Program Details
2026-04-29 13:00:00
Over 1,000+ webinars
Course Overview
2026-04-29 13:00:00
2h CLE Credits
Intermediate
2
1:00 pm - 1:10 pm ESTSecurities law may treat Golden Visa fund investors as victims while tax law could simultaneously treat them as reckless. Learn how both positions can coexist and what that means for your clients.
Amy Short 1:10 pm - 1:20 pm ESTIdentify why IFRS-based Annual Information Statements fail U.S. tax standards, how invalid QEF elections expose clients to punitive Excess Distribution taxation, and what practitioners must do to correct course.
Amy Short 1:20 pm - 1:30 pm ESTExamine how transient U.S. Shareholder status and untested cap tables create hidden CFC exposure, triggering compounding Form 5471 penalties at both the fund and portfolio levels.
Amy Short 1:30 pm - 1:40 pm ESTLearn how omnibus custody arrangements could trigger foreign grantor trust classification, creating overlooked Form 3520 and 3520-A reporting obligations with significant penalty exposure for your clients.
Amy Short 1:40 pm - 1:55 pm ESTTrace the Safeco-Horowitz-Reyes doctrinal chain and understand how the objective recklessness standard developed in FBAR cases could extend into broader Title 26 civil penalty arguments.
Amy Short 2:05 pm - 2:25 pm ESTAnalyze how divergent decisions across circuits in three landmark cases are simultaneously rejecting and confirming IRS authority to assess and collect international information return penalties and identify which procedural defenses remain viable for your clients today.
Amy Short 2:25 pm - 2:35 pm ESTUnderstand how SEC enforcement actions against non-compliant foreign fund offerings destabilize investor positions and generate direct IRS audit triggers that practitioners must anticipate and proactively address.
Amy Short 2:35 pm - 2:50 pm ESTExamine how self-directed IRA investments in Golden Visa funds create prohibited transaction risk and FATCA reporting misrepresentations, compounded by structural titling problems unique to civil law jurisdictions.
Amy Short 2:50 pm - 3:00 pm ESTLearn how the Koopman appointment is expected to collapse the traditional separation between civil audits and criminal referrals at the Service, accelerating escalation risk for clients with unresolved reporting compliance issues for offshore holdings.
Amy Short 3:00 pm - 3:10 pm ESTMaster the remediation toolkit, including retroactive QEF elections under Rev. Proc. 2026-10, the Section 6511 refund window, and documenting independent diligence as a defense against willfulness findings.
Amy ShortAmy Short is the Principal of PFIC Help by Golden Visa Direct, a forensic tax exposure diagnostic practice that serves U.S. investors in Portuguese Golden Visa funds and comparable offshore structures. She holds a Series 7 registration with FINRA, is an MS in Taxation candidate, and is a dual U.S. and Portuguese citizen. Her practice investigates across tax, securities, custody, and cross-border operations to map failure points at the boundaries between systems, uncovering structural deficiencies in how foreign funds sell and report to U.S. investors. She does not prepare tax returns or provide legal advice; she provides the forensic analysis that sits upstream of both. As a FINRA-regulated placement agent, she spent years offering Portuguese funds a compliant path into the U.S. market before concluding that the industry’s resistance to U.S. regulatory constraints made the market structurally dangerous for American investors. That resistance was a bellwether for the tax failures plaguing the market today. She now provides independent forensic diagnostics, CPA and counsel briefings, and expert analysis for U.S. investors and their advisors.
Amy Short is the Principal of PFIC Help by Golden Visa Direct, a forensic tax exposure diagnostic practice that serves U.S. investors in Portuguese Golden Visa funds and comparable offshore structures. She holds a Series 7 registration with FINRA, is an MS in Taxation candidate, and is a dual U.S. and Portuguese citizen. Her practice investigates across tax, securities, custody, and cross-border operations to map failure points at the boundaries between systems, uncovering structural deficiencies in how foreign funds sell and report to U.S. investors. She does not prepare tax returns or provide legal advice; she provides the forensic analysis that sits upstream of both. As a FINRA-regulated placement agent, she spent years offering Portuguese funds a compliant path into the U.S. market before concluding that the industry’s resistance to U.S. regulatory constraints made the market structurally dangerous for American investors. That resistance was a bellwether for the tax failures plaguing the market today. She now provides independent forensic diagnostics, CPA and counsel briefings, and expert analysis for U.S. investors and their advisors.
Requirements
The Alabama State Bar MCLE Commission requires attorneys to complete 12 credits, including 1 ethics, by December 31 of each year. All credits must be reported by February 15 of the following year. A maximum of 12 credits, including 1 ethics credit, may be carried over for 1 year only.
Formats
