Course Overview
Attorneys will learn how a single Golden Visa fund investment can simultaneously trigger PFIC, CFC, foreign grantor trust, FBAR, SDIRA, and ERISA exposure.
Attorneys will gain a framework for evaluating client exposure across multiple overlapping tax regimes and understanding remediation pathways including retroactive QEF elections under Rev. Proc. 2026-10.
Attorneys will learn how a single Golden Visa fund investment can simultaneously trigger PFIC, CFC, foreign grantor trust, FBAR, SDIRA, and ERISA exposure.
Attorneys will gain a framework for evaluating client exposure across multiple overlapping tax regimes and understanding remediation pathways including retroactive QEF elections under Rev. Proc. 2026-10.
Agenda
Session 1
The Victim Becomes Violator Paradox
Session 2
PFIC Statement Deficiencies and Invalid QEF Elections
Session 3
CFC Exposure and Form 5471 Penalties in Golden Visa Funds
Session 4
Foreign Grantor Trust Risk and Form 3520 Triggers
Session 5
The Objective Recklessness Standard and FBAR Willfulness
Session 6
Penalty Assessment After Farhy, Mukhi, and Jarkesy
Session 7
The SEC Cross-Border Task Force and IRS Audit Triggers
Session 8
SDIRA Prohibited Transactions and FATCA Misrepresentations
Session 9
The Koopman Appointment and the IRS Civil-Criminal Enforcement Wall
Session 10
Remediation Pathways and Willfulness Defense Strategies
1:00 pm - 1:10 pm EST
PFIC Help by Golden Visa Direct
Securities 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.
PFIC Help by Golden Visa Direct
1:10 pm - 1:20 pm EST
PFIC Help by Golden Visa Direct
Identify 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.
PFIC Help by Golden Visa Direct
1:20 pm - 1:30 pm EST
PFIC Help by Golden Visa Direct
Examine 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.
PFIC Help by Golden Visa Direct
1:30 pm - 1:40 pm EST
PFIC Help by Golden Visa Direct
Learn 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.
PFIC Help by Golden Visa Direct
1:40 pm - 1:55 pm EST
PFIC Help by Golden Visa Direct
Trace 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.
PFIC Help by Golden Visa Direct
2:05 pm - 2:25 pm EST
PFIC Help by Golden Visa Direct
Analyze 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.
PFIC Help by Golden Visa Direct
2:25 pm - 2:35 pm EST
PFIC Help by Golden Visa Direct
Understand 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.
PFIC Help by Golden Visa Direct
2:35 pm - 2:50 pm EST
PFIC Help by Golden Visa Direct
Examine 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.
PFIC Help by Golden Visa Direct
2:50 pm - 3:00 pm EST
PFIC Help by Golden Visa Direct
Learn 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.
PFIC Help by Golden Visa Direct
3:00 pm - 3:10 pm EST
PFIC Help by Golden Visa Direct
Master 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.
PFIC Help by Golden Visa Direct
SESSION I
Deposing trucking company personnel…
SESSION II
Defending the Company. Effective Deposition …
SESSION III
Defending the Company. Effective Deposition …
SESSION IV
Defending the Company. Effective Deposition …
2:00 – 3:00 PM EST
In trucking accident litigation, plaintiff attorneys must strategically depose key company personnel to uncover negligence, regulatory violations, and systemic misconduct.
This session provides practical deposition strategies to hold carriers accountable and maximize case value. From frontline drivers to senior executives, attendees will learn how to ask precise questions that expose operational lapses, reveal liability patterns, and strengthen plaintiff claims.
Participants will gain tools to challenge unsafe company cultures, evaluate inadequate training and hiring, and document compliance gaps that often lead to catastrophic incidents.
2:00 – 3:00 PM EST
In trucking accident litigation, plaintiff attorneys must strategically depose key company personnel to uncover negligence, regulatory violations, and systemic misconduct.
This session provides practical deposition strategies to hold carriers accountable and maximize case value. From frontline drivers to senior executives, attendees will learn how to ask precise questions that expose operational lapses, reveal liability patterns, and strengthen plaintiff claims.
Participants will gain tools to challenge unsafe company cultures, evaluate inadequate training and hiring, and document compliance gaps that often lead to catastrophic incidents.
2:00 – 3:00 PM EST
In trucking accident litigation, plaintiff attorneys must strategically depose key company personnel to uncover negligence, regulatory violations, and systemic misconduct.
This session provides practical deposition strategies to hold carriers accountable and maximize case value. From frontline drivers to senior executives, attendees will learn how to ask precise questions that expose operational lapses, reveal liability patterns, and strengthen plaintiff claims.
