Explore Our Services

Bespoke private client strategy calls that orient U.S. investors to the risks and implications of investing in Golden Visa offerings.

We will establish your objectives, timelines, and risk tolerance, and we will clarify the common, opaque, and layered risks for you and your advisors.

30 Minute | 60 Minute

Investors who desire more than a spot-check on key questions are invited to inquire about Private Client Support.

Funds, Holding Companies, Start-Ups:

Many offshore funds, holding companies, and some start-ups meet the definition of Passive Foreign Investment Company (PFIC) for U.S. tax purposes. A smaller subset meet the definition of a Controlled Foreign Corporation (CFC) for U.S. tax purposes.

Whether your offshore investment is eligible to be taxed in the U.S. under a valid QEF election or whether it might default to taxation under section 1291 Excess Distribution rules depends on whether the Passive Foreign Investment Company (PFIC) regime is in force for your subscription or whether the Controlled Foreign Corporation (CFC) regime is in force. We investigate your exposure.

• If the fund is a CFC, we determine whether you meet the definition of a U.S. shareholder of a CFC for your subscription and tax year.

• If the PFIC regime is in force for your subscription and tax year, we determine whether a QEF election is supportable based on the fund’s actual reporting. We investigate underlying data and whether the fund’s reporting on PFIC Annual Information Statements fully meet U.S. requirements. We identify structural flaws that could invalidate the PFIC AIS for U.S. tax purposes. 

This clarity allows you and your tax advisor to understand the reporting posture and evaluate the available paths forward.

Real Estate Development Projects

Many offshore real estate development projects offer fractional deed sales with what they call a “guaranteed buy-back” after a number of years. These promoters also sometimes offer creative solutions to entice prospective investors including:

• Covering the investors transaction costs and associated tax obligations

• Paying an “upfront yield” to the investor that effectively lowers the investor’s immediate out-of-pocket cash outlay when making the investment

• Payment of a low rate of interest to the investor either annually or in the event that the fractional deed isn’t met with a “buy-back” on the agreed upon timeline.

U.S. investors in these offers are likely to trigger original issue discount (OID) tax exposure. Even if the offshore investment is in a fractional real-estate deed, the investment vehicle may more closely resemble a below-market-rate loan than a real estate purchase. OID will discount the initial value of the investment by an amount that is equivalent to the value of applicable federal rate (AFR) interest over the lifetime of the holding. U.S. taxpayers are meant to make annual ordinary income inclusions equivalent to that year’s portion of the interest.

Actionable reports are suitable for reliance by counsel and CPAs.

A focused advisory engagement for U.S. investors assessing Golden Visa programs and offers in Portugal, Italy, or Greece.

Designed to bring regulatory clarity, uncover risk, assess U.S. tax risk across PFIC, CFC, IRA, OID, and grantor trust exposure, optimize FX conditions, and support strategic decision making about offers in markets where compliant offers are limited from a U.S. perspective.

While Golden Visa Direct primarily supports U.S. taxpayers evaluating qualifying investments for residency by investment programs, we also provide consulting to a limited number of issuers seeking to approach the U.S. market in compliance with U.S. law. The work focuses on U.S. regulatory requirements, U.S. tax positioning and compliant reporting, investor-facing credibility, and market intelligence.

This is not a capital-raising engagement.

U.S. Securities Law: Support in assessing which U.S. exemptions apply, what forms the fund must file, and how to maintain a compliant posture when interests are offered to U.S. investors.

U.S. Tax Compliance: Advisory on the U.S. tax characterization of offshore funds and other offers and the implications for U.S. subscribers, including how offering design choices affect reporting, classification, and long term investor outcomes.

Includes evaluation of proposed or existing portfolio holdings for PFIC status, CFC status, and look through complications, including guidance on how those exposures interact with U.S. investor reporting obligations.

CFC and PFIC Remediation: Structured guidance for fund level remediation of CFC and PFIC exposure, including identification of reporting gaps, correction of investor level tax reporting, preparation for deemed sales (as appropriate), and creation of reporting that meets regulatory standards to support a valid QEF election.

Includes evaluation of fund manager issued PFIC Annual Information Statements and the underlying preparation methods.

U.S. Investor Readiness Assessment: A pre-market review of whether the offer’s regulatory posture, documentation, reporting capabilities, governance, and service providers are compliant for subscribing U.S. investors without exposing the issuer to avoidable compliance or reputational risks.

Service Provider Selection: Introductions to registered U.S. private placement agents or U.S. tax, audit, and compliance providers suited to make regulatory filings, prepare CFC/PFIC aligned tax reporting, or prepare financial statements suitable for U.S. investors.

U.S. Market Intelligence: A limited retainer for issuers that want ongoing visibility into U.S. regulatory trends, tax developments, and investor expectations that directly affect viability for subscribing U.S. investors. The focus is on high level interpretation of cross border risks, emerging enforcement patterns, and structural themes, not on fund specific marketing or investor outreach. Designed for managers who want to stay ahead of U.S. complexity without carrying a full time specialist.