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
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.
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?
Faculty

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
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.
Close
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
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.
CloseK. Eli Akhavan
Managing Partner
Akhavan Law Group
Mr. Akhavan counsels clients on sophisticated domestic and international estate planning, including advising... | Read More
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.
Close
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
Ms. Seaton practices U.S.-International estate planning and individual tax, U.S. probate and estate administration and tax. She has over 20 years’ experience advising dual citizens, Israelis and green card holders regarding U.S. inheritance and tax issues, and renunciation of U.S. citizenship and green cards.
Close