Triage Assessment
Triage Assessment: $1,500
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.
If your DIY has become an SOS, our risk scorecard helps you find your way forward.
How It Works
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Step 1
Click the link to begin. When payment is received, an intake form and secure folder for document uploads will be sent to you. Complete the short intake form, detailing your fund, subscription date, amount, holding period, and any redemptions or distributions.
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Step 2
Share what data you have. Upload the fund documents you've received: marketing decks, PFIC Annual Information Statements, portfolio schedules, subscription agreements, financial reports, and any relevant correspondence.
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Step 3
Receive your Triage Assessment. A risk scorecard across multiple points of U.S. tax exposure: PFIC/QEF, Foreign Trust, ERISA, IRA, FATCA, FBAR. U.S. securities law red flags. Each risk area is classified by severity with a brief summary finding.
What We’ll Examine
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1. PFIC Status
Does the fund appear to be a Passive Foreign Investment Company? Do any of the fund’s portfolio assets meet the definition of a Passive Foreign Investment Company themselves?
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2. PFIC AIS
Does the fund’s PFIC Annual Information Statement, if available, appear to meet the statutory requirements based on available data? Do the pro rata computations seem plausible?
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3. QEF Viability
If the fund is a PFIC, and the PFIC AIS is available, does it appears probable or improbable that a U.S. investor can defensibly make and maintain a QEF election with the data on hand?
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4. Custody Arrangements
If the investor has elected fund manager omnibus account custody, does the corresponding paperwork, if any, point toward or away from the hallmarks of a foreign grantor trust?
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5. IRA / ERISA Compliance
If the investor funded the investment with tax advantaged U.S. retirement savings, an overview of the consequences of a prohibited transaction and non-compliant custody will be included.
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6. SEC Compliance
Is the fund compliant with U.S. securities law? Most Golden Visa funds are not. Your fund will be tested for SEC compliance and the assessment will detail your relevant rights and risks.
Each Triage Assessment will contain:
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U.S. Tax Law: Exposure Risk Scorecard
An assessment of tax risks you face as an investor in a certain offshore structure. This Triage Assessment identifies areas of concern that merit deeper investigation including the fund-provided data and how it interacts with the defensibility of U.S. tax positions, and whether past U.S. tax payments are at risk of being lost. -
U.S. Securities Law: Compliance Scorecard
A review of the fund's regulatory position in the U.S.. The Triage Assessment identifies risks associated with the fund's regulatory position. It will also include whether you, as a U.S. investor, have recourse under U.S. law under the provisions of The Securities Act of 1933 or The Securities Exchange Act of 1934. -
Triage Assessment Terms
$1,500 paid at booking.
Diversified Investors can add additional Triage Assessments for $1,000 each at booking.
The Triage Assessment will be delivered within 14 days of receipt of your investor documents in our secure portal.
If you decide to commission a Forensic Exposure Diagnostic, the price of your Triage Assessment will be applied to the cost of the Forensic Exposure Diagnostic if you proceed within 30 days of delivery of the Triage Assessment.
The Triage Assessment is an analytical report. It is not tax advice, not investment advice, not legal advice, and is not a solicitation for the purchase or sale of securities.
Not Included in the Triage Assessment
Controlled Foreign Corporation (CFC) Testing - this requires fund data not available publicly
Personalized cap table reconstruction
Deep analysis of portfolio assets
Deliverables suitable for use as a Reyes/Horowitz willfulness defense
Private Letter Ruling (PLR) support per Rev. Proc. 2026-10 for retroactive QEF repair
The Triage Assessment identifies the questions. The Forensic Exposure Diagnostic answers them. The Fund-Level Audit assesses the health and viability of the fund and whether the fund manager is acting in the best interest of the investors.
Deeper Analysis, Documented Diligence
For a deeper analysis of the U.S. tax exposure resulting from a Golden Visa investment, including CFC analysis, choose the Forensic Exposure Diagnostic. The resulting report is suitable as supporting evidence in tax and legal claims.
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.