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

Webinar: ID# 1026354
Recorded CD or On-Demand
About This Course:
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.

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.

  • 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

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
How To Access Course And Materials

Handout materials and the phone number for live presentations are made available to you one day prior to the event via email from the presenter. Copies of the presentations are included with recorded versions.
If you order a recorded version of the webinar, CDs will be mailed out approximately 10 days after the live event. Shipping is included in the price of recorded versions.

Continuing Education Credits Available

This program has been approved for 2.0 CPE hours through Strafford Publications. To obtain CPE credit, attendees must participate in the live event (recorded versions do not qualify for credit), return an Official Record of Attendance to Strafford affirming their participation (including the CPE code announced during the program), and pay a processing fee of $35 per person.

Strafford will mail a certificate of credit within approximately two weeks of receiving your completed Official Record of Attendance, provided all required conditions have been satisfied.

Strafford is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit.
U.S.-Israeli Estate Tax Planning for Dual Citizens
Available on CD or On-Demand formats
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