IRS Visits to Wealthy Americans Drive Malta Pension Probe (1)

One morning in late June, criminal agents from the Internal Revenue Service made unannounced visits to dozens of wealthy Americans. They carried summonses and wanted to ask about pension plans in Malta on the IRS “Dirty Dozen” scams list.

But several tax lawyers said agents may have gone too far by looking for crimes in transactions that promoters promised were permissible under a 2011 US-Malta tax treaty.

“It is hard to see anything criminal in claiming tax benefits pursuant to a textual reading of the treaty, so it seems unlikely that most participants have any real criminal exposure,” said Tom ...