Withers' Special Counsel Richard LeVine was featured in the recent Wall Street Journal article, "Quirks in a U.S. Treaty With Malta Turn Into a Tax Play," which discusses the implications of Malta Pension Plans in the wake of looming tax proposals from the Biden administration.
Richard explains to the Wall Street Journal that this strategy comes with caveats and "to be free of U.S. tax, the payouts under the U.S.-Malta treaty must also comply with the treaty's overall conception of a pension." Richard adds that in addition to an IRS crackdown, the Treasury Department could seek changes to the Malta treaty. Congress could also move to limit benefits.
For those subscribed to the Wall Street Journal, the full article can be read here. Please note a subscription is required.