, 20-year fully amortizing loan with monthly payments, and 3% interest rate. You plan on selling it at the end of year 2 for $4.1M. The lender will receive equity participation of 40% of income after debt service. Depreciation is straight-line over 39 years. Improvements are 80% of purchase price. The tax rate is 21%. NOI is 450,000 for first year and will increase by 3% next year. What is the After-Tax IRR for this property?