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For foreign advisors

Israeli co-counsel for advisors abroad

Most of my work involves partnering with advisors abroad. You keep the client; I handle the Israeli part of the file.

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.

Worth knowing
In Israel, privilege applies to lawyers - not to accountants or tax advisors. Under section 48 of the Evidence Ordinance, a lawyer cannot be compelled to produce client communications relating to the professional service. There is no equivalent protection for an Israeli accountant or tax advisor.

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.

When advisors call

The most common scenarios

Your client is moving to Israel

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.

Your client holds Israeli employee equity

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.

Your client is leaving Israel

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.

Your client owns Israeli property

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.

Your client has unreported Israeli exposure

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.

You need an Israeli position in writing

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.

How it works

Working together

I act as Israeli counsel alongside you on the Israeli part of the file.
Registered with the Israel Tax Authority as a representative: I can file, object, appeal and deal directly with the assessing office rather than instructing someone else to do it.
Qualified in both law and accounting, ensuring the analysis and the filing are not handed back and forth between two people.
Used to working to another jurisdiction's deadlines and producing the Israeli half of a position your side can rely on.