Participants will gain tools to challenge unsafe company cultures, evaluate inadequate training and hiring, and document compliance gaps that often lead to catastrophic incidents.
2:00 – 3:00 PM EST
In trucking accident litigation, plaintiff attorneys must strategically depose key company personnel to uncover negligence, regulatory violations, and systemic misconduct.
This session provides practical deposition strategies to hold carriers accountable and maximize case value. From frontline drivers to senior executives, attendees will learn how to ask precise questions that expose operational lapses, reveal liability patterns, and strengthen plaintiff claims.
Participants will gain tools to challenge unsafe company cultures, evaluate inadequate training and hiring, and document compliance gaps that often lead to catastrophic incidents.
speakers
A 2013 graduate of the Gerry Spence Trial Lawyers College in Dubois, Wyoming, Joe is rated AV Preeminent™ by Martindale-Hubbell — the highest peer rating for exceptional legal ability and ethics. He is among the first nine attorneys nationwide to earn board certification in Truck Accident Law from the National Board of Trial Advocacy.
Joe received the Roadway Safety Award from the American Association for Justice (AAJ) for his commitment to improving highway safety. He currently serves as Co-Chair of the Academy of Truck Accident Attorneys (ATAA) Safety Committee, advocating for higher safety standards across the trucking industry.
Joe serves on the faculty of the AAJ Advanced Trial Advocacy College: Litigating Truck Collision Cases (2015 & 2024). He is an active member of AAJ’s Trucking Litigation Group and sits on the Board of Regents for the Academy of Truck Accident Attorneys.
Joe frequently consults and co-counsels on complex commercial truck cases. His proven track record includes numerous successful trials against motor carriers and truck leasing companies — delivering justice for victims of commercial vehicle accidents.
A 2013 graduate of the Gerry Spence Trial Lawyers College in Dubois, Wyoming, Joe is rated AV Preeminent™ by Martindale-Hubbell — the highest peer rating for exceptional legal ability and ethics. He is among the first nine attorneys nationwide to earn board certification in Truck Accident Law from the National Board of Trial Advocacy.
Joe received the Roadway Safety Award from the American Association for Justice (AAJ) for his commitment to improving highway safety. He currently serves as Co-Chair of the Academy of Truck Accident Attorneys (ATAA) Safety Committee, advocating for higher safety standards across the trucking industry.
Joe serves on the faculty of the AAJ Advanced Trial Advocacy College: Litigating Truck Collision Cases (2015 & 2024). He is an active member of AAJ’s Trucking Litigation Group and sits on the Board of Regents for the Academy of Truck Accident Attorneys.
Joe frequently consults and co-counsels on complex commercial truck cases. His proven track record includes numerous successful trials against motor carriers and truck leasing companies — delivering justice for victims of commercial vehicle accidents.
A 2013 graduate of the Gerry Spence Trial Lawyers College in Dubois, Wyoming, Joe is rated AV Preeminent™ by Martindale-Hubbell — the highest peer rating for exceptional legal ability and ethics. He is among the first nine attorneys nationwide to earn board certification in Truck Accident Law from the National Board of Trial Advocacy.
Joe received the Roadway Safety Award from the American Association for Justice (AAJ) for his commitment to improving highway safety. He currently serves as Co-Chair of the Academy of Truck Accident Attorneys (ATAA) Safety Committee, advocating for higher safety standards across the trucking industry.
Joe serves on the faculty of the AAJ Advanced Trial Advocacy College: Litigating Truck Collision Cases (2015 & 2024). He is an active member of AAJ’s Trucking Litigation Group and sits on the Board of Regents for the Academy of Truck Accident Attorneys.
Joe frequently consults and co-counsels on complex commercial truck cases. His proven track record includes numerous successful trials against motor carriers and truck leasing companies — delivering justice for victims of commercial vehicle accidents.
PFIC Help by Golden Visa Direct
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.
PFIC Help by Golden Visa Direct
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.
