I am not an accountant but do have a pretty good understanding of how the US tax code works with respect to PFIC investments and investments in general. I think what Bradley is asking in his original post is whether any expenses incurred in getting the GV are tax-deductible (i.e. can be used to offset income), and in this respect my personal opinion is that they cannot, except perhaps for those who took loans to make their investment and have deductible investment interest.
What I think will probably work (and again this is in no way tax advice) is to track the investment-related expenses for the duration of your holding period, and add them to your cost basis as you go. In my opinion this would be things like initial setup commissions paid to the fund sponsor (but probably not annual fees or performance fees), fees paid to the bank that holds your funds, and any income that was not actually received but that you had to pay taxes on (seems fairly common based on the funds I’m in). In this way you are reducing your future capital gain liability when you go to sell your PFIC shares, but you can’t really get any benefits “as you go”. That’s my understanding of how the PFIC election works at the federal level, though it may vary depending on your state. It is intended to be a punitive tax regime for US investors, after all.
On the topic of whether PT trip and/or biometric appointment expenses are deductible, I’m sure some of the more aggressive accountants out there will sign off on that, but I for one would not like to be under the IRS microscope if I were audited and the auditor asked “were these expenses really required in making the investment, or were they personal in nature”. Basically, consider if you were an investor in the fund who wasn’t seeking a GV - would they incur these expenses as a necessary part of their investment, or are they basically particular to your case since you are also aiming for PR or Citizenship?
If you bought actual real estate in Portugal, it’s more possible that these things could fly. I’m not as clear on the rules for actively managed rental real estate but know they allow more than passive investments. Either way, for those who invested in funds I personally do not think anything other than standard-fare investment-related expenses will actually hold up in an audit.
Would be curious to know what more knowledgeable members of the forum would have to say on the matter, in particular @jb4422 who has had plenty of helpful input on US tax issues in the past, but I also know that there have been various US-tax related contributions from other users in this thread: PFIC For US Citizens