International Taxation&Trusts

Our firm specializes in providing comprehensive tax solutions for non-residents investing in Israel and for Israeli citizens conducting business abroad, including matters involving Controlled Foreign Corporations (CFCs), Foreign Professional Corporations (FPCs), permanent establishments, the taxation of U.S. LLCs, and more. We deliver strategic structuring advice to Israeli and multinational companies in order to minimize tax exposure and avoid unintended Israeli tax consequences in the context of cross-border transactions.

Additionally, our firm advises individuals planning to sever Israeli residency and relocate to a foreign jurisdiction, with a focus on optimizing future tax benefits for returning residents and veteran returning residents. We also provide tailored professional advice in the area of foreign trusts and assist new immigrants in understanding and utilizing the tax benefits to which they are entitled.

All services are provided with careful consideration of international tax treaties and in close coordination with leading international tax advisors. Our strong working relationships with global tax experts ensure optimal, customized solutions for complex international transactions. Our experience includes handling information exchanges between the Israeli Tax Authority and foreign tax authorities, managing mutual agreement procedures (MAPs), and offering in-depth interpretations of international tax treaties. These capabilities enable us to provide our clients with high-level legal and tax opinions tailored to any international tax challenge.

Our firm offers extensive and in-depth expertise in the handling of trust-related matters and trust arrangements, including highly complex cases, based on the substantial experience gained by one of our partners during his senior role within the Israeli Tax Authority’s trust division. We represent trusts seeking to apply the taxation arrangements published by the Israeli Tax Authority, and we are highly experienced in drafting professional legal opinions on various trust-related issues, including complex matters arising from legislative amendments to the trust chapter of the Israeli Income Tax Ordinance.

Our services are characterized by a personalized and tailored approach, combining extensive legal and tax knowledge with a deep understanding of the complex tax, legal, and financial aspects of trust law.

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