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

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

Note: CPE credit is not offered on this program

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

Conducted on Thursday, August 19, 2021

Recorded event now available

or call 1-800-926-7926
Course Materials

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


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 vital 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 the estates of clients 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.



  1. Estate planning & probate for the global family involving the U.S. and Israel
  2. Israeli income tax treatment of foreign trusts
  3. U.S.-Israel income tax treaties
  4. U.S. disclosure requirements
  5. Structuring and planning before emigration to Israel


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 dual tax impact?


Akhavan, K. Eli
K. Eli Akhavan

Senior Counsel
Norton Rose Fulbright US

Mr. Akhavan focuses his practice on domestic and international estate, asset protection and tax planning for high...  |  Read More

Broide, Gidon
Gidon Broide, CPA (Israel & US), TEP

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

Fox Rothschild

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

Seaton, Felicia
Osher Felicia M. Seaton, Esq. TEP

Founding Attorney
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

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Strafford will process CLE credit for one person on each recording. All formats include course handouts.

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