Plans
| Access type | Individual Purchase | Basic | Premium Most Popular | Corporate CLE Plan |
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| Price |
$95 – $245
Price varies based
on the course duration of 1 to 3+ hours |
$395/year
One-time purchase
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$495/year
One-time purchase
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Custom
based on firm size
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| Access type | Pay per class | Unlimited annual access | Unlimited annual access | Unlimited access for all firm members |
| Number of Available Webinars | 1 | 1,000+ | 1,000+ | 1,000+ |
| Number of New Webinars Added Yearly | Limited | 500+ | 500+ | 500+ |
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Special credits (Ethics, Elimination of Bias, etc.) |
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| Bootcamps |
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| Access type |
Pay per class |
|---|---|
| Number of Available Webinars | 1 |
| Number of New Webinars Added Yearly | Limited |
| Earn "Live" CLE credit |
|
|
Ability to Ask Questions During the Presentation via a Chat Box |
|
| Attend "Live" Re-Broadcasts |
|
| Exclusive Partner Webinars & Events | |
|
Special credits (Ethics, Elimination of Bias, etc.) |
|
| Instant Certificates After Completion | |
| Personalized CLE Platform | |
| Live Conferences | |
| Bootcamps |
Why Attend
Being an attorney is hard enough without the bookkeeping/IOLTA nonsense. Ready to keep more of what you earn? Whether you’re launching a new law practice or been in your own practice for forty years, this program is your roadmap to slashing your tax bill and building real wealth. Want to write off that second home, or discover how to deduct your vacation? In this dynamic, eye-opening session, civil and criminal tax controversy attorney Eric Green will walk you through often-overlooked strategies to dramatically cut taxes, increase deductions, and protect your law practice from IRS audit adjustments. You’ll walk away armed with actionable insights you can put to work immediately and easily earn back 8-10X what you invested in this seminar!
The program will cover not just how to deduct these expenses but what documentation you need to maintain to make sure you are audit proof if Uncle Sam comes calling!
In this new expanded webinar, Eric and Leighanne will review other benefits like converting your practice to an S Corporation, retirement planning and discuss apps that can help tie all this together and make your record keeping a breeze!
Who Should Attend:
Don’t miss this opportunity to transform the way you think about taxes—and take home the tools you need to save thousands year after year.
Key topics to be discussed:
Closed-captioning available
2026-06-19 13:00:00
This program begins with the foundations of generative AI, introducing large language models and transformer architecture, then moves into practical applications for legal professionals. Participants will learn how to design and deploy custom GPTs in OpenAI and build agent-based automations in Microsoft Copilot, both of which enable legal teams to streamline repetitive work across transactional matters, litigation management, and broader legal operations. The program also highlights how to use OpenAI projects and Microsoft’s integrated tools to scale and organize AI-driven efficiencies across the legal function.
Key topics to be discussed:
Date / Time: December 19, 2025
Closed-captioning available
2025-10-30 14:00:00
Session I – Considerations: Revocable vs. Irrevocable – Georgia Bender
In this session, attorney Georgia Bender will present a brief analysis of the structures and considerations involved in revocable and irrevocable trusts and when each type of trust may be appropriate. Next, Ms. Bender will go into a broad discussion of revocable trusts and the advantages they bring in flexibility of administration, probate avoidance, and estate tax planning. She’ll then review who might be an ideal candidate for this type of trust.
Key topics to be discussed:
Session II – Irrevocable Trusts and Trust Administration – Joseph Donohue
In this session, Attorney Joseph Donohue will review four common types of irrevocable trusts and the contexts in which they are best used. Next, Mr. Donohue will offer some helpful drafting tips for trusts. Lastly, he will dive into topics surrounding trust administration from tax reporting to key phases, avoiding trust contests, and drafting documents to protect your fiduciary clients.
Key topics to be discussed:
Date / Time: December 11, 2025
Closed-captioning available
2026-06-05 14:00:00
FAQ
Yes — the Basic Unlimited Pass gives members access to all online live, replay, and on-demand CLEs, excluding only the live conferences. With the Premium Unlimited Pass, members receive access to over 11 multi-day live conferences as well.
Yes — myLawCLE is an officially accredited CLE provider and seeks CLE approval in all 50 states. Our live webinars, on-demand programs, and replays meet or exceed state bar requirements, ensuring your CLE credits are fully recognized wherever you practice.
Yes — after completing the CLE webinar, attendees select their state for CLE credit and fill out an online evaluation form. Once submitted, a CLE certificate is emailed to them and uploaded to their dashboard.
Yes — myLawCLE develops CLE programs meeting all required CLE types, including mental health, ethics, professionalism, technology, substance abuse, and elimination of bias.
myLawCLE maintains all CLE programs in its library for 12 months following the original broadcast date. Attendees can access any program that remains available in the system during this period.
Yes — all of myLawCLE’s programs are originally broadcast live, with a chat box available for attendees to submit questions during the webinar. Additionally, replays and on-demand versions offer email correspondence with the presenters for any follow-up questions.
Expand Your Legal Expertise
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
