Andrew Gradman

Andrew Gradman is the tax lawyer used in The leaked tapes that show how the rich avoid taxes to explain how the Malta Tax Loophole emerged from the U.S.-Malta Tax Treaty. He walks the episode through the retirement-account treaty language, Maltese account features, and why public professional discussion made the strategy look legally plausible to some participants.

The episode’s key Gradman idea is that a loophole can be a “wasting asset”: its value depends on use before the government clarifies, litigates, or closes the opening. That makes him the source’s bridge between Tax Treaty Arbitrage and [[TaxAvoidanceEvasionBoundary|the avoidance/evasion boundary]].

Source Position

• Gradman explains how treaty reciprocity around retirement accounts created the opening.
• He notes that public writing about the loophole could signal professional belief in its legal legitimacy.
• His “wasting asset” frame clarifies why high-end tax strategies can spread quickly before regulators respond.

Connections

• U.S.-Malta Tax Treaty and Malta — treaty and jurisdiction context.
• Malta Tax Loophole and Tax Treaty Arbitrage — tax-structure branch.
• Tax Avoidance-Evasion Boundary and Economic Substance Doctrine — legality and enforcement tests.
• Planet Money — source show.