International tax

Legal opinions

Litigation and Tax Conflict

Relocation taxation

Taxation of trusts

Real Estate Taxation

VAT

Planning and accompanying transactions, mergers, splits, and acquisitions

Intergenerational Transfer

Preliminary taxation decisions (pre-rulings)

Corporate Taxation

International tax

Our firm advises Israeli and multinational companies regarding the tax aspects of international transactions in Israel, including planning efficient investment structures, changing the structure of activities, assisting in conducting due diligence before acquiring companies in Israel, transfer prices, mergers and acquisitions, joint ventures, splits, private equity funds, financing and raising capital through stock exchanges around the world. Our firm assists both Israeli investors operating outside Israel and foreign investors seeking to invest in Israel, both in active and passive investments. In addition, we advise immigrants and Israelis returning to Israel in planning a return to Israel, analyze the date of commencement of residency in Israel, and check eligibility for tax relief granted to them during the benefits period. We are well versed in the various laws that provide various benefits for capital investments and their application to foreign investors. Our firm works in close contact with leading international lawyers and accountants to ensure the success of tax planning both in Israel and in the target country.

Legal opinions

Our firm's legal opinions are highly esteemed by colleagues and the tax authorities. We have provided legal opinions dealing with creative solutions to complex and diverse tax issues, to various clients in the Israeli economy, including public companies, private entities, trusts, and individuals. We make every effort to ensure that our legal research in tax law in Israel and around the world is both accurate and comprehensive. Our opinions are written in a clear and unambiguous language and provide the client, who relies on them, with creative and unique solutions, in addition to immunity from criminal proceedings, and protection at the administrative level against a claim of negligence.

Litigation and Tax Conflict

Our firm provides its services at all stages of the dispute with the tax authorities - assessment hearings, obtaining, and if necessary, handling an appeal to the District Court and the Supreme Court. Our involvement in examining the tax aspects of many transactions gives us a special advantage when appearing before the tax authorities - we not only appear and defend tax planning but are also well placed in the interplay between successful tax planning and the outcome of litigation. We have represented clients in numerous and complex legal proceedings before the district courts and before the Supreme Court in all areas of taxation. Conducting court proceedings requires a unique combination of legal knowledge, a deep understanding of tax law, and representational and persuasive abilities. Many of the cases in which we appeared led to guiding precedents.

Relocation taxation

Relocation is the process of moving from one country to another. Relocation for the purpose of work is usually temporary and can be done both through the employing company and in person.

When leaving for relocation, the tax aspects must be considered, for both leaving Israel and returning to Israel. Our firm specializes in finding a beneficial solution that will minimize tax exposures and reduce tax liability.

Taxation of trusts

We specialize in establishing trusts around the world as well as in the tax aspects that accompany this step in Israel as well as in the country where the trust was established. We advise creators, trustees and benefactors, Israelis, and foreigners, in order to reduce the tax liability while ensuring proper compliance with the reporting obligations imposed on them. Our expertise in the field of taxation allows us to offer Individuals with capital a creative tax outline that provides proper protection from the Israeli tax authorities.

Real Estate Taxation

We advise entrepreneurs, contractors, and owners of large-scale commercial properties, as well as individuals and partnerships. Real estate transactions sometimes require unique tax planning, in order to avoid a particularly harsh tax burden, double taxation, and sometimes to ensure that the tax is paid out of the cash flow that is being created during the transaction. Our comprehensive knowledge in the real-estate field allows us the creativity and innovation that are required in complex and sophisticated transactions, as well as the dissolution of real estate associations. This knowledge has been acquired by accompanying many transactions of local investors in the real estate market, and foreign investments in real estate in the country. Our firm has extensive experience in combination transactions, liquidation of real estate associations, accompanying purchasing groups, and ongoing consulting in traditional real estate transactions.

VAT

We provide ongoing advice regarding VAT aspects related to our clients' activities, as well as unique tax plans. In addition, we also provide solutions in the field of VAT and if necessary, apply to the tax authority, for an appropriate taxation decision.

Planning and accompanying transactions, mergers, splits, and acquisitions

Acquisition transactions and structural changes entail significant tax aspects. We assist our clients in planning the transaction in the most tax beneficial manner. Our firm also accompanies the client in the due diligence phase, and we later handle the reporting requirements for tax purposes arising from the transaction. Once the transaction has been completed, we represent our clients before the tax authorities in the assessment and audit stages of the transaction, as necessary.

Intergenerational Transfer

Many taxpayers who have amassed capital over the years are interested in transferring their assets to the future generations. There are various legal and financial options for capital transfers. Proper planning of intergenerational transfers of assets within the family requires a broad perspective that combines the relevant aspects of family law with relevant aspects of tax law with the drafting of wills, gifts agreements inter vivos between heirs, and transferring assets to a trust in appropriate cases.

This matter presents a complex tax planning challenge. In most cases, a process of preliminary tax planning is the ideal solution that includes, among other things, analyzing the possible tax results in each of the relevant alternatives and determining the correct taxation strategy in each case.

Our firm specializes in finding creative solutions for transferring family assets to the next generation in a correct and informed manner and in accordance with the clients' wishes, considering the tax aspects at the time of transfer and those that may arise in the future when the assets are realized by the potential heirs. Tax planning in intergenerational transfers also takes into account, among other things, aspects of real estate taxation, and aspects of international taxation as and if required.

The service is especially relevant for affluent families who own a variety of properties (real estate in Israel; and real estate abroad; investments in Israeli and foreign companies; valuable art collections; etc.) and especially in cases where some family members are not registered as Israeli residents for tax purposes.

Preliminary taxation decisions (pre-rulings)

Taxation decisions Can give certainty in the tax consequences of a particular action. Our firm has extensive experience in applying to the tax authorities in cases that require preliminary taxation decisions, on a variety of issues: mergers and splits, capital market, real estate taxation, VAT, determination of residency, taxation of trusts, applying step up to inherited shares, etc.

Corporate Taxation

Our corporate tax practice is devoted primarily to the solution of intricate corporate tax problems. The scope and diversity of our practice accords us a leading edge capability which we deploy in providing strategic planning for restructuring, mergers, acquisitions, spin-offs, profit payouts, liquidations and leveraged buy-outs. We advise and devise specially designed tax fitting financial instruments including stock, bonds, convertible securities and derivatives.

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