Frequently Asked Questions
PFIC Help maps failures at the boundaries between systems.
Here, we share some of the pathways we've charted.
Services
How the Triage Assessment, Forensic Exposure Diagnostic, and Fund-Level Forensic Audit work, what they cost, and who they're for.
Investor Registry
How to connect with other U.S. investors in your fund for coordinated remediation and cost-shared audits.
U.S. Securities Law
SEC compliance failures, rescission rights, unregistered broker-dealers, Blue Sky Laws, and the 100 Investor Rule.
IRA, SDIRA & 401(k) Investments
Prohibited transactions, custody failures, FATCA reporting mismatches, and why "SDIRA approved" is meaningless.
PFIC, QEF & Excess Distribution
What a PFIC is, how QEF elections fail, what Excess Distribution taxation costs, and what to do about a faulty PFIC Annual Information Statement.
CFC, Foreign Grantor Trusts & Penalty Stacking
Untested CFC exposure, omnibus custody trust risk, information impossibility, and how penalties compound beyond the value of the investment.
Reyes, Willfulness & Procedural Defense
The objective recklessness standard, the Safeco-Horowitz-Reyes legal chain, and why documenting diligence matters now.
You didn’t create this problem. Misleading marketing practices, fund structure, gaps in reporting, and the professional infrastructure around it created this problem. But under U.S. tax law, the consequences land on you unless you act. The window to mitigate them is limited.