You've "tried it" several times, OPC, as have I, and we've beaten this horse so far past death, I believe we're sitting in a pot of glue!
In my mind, your transaction, which you call a loan, is a shallow subterfuge - it's a delayed sale, being used with the purpose of not angering the FDA with an outright, we have already delivered the goods, traditional type of sale. If the transaction is so transparent, that's why I say just go ahead and sell it, don't further insult the FDA by trying to call it a loan, it's not a loan.
What happens past glue?