SERVICES
Private Client
Q4 2025
Critical Market Alert
Private Client Engagements Suspended for
Fund-Based Golden Visa Processes
Support remains available for
Donation-Based Golden Visa Processes
I have suspended new Private Client engagements that involve analysis or evaluation of Portuguese Golden Visa investment funds for purposes of making or supporting an investment decision.
Based on ongoing analysis, I have determined that the current Portuguese Golden Visa fund market presents unresolved U.S. tax and regulatory risks that cannot be responsibly mitigated through document review, comparative analysis, or individualized assessment.
Accordingly, I cannot in good faith accept engagements that would support or influence investment decision-making in a market where structural, regulatory, and reporting deficiencies remain unresolved and materially impact U.S. investors.
This determination reflects a professional obligation to prioritize regulatory compliance, tax defensibility, and investor protection.
What I Am Supporting Right Now
Private clients pursing a cultural donation-based Golden Visa process. Advisory support remains available. Please enquire below.
PFIC and CFC Exposure Diagnostics
for U.S. investors already subscribed to one or more Portuguese funds.
Tax exposure damage calculations
Quantifying consequences arising from defective or non-compliant tax reporting.
Investor exit strategy reviews
Identification of potential exit pathways, cost considerations, and exposure scenarios.
Documentation and audit-readiness support
Preparation of defensible records for CPA, legal, or regulatory review.
Briefings for CPAs, RIAs, and fiduciaries
Education on cross border investment tax and compliance risks.
Expert Memoranda
Analytical support for rescission analysis, dispute resolution, and damage assessment.
Private Client Support for U.S. Investors
A bespoke engagement for Americans who need a defensible strategy before selecting or subscribing to a residency-by-investment structure.
U.S. taxpayers face risks in Portugal’s fund market and Italy’s firm route that do not appear in marketing materials or in discussions with offshore advisors. These risks flow from the structural design of the vehicles, inconsistent reporting standards, and the way U.S. tax law applies to foreign entities.
This engagement typically lasts 60 days and provides an evidence-based assessment of those risks and develops a U.S.-aligned path forward, whether that means selecting a fund, a donation opportunity, or declining to subscribe.
Candidates
U.S. citizens who:
- are considering the fund/firm pathway for a Golden Visa
- want a U.S. specific review of the few viable fund options (review limited to the client’s shortlist, typically no more than five structures) or Cultural Donation opportunities.
- wish to avoid PFIC reporting failures and CFC exposure
- require a defensible strategy before committing capital
This is an advisory engagement, not a sales channel. The purpose is to avoid preventable U.S. tax and structural errors.
U.S. taxpayers who are already subscribed to an offshore fund and seek a formal PFIC or CFC reporting posture are invited to engage PFICHelp.com for PFIC and CFC Exposure Diagnostic services.
Scope of the Engagement
U.S. tax posture screening
High level assessment of entity classification impact, potential CFC and PFIC exposure, QEF feasibility indicators, portfolio composition risk factors, and the investor’s likely reporting posture under current U.S. law. Detailed diagnostic testing and QEF validity analysis are offered separately. See PFICHelp.com for details on diagnostic services.
Targeted review of candidate fund structures
Analysis of legal form, offshore regulatory classification, asset composition, and structural features affecting U.S. tax outcomes. Review is limited to the client’s curated shortlist, typically no more than five structures.
Parallel Investment + Immigration strategy
Integration of fund liquidity, subscription timing, redemption provisions, administrative realities, and nationality rules into a coherent, executable plan.
Timing optimization
Guidance on how subscription timing, asset holding periods, and fund-level realization patterns influence long-term capital gain treatment and reporting posture.
Document review
Review of documents the client already holds or can obtain in the ordinary course of their investor relationship.
The ideal document stack includes:
- Management regulations
- Portfolio holdings, including full holdings schedules where available
- Cash sleeve details
- PFIC Annual Information Statements (if issued)
- Audited financials
- Investor rosters
- Subscription documents
- Administrator communications
- Marketing materials
This engagement does not include contacting funds or service providers on the client’s behalf. All documents must be provided by the client.
Strategic memorandum
A structured assessment of risks, options, and reporting considerations, tailored to the client’s residency by investment goals.
Two 60 minute working sessions
Deep dive calls focused on tax posture, fund selection, structuring choices, and timing considerations.
Over 60 days
Private Client Engagements typically last 60 days. Accommodations can be made for longer engagements.
Email access for the full engagement
Timely responses to emerging questions as the investor moves through the evaluation and decision process.
Terms
Fee Structure
This engagement is offered on a flat fee basis for the full period, which typically lasts 60 days. Arrangements can be made for longer engagements.
The fee reflects the complexity of the client’s circumstances, the number of candidate structures under review, and the level of strategic coordination required.
Pricing begins at $25,000 for fund-based engagements and $10,000 for donation-based engagements.
Notes on Pricing
This program is designed for U.S. taxpayers navigating foreign investment structures where misalignment with U.S. law can produce material tax exposure. The fee reflects the depth of analysis, the specialized nature of the work, and the limited number of clients with private client engagements.
If a full PFIC and CFC Exposure Diagnostic is required for a target subscription or an existing subscription, that analysis is performed separately and depends on fund cooperation and data availability. See PFICHelp.com for more details on diagnostic services.
Coordination With Advisors
As appropriate, I may coordinate with the client’s U.S. tax advisors, wealth advisors, or legal counsel to ensure that structural insights and reporting considerations are accurately integrated into the client’s overall plan. Such coordination is limited to high level alignment and does not include ongoing advisor management or delegated responsibilities.
Independence and Compensation
I do not accept commissions, referral fees, or success based compensation from any offshore investment fund or project. All analysis provided in this engagement is independent. If I were to represent a fund or firm in the future, it would be for a vehicle that I created and structured, and any related private placement activity would occur exclusively through my regulated channel, Golden Visa Capital LLC, under the supervision of Finalis Securities LLC, a U.S. registered broker-dealer.
Why This Engagement Exists
Offshore residency-by-investment fund managers do not design their vehicles around U.S. tax consequences.
Migration agencies are compensated for investor referrals, not investor protection.
Americans often encounter:
- Incomplete PFIC Annual Information Statements
- IFRS-based reporting that does not translate to mandated U.S. tax reporting
- Fund structures with lower-tier assets and cash sleeves that create U.S. tax exposure
- Redemption terms that are restrictive or unfavorable
- Immigration counsel that omits U.S. tax posture
- Marketing narratives disconnected from actual risk
Once a calendar year closes, many choices become irreversible. This engagement exists to prevent those errors before they occur.
Outcomes
By the end of the 60 days, the investor will have:
- A defensible U.S. aligned residency-by-investment strategy
- Clarity on which offerings in the target country’s program (e.g. Portugal’s fund or cultural donation paths or Italy’s firm route) are viable for their profile
- Evidence-based selection criteria
- A map of potential tax exposure risks, if applicable
- A documented path integrating fund structure, reporting posture, timing, and immigration goals
No offshore provider or offshore migration agent can deliver this risk analysis from a U.S. vantage point. CPAs rarely have visibility into fund structure.
This engagement covers the blind spots at the intersection of U.S. tax regimes, foreign entity structures, and immigration timelines.
Request a Private Client Engagement
To ensure maximum service, a limited number of investors are accepted at a time. If you wish to be considered for the next available opening, please express interest by completing our brief intake survey.
