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Inheriting assets can evoke a mix of emotions—gratitude for the legacy, nostalgia for a loved one, and the weight of new financial responsibilities. 

For Americans living in Israel, the task becomes more complicated. Managing cross-border inheritances isn’t just about receiving assets; you must navigate the legal and tax systems of two countries. Understanding how those assets function under both U.S. and Israeli laws helps you face the challenges that may come.  

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As more U.S. citizens make Aliyah, they increasingly confront these cross-border inheritance issues. Trusts, a common estate planning tool in the U.S., complicate things further when beneficiaries live abroad. But with proactive planning, you can navigate these challenges more effectively. 

Navigating the Tax Maze of U.S. Inheritances in Israel 

Taxes play a central role in inheritance matters, and dealing with two countries’ tax systems adds layers of complexity. When you inherit from a U.S. trust, you might assume the process will be straightforward. However, beneficiaries living in Israel often discover unexpected tax burdens. What you thought was a tax-free inheritance might quickly become a taxable windfall under Israeli tax laws. 

The tax systems in Israel and the U.S. don’t always align. For example, a distribution that’s tax-free in the U.S. could be classified as taxable income in Israel. This mismatch can greatly reduce the inheritance amount you retain. By consulting with tax advisors who understand both systems, you can prepare for these obligations and plan accordingly. 

Key Questions: Writing Trusts When You Have Children in Israel 

How will the trust be treated under Israeli tax law? 

  • Understanding how Israeli tax authorities view U.S. trusts is essential, as distributions could be taxed differently than in the U.S. 

Should the trust be structured differently because beneficiaries live in Israel? 

  • The residency of beneficiaries can affect how trust income and principal are taxed. 

What reporting requirements apply to the trust in Israel? 

  • Israeli residents may need to report their interest in a foreign trust, which could trigger additional tax obligations. 

How will distributions to Israeli residents be taxed? 

  • Not all distributions are treated equally under Israeli law. 

Are there specific clauses or provisions that can protect beneficiaries in Israel? 

  • Some trust provisions can help safeguard assets from excessive taxation or legal complications. 

Trusts Without the Tears 

Trusts allow families to manage assets and ensure inheritances follow specific wishes. However, complications arise when beneficiaries move abroad. Even small details, like the beneficiary’s residency, can have significant tax implications. Families often establish trusts assuming everyone will remain in the U.S., only to encounter issues when a beneficiary relocates to Israel. 

Residency changes can dramatically affect how trust distributions are taxed. Open conversations between beneficiaries and financial advisors are crucial to identifying potential problems before they escalate. Discussing the trust’s tax liabilities and legal implications in both countries helps prevent costly surprises. 

Jonathan Swift, renowned author, said, “A wise person should have money in their head, but not in their heart.” Financial decisions, especially involving cross-border trusts, require clear-headedness. By separating emotion from strategy, you can make decisions that protect your financial interests. 

Inheritance in Hand: What Comes Next? 

After receiving an inheritance, many beneficiaries feel the urge to act quickly. Whether it’s investing the funds, paying off debts, or redistributing assets, hasty decisions often lead to regret. Without a clear strategy, you risk mismanaging newfound wealth. 

Behavioral finance reveals a common problem called “overconfidence bias.” This bias occurs when people, suddenly in possession of wealth, believe they can make foolproof financial decisions. Overconfidence can lead to risky investments or impulse spending, both of which can quickly diminish your inheritance. Instead of rushing into decisions, step back, review your financial goals, and align your inheritance with your long-term strategy. 

Don’t Go It Alone 

Managing cross-border inheritances doesn’t have to feel overwhelming. Start by discussing potential inheritances with your family, and then work with professionals who specialize in U.S.-Israel tax and estate planning. Proactive planning minimizes tax surprises and maximizes the benefits of your inheritance. 

To explore steps you should take after receiving an inheritance, visit Did You Receive an Inheritance? What You Need to Do Now. This guide outlines critical actions to safeguard your newfound assets and offers insights to help you make informed decisions. 

With the right advice and a clear strategy, you can turn your inheritance into the financial blessing it’s meant to be—without the complications and frustrations that so often accompany cross-border wealth management. 

Douglas Goldstein, CFP® is the director of Profile Investment Services, Ltd. www.Profile-Financial.com. Securities offered through Portfolio Resources Group, Inc. Member FINRA, SIPC, MSRB, FSI. The opinions expressed are those of the author and not those of this website, Portfolio Resources Group, Inc. or its affiliates. Neither Profile nor Portfolio Resources Group, Inc. or its affiliates, provide tax or legal advice. Nothing in this article is intended to be investment, tax, or legal advice. Information in this article is gathered from sources considered reliable, but we cannot guarantee their accuracy. Past performance is no guarantee of future returns. 


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Douglas Goldstein, CFP®, is the director of Profile Investment Services, Ltd, a financial planning and investment services firm specializing in working with Americans living in Israel who have investment accounts in America. He is a licensed financial professional both in the U.S. and Israel.