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For foreign advisors

Israeli co-counsel for advisors abroad

Most of my work already runs alongside advisors abroad. You keep the client; I take the Israeli part of the file.

Israeli tax rarely arrives on its own. It turns up attached to a US return, a UK domicile question, a trust in one jurisdiction and a company in another - and usually at the point where your client says something that makes you want a second opinion from someone who actually practises here.

Worth knowing
In Israel, privilege attaches to lawyers - not to accountants or tax advisors. Under s.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 historic exposure - unreported income, a residency position that may be tested, a disclosure in contemplation - who your client speaks to in Israel determines whether that conversation is protected. It is a decision that is easy to make by accident.

When advisors call

The situations that come up most

Your client is moving to Israel

New olim and returning residents get a ten-year exemption on foreign income and gains - but its edges are narrower than clients assume, and it does nothing about their home-country liability. 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 - sit.

Your client is leaving Israel

Israeli residency does not end when the plane leaves. Severance has a filing duty, an exit-tax charge on unrealised gains, and a fact pattern the Tax Authority will test years later against what was actually filed.

Your client owns Israeli property

Betterment and purchase tax treat foreign residents differently, and the reliefs are easy to forfeit through timing. Refund claims are often available long after the transaction has closed.

Your client has an unreported Israeli exposure

Voluntary disclosure can resolve historic non-reporting with protection from criminal proceedings. It is time-sensitive and procedural, and the order in which things are done matters.

You need an Israeli position in writing

A reasoned legal opinion on the Israeli treatment - for your file, for a return position, or for 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 instruct someone who can.
Qualified in both law and accounting, so the analysis and the filing are not handed between two people.
Used to working to another jurisdiction's deadlines and to producing the Israeli half of a position your side can rely on.