Category: Tax Treaty

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Recently enacted legislation termed “CTA” may affect your tax planning.

The recently enacted legislation is part of the National Defense Authorization Act (NDAA) enacted by Congress on January 1, 2021, through the override of a presidential veto. The NDAA is a series of federal laws primarily specifying the annual budget and expenditures of the United States Department of Defense. The NDAA for Fiscal Year 2021 includes the expansive Anti-Money Laundering Act of 2020 (AMLA). The AMLA bolsters existing anti-money laundering legislation through several amendments to the Bank Secrecy Act (BSA), which has been the primary statutory vehicle for financial institutions to assist the federal government in detecting and preventing money laundering since its passage in 1970. The amendme

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Some U.S. citizens and residents are relying on an interpretation of the U.S.-Malta Income Tax Treaty (Treaty) to take the position that they may contribute appreciated property tax-free to certain Maltese pension plans and that there are also no tax consequences when the plan sells the assets and d