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IRS Criminal Probe Spells Uncertainty For Malta Pension Plans

By Michael Sardar, Don Fort, and Caroline Ciraolo
July 28, 2023

Malta pension plan arrangements under the U.S.-Malta income tax treaty have been a focus of the Internal Revenue Service and U.S. Department of the Treasury for more than two years.

That focus intensified recently as special agents from the IRS’ Criminal Investigation division contacted numerous individuals and entities involved in Malta pension plan arrangements in what appears to be a coordinated task force-type criminal investigation.

In addition to seeking — and in some cases, obtaining — interviews, the IRS-CI issued a flurry of administrative summonses in person and by mail to taxpayers, professional advisers, promoters and third-party record-keepers.

While clearly strategic, the IRS approach in this investigation is unusual, aggressive and likely subject to challenge.

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