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
A live 90-minute CLE/CPE webinar with interactive Q&A
Tuesday, September 12, 2017
1:00pm-2:30pm EDT, 10:00am-11:30am PDT
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.
Outline
- U.S. estate tax regime vs. Israeli Law of Inheritance
- Israeli income tax treatment of foreign trusts
- U.S.-Israel income tax treaties
- U.S. disclosure requirements
- 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?
Learning Objectives
After completing this course, you will be able to:
- Identify differences in U.S. and Israeli estate and inheritance law that may impact the U.S. estate plans of taxpayers with presence in Israel
- Determine needed steps in adjusting existing U.S. estate plan prior to emigrating to Israel or in seeking dual citizenship
- Recognize income tax impact of foreign-settled or -sitused trusts with Israeli beneficiaries
- Discern areas where the U.S.-Israel tax treaty may not protect trust assets and distributions from dual taxation
Faculty
Gidon Broide, CPA, Managing Partner
Broide and Co.,
Jerusalem, Israel
Mr. Broide provides accounting and tax services to Israeli and foreign clients. He and the firm are specialists in the fields of Israeli taxation, including taxation of trusts, individuals and corporate entities. The majority of his clients are Israelis from the Anglo-Saxon countries, mainly the US. He and his team advise multinational Jewish families on their tax planning, working closely with top local firms in various countries. He is a qualified Israeli and US CPA with 19 years of experience.
Debra T. Hirsch, Partner
Fox Rothschild,
Morristown, N.J. and New York
With more than 35 years of tax law experience, Ms. Hirsch represents clients in sophisticated estate tax planning, charitable planning, preparation of wills and trusts and estate administration. She has a particular focus on advising individuals and fiduciaries on certain matters involving the United States and Israel, such as U.S. estate planning for dual citizens who are residents of Israel, and tax issues involving U.S. citizens who have children or grandchildren in Israel, particularly in connection with recent changes to the Israeli trust income tax law.
K. Eli Akhavan, Managing Partner
Akhavan Law Group,
New York
Mr. Akhavan counsels clients on sophisticated domestic and international estate planning, including advising high-net-worth individuals on their tax, wealth preservation and estate planning needs. He also provides guidance on business succession planning, asset protection trusts, and charitable planning. Prior to forming his current firm, he represented clients on matters concerning asset protection planning, business succession planning, income taxation and charitable gifting and counseled clients on complex partnerships, joint ventures and general taxation matters. He is a is a widely published author and frequent speaker on estate planning issues.
Felicia M. Seaton, Esq.
Felicia Seaton Law,
Jerusalem, Israel
Ms. Seaton practices U.S.-International estate planning and individual tax, U.S. probate and estate administration and tax. She has 20 years’ experience advising dual citizens, Israelis and green card holders regarding U.S. tax issues and renunciation of US citizenship and green cards.
Live Webinar
Live Webinar $297.00
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This webinar is eligible for at least 1.5 general CLE credits.
CLE credits are not available for PR.
*In KS, OH, PA, for more than 1 attendee on the connection you must contact Strafford CLE via email or call 1-800-926-7926 ext. 35 prior to the program for special instructions.
CPE on Live Event
Continuing Professional Education credit processing is available for an additional fee per person. You may register for CPE credit processing at any time before or after the program. To qualify for CPE you may not listen via the telephone.
This program is eligible for 1.5 CPE credits.
- Field of Study: Taxes.
- Level of Knowledge: Intermediate.
- Advance Preparation: None.
- Teaching Method: Seminar/Lecture.
- Delivery Method: Group-Internet (via computer).
- Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of verification codes announced throughout the presentation.
- Prerequisite: Three years+ business or public firm experience at mid-level within the organization, drafting wills and trust documents, supervising other attorneys or estate planners. Specific knowledge of concepts regarding taxation of foreign investments held by U.S. taxpayers; familiarity with tax treaty provisions.
NOTE: CPE credit processing for all attendees must be ordered by 2pm Eastern the day of the program to receive a Certificate of Attendance within 24 hours.
Recordings
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Customer Reviews
The seminar was very informative and easy to understand.
Amy Allison
Anderson Hunter Law Firm
The webinar offered excellent insight into some specific areas.
Beth Ann R. Lawson
Virginia Beach Law Group
I thought the information provided was great.
Erika Gamiz
Law Offices of Marcia L Kraft
Better than I expected. Well done on both subject matter and production quality.
Jeff Simpson
Gordon, Fournaris & Mammarella
The program was well organized and discussed the major issues.
Roxy Hammett
Wolff & Samson
Estate Planning Advisory Board
Principal and Founder
Altman & Assoc.
Brian M. Annino
Partner
Annino Law Firm
Member
Franklin Karibjanian & Law
Partner and Practice Group Leader - Tax
Waller Lansden Dortch & Davis
Consultant, Speaker and Author
The University of Toledo Foundation
Partner
Windels Marx Lane & Mittendorf
Atty
Donna J. Jackson, Attorney at Law
Member
Giarmarco Mullins & Horton
Edwin P. Morrow, III, Esq.
Senior Wealth Specialist
Key Private Bank Wealth Advisory Services
Atty
The Tippett Law Firm
Partner
Perkins Coie
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