Before comparing fees or strategy, confirm that the fund will onboard U.S. persons. Movingto Funds separates funds that report accepting U.S. persons from funds whose status is not confirmed. Acceptance is self-reported by each fund and not verified by Movingto. Check the live U.S.-investor fund directory for current status, then obtain written confirmation from the manager before relying on it.

FATCA changes the onboarding process

FATCA is a U.S. reporting regime for foreign financial accounts. IRS guidance says participating foreign financial institutions agree to report certain information about their U.S. accounts. For a Portugal Golden Visa fund, onboarding a U.S. person can therefore require additional classification, tax-status and reporting steps. The fund, administrator and custodian should confirm the process that applies to that specific structure.

Some funds report accepting U.S. persons, some may decline them, and many entries in the live directory have no confirmed status. An unconfirmed status is not evidence of rejection. Ask the manager or administrator for written, current confirmation before treating a fund as available.

The PFIC problem adds another layer

A non-U.S. investment may require PFIC analysis under U.S. tax law. Classification depends on the entity's facts and structure, as well as how the investor holds it. U.S. shareholders may also have Form 8621 reporting obligations. Get fund-specific advice from a qualified U.S. tax professional before subscribing.

If a fund is treated as a PFIC, a QEF election may be available only when the required information is supplied. IRS Form 8621 instructions say a PFIC must provide shareholders with a PFIC Annual Information Statement for each year to which the QEF election applies. Ask the fund whether it supplies that statement and what support it provides; do not infer QEF availability from a marketing label.

A fund ranking cannot replace written confirmation of U.S.-person onboarding or PFIC/QEF documentation.

What to verify before comparing funds

Use three distinct statuses: fund-reported yes, fund-reported no, and status not confirmed. Movingto Funds keeps those categories separate because an unknown status does not prove either acceptance or rejection. Fund policies can change, so verify the position directly before subscribing.

Before spending any time comparing investment themes or manager brands, U.S. investors should confirm three things upfront:

  • Does the fund explicitly accept U.S. persons? Not "probably" or "we've had Americans inquire before." Explicit, current confirmation.
  • Who will handle U.S.-person onboarding? Ask whether the manager, administrator or custodian performs the review, which forms it requires, and whether it has processed comparable U.S. subscriptions.
  • What documents and timing should you expect? Ask for the fund's current checklist, including any U.S. tax-status forms, identity documents and source-of-funds evidence. Get an expected timeline from the onboarding team instead of relying on a general estimate.

Only after clearing that filter does the usual comparison begin — fees, liquidity, lock-up terms, manager credibility, reporting standards. And for Americans specifically, whether the fund's PFIC position is documented and whether QEF support is available.

The bottom line

For a U.S. investor, the first filter is written eligibility. Next comes PFIC/QEF documentation and independent tax advice. Only then should fees, strategy, liquidity and manager reporting drive the comparison. Treat a status that is not confirmed as exactly that: unconfirmed.

Two practical next steps: check the live U.S.-person status directory, then read the IRS Form 8621 instructions with a qualified U.S. tax adviser. These sources help you confirm whether a fund is open to you and what tax information it can provide before you spend time on a full comparison.