Services
Forensic Exposure Diagnostics for U.S. Investors in Offshore Fund Interests
I provide specialized investigative analysis for U.S. taxpayers and their advisors. My work identifies structural failures at the intersection of U.S. tax law, U.S. securities regulation, and offshore fund structures, providing the documented foundation required for informed decision-making.
Scope
What I Examine
Every diagnostic engagement investigates whether:
The fund’s PFIC Annual Information Statement to determine whether it meets U.S. requirements to support a QEF election
Whether there are portfolio assets that require separate reporting
The fund’s cap table to test for U.S. Shareholders of a Controlled Foreign Corporation
Whether the custody arrangements for the investor’s fund units expose the investor to foreign trust reporting obligations and whether they comport with ERISA law, where applicable
Prohibited transaction rules triggered by an SDIRA-funded investment
Whether the offer, sale, and ongoing management of the fund interest complies with U.S. securities laws
Foreign legal analysis available on request. Coordination with or referral to jurisdictional counsel available.
Deliverables
What I Deliver
A comprehensive written report documenting findings, supported by workpapers. This report is designed to serve multiple functions simultaneously:
Tax Exposure Reality / CPA Foundation
You and your tax preparer receive the factual and analytical basis for determining the correct reporting position, preparing amended returns, and computing refund claims where applicable.
Defense Documentation
Under United States v. Reyes (2d Cir. 2026), reckless disregard now equates to willfulness. U.S. investors must demonstrate independent verification of foreign fund reporting to avoid willfulness penalties. This report is that documentation.
PLR Support
For investors seeking retroactive QEF elections under Rev. Proc. 2026-10, the diagnostic documents how the professional infrastructure provided information that misled the investor. Batch PLR applications with fellow fund investors may significantly reduce costs. Join the investor registry.
Legal Foundation
For investors or counsel evaluating securities law claims, the diagnostic provides the factual record of what was disclosed, what was omitted, and what was misrepresented in obtainable fund data. Deeper legal diagnostics are available upon request.
Two Levels of Analysis
The Investor Exposure Report ($7,500) tests the investor's exposure through the fund. It answers: "what does this mean for you?" It compels books and records, reconstructs the cap table, tests CFC and PFIC status, and produces a personalized, defensible report.
The Fund-Level Forensic Diagnostic (from $20,000) audits the fund itself. It answers: "what is this fund actually doing?" It reviews every transaction, contract, and lease, and tests compliance with management regulations and fiduciary obligations. This is what counsel uses. It requires the Exposure Report first, and it can be cost-shared among investors in the same fund.
What I Do Not Do
I do not prepare or review tax returns. I do not provide legal advice. I do not perform accounting reconstruction, though I can refer you to qualified professionals for that work. I do not sell offshore fund investments or represent fund managers.
I provide forensic analysis. Everything downstream is executed by your CPA or your attorney, grounded in my work.
Services
How We Work Together
I offer a stepped engagement structure. Each tier builds on the one before it.
Tier 1
$1,500
What it does: Risk screening based on public data and documents you already have. Oriented to investor protection. Designed to answer: do the signs indicate potential tax harm?
What you receive: A risk scorecard across multiple points of U.S. tax exposure: PFIC/QEF, CFC, Foreign Trust, ERISA, IRA, FATCA, FBAR. U.S. securities law red flags. Each risk area is classified by severity with a brief summary finding. The report includes estimated exposure ranges, immediate action items, and a recommendation on whether deeper analysis is warranted.
What it does not include: CFC testing (requires fund data not available at this tier), personalized cap table reconstruction, or deliverables suitable for use as a Reyes/Horowitz willfulness defense or Rev. Proc. 2026-10 PLR support. The Triage identifies the questions. The Forensic Diagnostic Report answers them.
Who it’s for: Any U.S. investor in a Portuguese fund (or other offshore fund) who wants to know whether they’re affected before committing to a deeper engagement. Also suitable as a diligence tool for potential investors.
Credit: Full $1,500 applied toward the Forensic Diagnostic Report if you proceed within 30 days.
Discount for diversified investors: $2,500 for two funds in one engagement.
Tier 2
$7,500
What it does: Your personal forensic exposure analysis. I compel books and records from the fund using your investor inspection rights. I reconstruct the cap table from bank statements, Interbolsa statements, and subscription documents. I test for CFC status at the fund level and, where indicated, at the portfolio level. I test the PFIC AIS methodology. I evaluate lower-tier PFIC status for portfolio assets where it is not obvious. I assess foreign trust reporting obligations. Everything is personalized to your specific investment, holding period, and circumstances. Designed to be defensible and demonstrate a higher duty of inquiry. Does not include accounting method translation.
Deep PFIC testing: For portfolio assets that require individual analysis (typically start-ups or opaque structures): +$3,000 per asset, confirmed in advance with a cost-benefit analysis.
