November 29, 2021

Israel Tax Authority Proposes Changes for Individuals With Cross-border Connections

November 29, 2021/ Ruchelman P.L.L.C.

In an age of spectacular liquidity events for Israeli start-up companies, the Israel Tax Authority has proposed significant revisions to the tax law designed to bring more income and gains into the Israeli tax net. In part, this reflects a global trend among governments and to close a perceived tax gap among the wealthy, especially those having one foot at home and a second foot abroad. In Israel, the proposals directed at individuals include (i) adoption of objective rules for determining tax residence with greater certainty, (ii) tightening of exit tax rules to ensure collection of deferred amounts, (iii) expansion of C.F.C. rules to cover more foreign companies, (iv) elimination of foreign tax credit carryovers for unused foreign tax credits, and (v) changes to basis step-up rules for property inherited from foreign decedents. Daniel Paserman, a partner in the Tel Aviv office of Gornitzky, attorneys, and the head of the firm’s tax practice, and Inbar Barak-Bilu, a partner in the Tel Aviv Office of Gornitzky, attorneys, caution that the proposals are groundbreaking and are likely to have an influence on persons considering a move to or from Israel.

May 05, 2016

U.S. Immigration Tax Planning – Covered Expatriates→

May 05, 2016/ Ruchelman P.L.L.C.

Published in Taxes & Wealth Management by Thomson Reuters, Issue 9-1: February 2016. (p.14)

May 15, 2015

Pre-Immigration Tax Planning, Part III: Remedying The Adverse Consequences of the Covered Expatriate Regime

May 15, 2015/ Web Admin

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INTRODUCTION

Following our previous articles regarding pre-immigration planning and the expatriation rules applicable to covered expatriates (see here and here), this article considers some techniques for implementation before and after expatriation, with the objective to reduce the adverse treatment of the covered expatriate regime to the extent possible depending on the specific facts and circumstances of each individual.

For a Green Card holder, expatriating prior to becoming a long-term resident would eliminate the application of the covered expatriate regime. For a U.S. citizen (other than children under certain situations), the circumstances that will allow for a tax-free expatriation are more restrictive. An individual is considered a covered expatriate if he or she meets one of three tests. Pre-expatriation planning can eliminate the application of the covered expatriate regime for some individuals, while for others additional planning may be needed to reduce the unfavorable effect of the covered expatriate rules.

June 15, 2014

Expatriation the Transatlantic Way: Overview of the French and the U.S. Regimes

June 15, 2014/ Web Admin

Over the past years, both France and the United States have recorded a growing number of individuals expatriating as a tax planning device. In order to discourage these tax exiles, the French government introduced an exit tax in the late 90’s. The regime was later invalidated by the C.J.E.U. and reborn, in modified form, in 2011. Like France, the U.S. is no longer a tax paradise for those wishing to expatriate. In this article, guest author Nicolas Melot of Melot & Buchet, Paris, and Fanny Karaman compare the French and American exit tax regimes by giving an overview of their respective scopes and effects. For both U.S. and French purposes, the exit tax constitutes an important element in determining whether or not to expatriate.&