The close social and political ties between the United States and Israel make for significant economic migration for citizens of both countries. Many American citizens avail themselves of the "right of return" (Hok Hashvut) to emigrate to Israel and claim dual citizenship.

Estate planners and advisers serving clients contemplating emigration to Israel must know specific issues and provisions in Israeli and U.S. law governing estate and trust transfers to avoid costly tax consequences. The differences between U.S. and Israeli estate and wealth transfer rules present several important challenges.

Although Israel does not impose an estate tax, a recently passed Israeli law imposes significant Israeli income tax liabilities and reporting obligations on trusts created by a foreign person with Israeli beneficiaries.

The U.S.-Israel tax treaty allows for reciprocal credits for U.S. estate tax and Israeli taxes. Still, estate planners must reconcile the differences between the two countries' tax regimes and plan to minimize the tax impact of wealth transfers. This requires a thorough grasp of treaty provisions and recognizing the U.S. and Israeli income and gift tax implications of wealth planning transactions.

Listen as our experienced panel discusses planning clients' estates with U.S. and Israeli tax presence, focusing on Americans seeking Israeli citizenship, including interests in business entities, real estate, and financial accounts. The panel will cover the legal and tax considerations when planning for the disposition of each type of asset.

Benefits

The panel will review these and other notable issues:

• What are the considerations required to reduce the overall cost of inheritance, including relevant taxation, when there are U.S. and Israeli nexuses?
• What is the tax treatment for foreign-settled trusts with Israeli beneficiaries?
• Where are the "gap" areas in the U.S.-Israel tax treaty where income may be subject to dual taxation, and how may planners structure trust vehicles that minimize the impact?

Speakers:

Gidon Broide, CPA (Israel & US), TEP, Managing Partner, Broide and Co.
Osher Felicia M. Haleli, Esq. TEP, Founding Attorney, Osher Felicia International Law Office
K. Eli Akhavan, Partner, Steptoe & Johnson
Matthew A. Levitsky, Partner, Fox Rothschild LLP

View a recording of this webinar.