U.S.-Israeli Estate Tax Planning for Dual Citizens

Reconciling U.S. and Israeli Law on Trust Taxation, Inheritance Laws, Situs Wills, and Wealth Transfers

Recording of a 90-minute CLE/CPE webinar with Q&A


Conducted on Tuesday, September 12, 2017

Recorded event now available

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Program Materials

This CLE/CPE webinar will provide estate planners with a helpful guide to estate planning tax challenges and opportunities for clients who have tax presence in both the United States and Israel. The panel will discuss the U.S. tax law and treaty provisions that govern tax rules in both Israel and the United States. The webinar will focus on Israeli tax treatment of trusts with U.S. persons as settlors and Israeli residents as beneficiaries.

Description

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 key 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, but 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 provides guidance for planning the estates of clients with U.S. and Israeli tax presence, particularly 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.

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Outline

  1. U.S. estate tax regime vs. Israeli Law of Inheritance
  2. Israeli income tax treatment of foreign trusts
  3. U.S.-Israel income tax treaties
  4. U.S. disclosure requirements
  5. Structuring and planning for trusts and transfers prior to emigration to Israel

Benefits

The panel will review these and other key issues:

  • What provisions does the Israeli Law of Inheritance make for spousal or child maintenance and how may it conflict with a testamentary document?
  • 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 to minimize the dual tax impact?

Faculty

Broide, Gidon
Gidon Broide, CPA

Managing Partner
Broide and Co.

Mr. Broide provides accounting and tax services to Israeli and foreign clients. He and the firm are specialists in the...  |  Read More

Hirsch, Debra
Debra T. Hirsch

Partner
Fox Rothschild

With more than 35 years of tax law experience, Ms. Hirsch represents clients in sophisticated estate tax planning,...  |  Read More

Akhavan, K Eli
K. Eli Akhavan
Managing Partner
Akhavan Law Group

Mr. Akhavan counsels clients on sophisticated domestic and international estate planning, including advising...  |  Read More

Seaton, Felicia
Felicia M. Seaton, Esq.

Osher Felicia International Law Office

Ms. Seaton practices U.S.-International estate planning and individual tax, U.S. probate and estate administration and...  |  Read More

Other Formats
— Anytime, Anywhere

Strafford will process CLE credit for one person on each recording. All formats include program handouts. To find out which recorded format will provide the best CLE option, select your state:

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