BarbriSFCourseDetails
  • videocam On-Demand Webinar
  • signal_cellular_alt Intermediate
  • card_travel Estate Planning
  • schedule 90 minutes

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

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

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About the Course

Introduction

This CLE/CPE course will provide estate planners and tax advisers with a helpful guide to estate planning tax challenges and opportunities for clients with 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 Israel and the United States. The webinar will focus on the Israeli tax treatment of trusts with U.S. persons as settlers 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 important challenges.


Although Israel does not impose an estate tax, Israeli law imposes income tax liabilities and reporting obligations on trusts 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.

Presented By

K. Eli Akhavan
Partner
Grant Herrmann Schwartz & Klinger, LLP

Mr. Akhavan focuses his practice on tax and estate planning for high-net-worth US and non-US clients. He advises domestic and international individuals and families with respect to tax and estate planning for their US assets and beneficiaries. Mr. Akhavan also advises cross-border clients on all aspects of international estate matters, including foreign trusts, pre-immigration and expatriation planning, and on planning for the purchase of US residential and investment real property. He has considerable knowledge of the reporting requirements applicable with respect to foreign financial accounts and assets and with respect to FATCA and its global equivalent, the Common Reporting Standards (CRS). Mr. Akhavan's practice includes advising clients on the formation of private trust companies for purposes of wealth management and privacy.

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 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 families on their tax planning, working closely with top local firms in various countries. He is a qualified Israeli and US CPA with over 20 years of experience.

Adv. Shiri Malca
Partner
Shibolet Law Firm

Ms. Malca’s expertise includes litigation in all judicial instances in the civil and rabbinical courts, she has over 23 years of experience in handling complex and sensitive cases, which has provided her with extensive knowledge in all aspects of personal status (complex inheritance cases, property disputes between siblings, divorce cases, division of property, alimony, custody, immigration and child abduction, guardianship, etc.).‎ She has extensive experience in accompanying people, families and businesses at various stages, and has the skills to formulate a strategic plan tailored to the specific needs and goals of families and businesses, which includes building and carrying out a legal, family and tax strategy on an ongoing basis. Ms. Malca's expertise in drafting agreements for companies in general and for family businesses in particular, prevents the company from being exposed to intra-family disputes of its partners and arranging proper intergenerational transfer in the business, alongside providing ongoing, comprehensive and continuous consulting to ensure the continued activity of the family company even after the longevity of the founding partners, while integrating the second and third generations into the family business.‎ ‎In addition, she serves as a mediator for families and businesses, and advocates resolving disputes in general and in family disputes in particular, in alternative ways.‎

Credit Information
  • This 90-minute webinar is eligible in most states for 1.5 CLE credits.


  • Live Online


    On Demand

Date + Time

  • event

    Wednesday, December 3, 2025

  • schedule

    1:00 p.m. ET./10:00 a.m. PT

I. Estate planning and probate for the global family involving the U.S. and Israel

II. Israeli income tax treatment of foreign trusts

III. U.S.-Israel income tax treaties

IV. U.S. disclosure requirements

V. 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 impact?