Category: International Tax Planning


The Israeli Supreme Court has just turned down not once but twice an appeal against the refusal of the District Court to allow a foreign tax credit in a case involving a US LLC. The result is double taxation. The taxpayer is upset. What went wrong? Background: A Limited Liability Company (LLC) ... Read More
October 22, 2018Leon Harris


The Israeli Tax Authority (ITA) has issued a new generic Ruling allowing a streamlined procedure for B2B (business to business) e-commerce supplies by foreign businesses to Israeli businesses (Ruling 6369/18). The tax or lack thereof on e-commerce is a hot topic. On June 21 this year, the US Supreme Court ruled in the ... Read More
September 17, 2018Leon Harris



Your Taxes: Time to repent

If have a skeleton in your closet and need an Israeli tax amnesty, you have only three months until the end of 2018 to request it on an anonymous basis from the Israeli Tax Authority. And it takes time to prepare. Anyone applying for tax amnesty in 2019 will be at ... Read More
September 17, 2018Leon Harris


The Israeli Supreme Court has just ruled that a taxpayer cannot claim a foreign tax credit under the US-Israel tax treaty (Tel-Aviv 4 Assessing Officer vs. Gmul America Ltd, Civil Appeal 8934/16 of June 11, 2018). Double taxation and no tax treaty relief is not good for international trade and investment ... Read More
July 11, 2018Leon Harris


On 21 March 2018, the European Commission proposed new rules to ensure that digital business activities are taxed in a “fair and growth-friendly” way across the EU. This followed an OECD report of March 16 revealing a lack of international consensus about taxing digital operators (Tax Challenges Arising from Digitalization –Interim Report). The same day ... Read More
May 8, 2018Leon Harris


As Israel celebrates 70 years of independence, it is good to note what makes the start-up nation innovative and successful. A recent OECD report attributes this success in large part to venture capital (VC) funds (A Portrait of Innovative Start-Ups Across Countries).  On March 14, the Israeli Tax Authority issued updated guidance ... Read More
April 25, 2018Leon Harris


At Passover we celebrated our exodus from Egypt and the season of our freedom. In modern times, that means the start-up nation in the promised land is free to make money from exits – selling tech and other businesses to multinational groups that need to stay ahead at all costs. ... Read More
April 11, 2018Leon Harris


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 the Israeli Tax Authority (ITA) claims ... Read More
March 14, 2018Leon Harris


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 advisors. Background: The 2018 ... Read More
February 21, 2018Leon Harris


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 that 7,549 applications were ... Read More
December 19, 2017Leon Harris