Forensic Exposure Diagnostics for U.S. Investors with Offshore Fund Interests
Reports identify structural failures at the intersection of U.S. tax law, U.S. securities regulation, and offshore fund structures, and provide the documented foundation required for informed decision-making and defense against findings of willfulness.
Services
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Triage Assessment
High-level risk screening across investor documentation and public filings. A baseline scorecard to determine if your offshore holdings risk triggering immediate U.S. tax exposure.
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Forensic Exposure Diagnostic
Granular analysis of cross-border holdings, moving beyond the scorecard to map specific liabilities within PFIC, CFC, and Foreign Grantor Trust regimes, identifying the precise root of regulatory risk.
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Fund-Level Audit
A structural audit of the fund entity. We evaluate U.S. tax compliance, regulatory adherence, and internal governance to ensure the fund remains a viable vehicle for U.S. investors.
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Investor Registry
A secure no-cost clearinghouse for U.S. fund participants. Join the registry to coordinate with fellow investors, ensuring collective transparency and stronger protection through unified representation.
“It seems like you accomplished a mythical task, like Hercules and the stables or Psyche getting the ants to sort the seeds. Thank you!”
— RICK S., CLIENT
Upstream Technical Infrastructure for CPAs and Counsel
I provide the specialized forensic analysis that sits upstream of tax reporting and legal strategy. My reports give CPAs and attorneys the documented foundation to:
Isolate their own professional liability from offshore fund reporting failures
Establish a “Reasonable Cause” defense based on documented taxpayer diligence
Implement reporting positions grounded in forensic reconstruction rather than unverified fund data
Support refund claims for overpaid taxes on prior-year returns
Build the evidentiary basis for Rev. Proc. 2026-10 PLR applications
Firm trainings available.
I do not prepare returns. I do not practice law. I map failures at the boundaries between systems. I provide the analytical layer that makes your work defensible. Collaborative, complementary coordination welcome.
If your client holds a Portuguese Golden Visa fund interest (or comparable offshore fund), I welcome a confidential conversation about what I’m finding in this market.
U.S. investors deserve clarity, competence, care, and compliance.
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.
