In recent years, U.S. taxpayers have engaged in “Malta pension plans,” utilizing these arrangements to contribute appreciated assets and claim tax exemptions under the U.S.-Malta tax treaty. Nevertheless, the U.S. government has responded with measures, including the Competent Authority Arrangement (CAA) and proposed regulations, aiming to restrict treaty benefits due to suspected misuse and potential tax evasion. Participants now face compliance risks, including penalties and potential criminal investigations. To rectify their tax status, individuals have several avenues available, such as participating in voluntary disclosure programs, using streamlined filing compliance procedures, opting for a quiet disclosure, or choosing to take no immediate action, each carrying distinct risks amidst heightened IRS scrutiny.
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