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 PRO COURSES
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PFIC Exposure Diagnostic

     
Your Offshore Fund Investment
could be defaulted to Excess Distribution tax treatment if your
QEF Election is based on a faulty
PFIC Annual Information Statement
     

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Start a PFIC Exposure Diagnostic
Tax exposure may approach or
exceed a 55% effective tax rate.

This can be overwhelming.
I understand.

Book a precision call to determine if a PFIC/CFC exposure diagnostic is your best next move.

 

A fast overview of the fund's portfolio and reporting. Land on high risk or low risk of CFC exposure and PFIC QEF validity. 30 minutes.

 
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Reserve .5 hour
 

A more in depth review of the fund's portfolio and reporting. Time for questions, explanations, and assessing next best steps. 60 minutes.

 
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Reserve 1 hour
We'll look at your position and existing documentation together. I'll explain things in plain language so you can make informed decisions. Data review, not tax advice.
OUR SERVICES

How we can work together

We offer a three-step support series.
You can take it one step at a time.

PFIC Exposure Diagnostic

We review the fund’s accounting records, portfolio holdings, and PFIC Annual Information Statements to assess whether a QEF election is supportable. The diagnostic documents where underlying data is missing or flawed and establishes the historical period of § 1291 exposure. This report forms the factual basis for subsequent tax modeling and decision making by investors or their advisors.
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Tax Impact
Modeling

Once the reporting posture is established, our CPA partner quantifies the tax and interest impact under § 1291 for your actual holding period and compares it to the tax that would apply under QEF treatment using the same timeline. This produces a defensible tax differential, which serves as the evidentiary measure of financial impact for planning discussions with counsel or advisors.
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Reserve

Deemed Sale Coordination

If you and your tax advisor decide that a corrective filing is appropriate, our CPA partner prepares the Deemed Sale election and related Form 8621 filings. A Deemed Sale may eliminate historical § 1291 exposure and allow QEF treatment going forward, depending on the fund’s ability to support a QEF election. Not all funds benefit from this approach; suitability is determined with your advisor.
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Request

Where to Start

 
Take charge of your
tax exposure with a
PFIC Exposure Diagnostic
 

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Start a PFIC Exposure Diagnostic

​​​​​​​Purpose
  • To determine whether a U.S. investor’s QEF election is supportable under Treasury Regulation 1.1295-1(g), based on the fund’s actual PFIC Annual Information Statements and inspection of fund books and records.

Scope
  • Review PFIC Annual Information Statement format and content
  • Review fund's books and records including portfolio assets and investor roster
  • Determine whether a QEF election is supportable
  • Determine whether there is Controlled Foreign Corporation tax exposure
  • Provide a written reporting posture summary and documentation file for CPA use

Outcome 
  • A clear reporting posture: either supportable QEF treatment or a documented basis that the investment is currently positioned under section 1291 Excess Distribution rules.
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Terms
  • Prices are per fund per tax year.
  • Work depends on timely delivery of accounting records from the fund and must begin at least 21 days before report deadlines.
  • Funds are often reluctant to share data, causing delays.
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The Next step The Next Step

Quantify your tax exposure with an Evidentiary Damages Calculation

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Reserve The Evidentiary Damages Calculation

Purpose
  • To quantify the difference between section 1291 Excess Distribution tax and interest for the holding period and the tax that would apply under a supportable QEF election.

Scope
  • ​​​​​​​Convert historical fund accounting to U.S. tax reporting format
  • Identify the investor’s holding period and the fund’s holding period in impacted assets
  • Calculate tax under section 1291 (highest marginal rates and daily compounding interest)
  • Calculate tax under a QEF election using the investor’s ordinary income and capital gains rates
  • Provide written documentation summary suitable for CPA and legal use

Outcome
  • A personalized, evidentiary tax differential figure that reflects the investor’s specific holding period, tax profile, and fund portfolio. This figure is used for tax planning and may support legal or financial claims where relevant.

Pricing
  • estimated $10,000 - $20,000 per fund per tax year
  • Priority services available

Terms
  • Pricing is per fund, per tax year and varies by fund conditions
  • Work depends on timely delivery of fund accounting records and PFIC AIS
  • Documents must be received at least 21 days before the report deadline
  • Calculations and reporting work are performed by an independent CPA experienced in PFIC and CFC reporting
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The Next step Deemed Sale Elections

Purge the PFIC Taint and support a valid QEF election via a
Deemed Sale Election

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Request Deemed Sale Election Support

Purpose
  • To position the investment for a supportable QEF election in subsequent tax years by coordinating a Deemed Sale Election and associated reporting.

Scope
  • Use the accounting outputs from the Evidentiary Tax Differential Calculation
  • Determine the tax due under section 1291 for the historical holding period, including applicable interest
  • Prepare the tax return and Deemed Sale Election filings
  • Elect QEF treatment for subsequent tax years
  • Provide calculations and supporting documentation for CPA use or, if engaged, complete tax return preparation

Outcome:
  • A Deemed Sale Election that closes the historical section 1291 period and positions the investment for QEF reporting going forward, subject to ongoing fund disclosures.

Pricing 
  • By request, based on availability and suitability of conditions.

Terms
  • Pricing is per fund, per tax year
  • Work depends on timely delivery of fund accounting records and required PFIC information
  • Documents must be received at least 21 days before return filing deadlines
  • All tax calculations and filings are performed by an independent CPA experienced in PFIC reporting
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Disclaimer

This material has been prepared for information and educational purposes only. It is not intended to provide, nor should it be relied upon for tax, legal, or investment advice. Each investor should consult appropriate tax, legal, and financial professionals regarding individual circumstances.

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