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High-net-worth US taxpayers, working with professional advisers, have transferred assets into personal retirement plans established in Malta to limit and potentially eliminate tax on distributions. These so-called Malta pension plans rely on a specific interpretation of the US-Malta tax treaty. This interpretation hasn’t been tested in the courts, but the IRS expressly rejected it in its clarification of the treaty in December 2021.
High-net-worth US taxpayers, working with professional advisers, have transferred assets into personal retirement plans established in Malta to limit and potentially eliminate tax on distributions. These so-called Malta pension plans rely on a specific interpretation of the US-Malta tax treaty. This interpretation hasn’t been tested in the courts, but the IRS expressly rejected it in its clarification of the treaty in December 2021.
Active and careful management is required Grace Bronstein, Ian Weinstock | Mar 24, 2021 Many trustees mistakenly believe that life insurance is a static financial instrument. However, trust-owned life insurance (TOLI) requires active and careful management. Recent case law provides a roadmap for how trustees can adequately manage TOLI pursuant to the Uniform Prudent Investor Act (UPIA).
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