Category: International Tax Planning


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 ... Read More


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


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

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