What you receive: A comprehensive, personalized report that serves as: - PFIC & CFC testing at fund and portfolio levels - PFIC AIS methodology audit - Foreign Trust assessment - Reyes/Horowitz willfulness defense documentation - Support for private letter ruling requests (PLR) for retroactive QEF elections per Rev. Proc. 2026-10 (investor matching for batch requests per the investor registry) - CPA and legal reliance quality
What it does not include: Fund-level compliance auditing, management regulation review, fiduciary duty analysis, or accounting reconstruction. For fund-level analysis, see the Fund-Level Forensic Audit. Referrals for accounting reconstruction available if needed. I do not prepare or review tax returns.
Who it’s for: Any U.S. investor who has confirmed exposure through the Triage, or who already knows their fund’s reporting is deficient and needs a personalized evidentiary record. Also suitable for deep pre-investment diligence. Diagnostics also serve investors whose SDIRA-funded subscriptions may involve prohibited transactions, or whose custody arrangements may trigger foreign trust reporting requirements.
Tier 3
Start at $20,000
What it does: A comprehensive compliance audit of the fund itself for U.S. tax implications, adherence to management regulations, and the health of the fund. Reviews all transactions, contracts, leases, and other fund records to identify any departure from the U.S. tax reporting provided by the fund and from the fund’s Management Regulations and fiduciary obligations. Produces a memo suitable for use by U.S. or local jurisdiction counsel. This is not an accounting audit.
What you receive: A fund-level forensic report that documents: - Departures between fund activity and U.S. tax reporting provided to investors - Management regulation compliance or non-compliance - Fiduciary duty analysis - The factual record for securities law claims or regulatory submissions - The analytical foundation for civil litigation or coordinated investor action
Prerequisite: Tier 2 (Forensic Diagnostic Report) is required before proceeding to Tier 3. The personal exposure analysis establishes whether the fund-level audit is warranted and scopes it appropriately.
Cost-sharing: Unlike the Forensic Diagnostic Report (which is personal and cannot be shared), the Fund-Level Forensic Audit serves all investors in the same fund. Multiple investors can share the cost. If four investors split a $20,000 engagement, that’s $5,000 each for a product none of them could commission alone. The investor registry is designed to make this coordination possible.
Who it’s for: Investors pursuing civil claims. Investors in funds with particularly complex or suspicious structures. Counsel evaluating securities law or fiduciary claims. Investor groups coordinating collective action.
Add-On
$3,000
An add-on available to Tier 2 or Tier 3 clients. This briefing brings your tax professional or counsel up to speed on the deficiency patterns, compliance failures, and tax penalty landscape identified through the forensic review of the fund(s).
What you receive: A comprehensive briefing calibrated to what a CPA needs to know to serve clients in this space competently, and positioned for counsel reliance in damage claims and regulatory submissions. Covers structural failures, compliance risks, and remediation and exit pathways.
Who it’s for: CPAs, tax attorneys, and counsel working with Tier 2 or Tier 3 clients who need to understand the landscape to act on the diagnostic findings.
Firm trainings available. Expert witness available. Collaborative, complementary coordination welcome.
INVESTOR REGISTRY
Know Your Fellow Investors
The owner of the fund is YOU. The fund manager works for you and the other investors in the fund. But do you know who your fellow investors are?
When U.S. investors in the same fund coordinate, the economics of remediation change dramatically. Batch PLR applications reduce per-investor costs. Shared forensic accounting reconstruction eliminates redundant engagements. Civil claims gain weight when investors can demonstrate coordinated harm. And the Fund-Level Forensic Audit (Tier 3) can be cost-shared among investors in the same fund, making a $20,000+ engagement accessible at a fraction of the individual cost.
Register here and we’ll connect you with other U.S. investors in your fund.
This is a free service. Your personal information is never shared with fund managers or promoters outside of paid forensic diagnostic work. Anonymized, aggregated data may be used in regulatory submissions and market reports in support of investor protection. All entries are verified through the review of relevant subscription documents.
Your personal information is never shared with fund managers or promoters outside of paid forensic diagnostic work. Anonymized, aggregated data may be used in regulatory submissions and market reports in support of investor protection.
A Note on Independence
provide the specialized forensic analysis that sits upstream of tax reporting and legal strategy. My reports give CPAs and attorneys the documented foundation to:
My practice is fully independent of any fund manager, promoter, placement agent, custodian, or auditor operating in the Portuguese Golden Visa market or any other offshore fund market. I have no referral relationships with fund promoters. I receive no compensation from any fund or fund service provider.
My analysis is funded entirely by investor engagements. My only obligation is to the investor who retains me.
This independence is the structural prerequisite for the work I do. A forensic diagnostic has no value if the analyst has a relationship with the entity being analyzed.
This material has been prepared for information and educational purposes only. It is not intended to provide, nor should it be relied upon for, tax, legal, or investment advice. Each investor should consult appropriate tax, legal, and financial professionals regarding individual circumstances. Nothing on this website constitutes an offer to sell or a solicitation of an offer to buy any securities or investment products.
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