Category: International Tax Planning


The Israeli Tax Authority has just published a controversial tax ruling that imposes partial tax on a foreign investment fund. Background: Section 108 of the Israeli Income Tax Ordinance (ITO) empoweres the ITA to collect tax from an Israeli resident who represents a foreign resident. And ... Read More


The Israeli Tax Authority (ITA) has just published detailed instructions regarding the 2018 voluntary disclosure program (VDP or amnesty) which expand on the ITA’s initial announcement of December 12, 2017 (Operating Instructions 5/2018 of February 13, 2018).  The new instructions will create extra work for amnesty applicants and their ... Read More


The Israeli Tax Authority (ITA) announced a new voluntary disclosure program (VDP or amnesty) for applications filed by taxpayers between December 12, 2017 and the end of 2019. The new program replaces an earlier program that stopped accepting applications at the end of 2016. The ITA reports ... Read More


בשנת 2018 ישראל עומדת לתקן את כל 56 אמנות המס שלה בבת אחת וזאת עקב חתימתה בתאריך 7.6.2017 על אמנה רב צדדית של ארגון ה -  OECD על מנת ליישם הוראות הקשורות ל-   Base Erosion and Profit Shifting) BEPS). BEPS  הינה תכנית מקיפה של ארגון ה-OECD ... Read More


Israelis in hitech and other industries are often relocated to work abroad. At what time do they become foreign residents? For many years this was a mystery. The Israeli tax law says that dropping Israeli fiscal residency takes at least four tax years – two years in Israel ... Read More


Are Bitcoins and Other Virtual Currencies Tax-Exempt? In 1964, the Dave Clark Five pop group raised room temperatures with their foot stomping hit “Bits and Pieces”. In 2017, the rise in bitcoin prices is again raising room temperatures. To add to the euphoria, some think there ... Read More


President Trump and the Republican party issued a tax reform “framework” plan on September 27. It’s only 9 pages long so we don’t yet have full details and it has yet to be enacted. Given that, what’s in store for US businesses, US Olim, and everyone else?... Read More


The Israeli Tax Authority published final instructions regarding Reverse Vesting shares on June 5 (Circular 5.2017. This will be of interest to many people in the Start-Up Nation. Until now, founders and key personnel holding 10% or more of a company seemed to miss out on the opportunity ... Read More


The world’s tax treaties have just undergone instant plastic surgery. Unfortunately, they aren’t as pretty as they used to be. One of the surgeons in attendance was the Israeli finance minister, Moshe Kahlon. It all happened on June 7 in Paris, when the OECD held a grand ... Read More


Once upon a time in Never Land, a high tax country, Old Macdonald Inc. (OMI) hit upon a way of converting carrots into 24 carat pure gold at minimal cost. Unable to believe its good fortune, OMI licenses this knowhow to its subsidiary company OMI Offshore Ltd in ... Read More

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