Israeli tax rarely arises in isolation. It usually accompanies a US return, a UK domicile question, a trust in one jurisdiction and a company in another - often when your client says something that makes you want a second opinion from someone who actually practises here.
If the file has any historical exposure - unreported income, a residency position that may be tested, or a contemplated disclosure - who your client speaks to in Israel determines whether those conversations are protected. It is a decision too easily made by accident.
The most common scenarios
New olim and returning residents receive up to ten years of exemption on foreign income and gains - but its scope is narrower than clients often assume, and it does nothing to mitigate their home-country tax liabilities. The planning window is before the move, not after.
Section 102 has no real analogue elsewhere. The trustee route, the holding period, and what a cross-border move does to the split between employment and capital income are where most of the value - and most of the mistakes - lie.
Israeli residency does not end when the plane takes off. Severing residency triggers a filing requirement and an exit-tax charge on unrealised gains, creating a fact pattern the Tax Authority will test years later against what was actually filed.
Betterment and purchase taxes treat foreign residents differently, and reliefs are easily forfeited through poor timing. Refund claims are often available long after the transaction has closed.
Voluntary disclosure can resolve historical non-reporting and provide protection from criminal proceedings. The process is time-sensitive and highly procedural, and the order in which steps are taken matters.
I can provide a reasoned legal opinion on the Israeli tax treatment - whether for your internal file, a return position, or a treaty analysis you are running from the other side.