אריה ליבוביץ ושות'

Following an amendment to Israel’s Income Tax Ordinance, the reporting exemption previously available to new immigrants ("OLE HADASH") and veteran returning residents will be revoked. The tax exemption on foreign income will, at least formally, remain in place — yet the amendment will enable the tax authorities to challenge the source or nature of income, for example, by claiming the existence of a permanent establishment in Israel. This change marks the beginning of a new era of full transparency under the OECD and CRS international standards, requiring early planning for anyone intending to immigrate to Israel after January 1, 2026.

Most new immigrants (“Olim Hadashim”) are unaware that they can choose between two different Purchase Tax routes when buying real estate in Israel: the regular progressive rate with a graded exemption, or a special fixed low-rate track available only to new immigrants. The right choice can save tens of thousands of shekels — and there’s even a “bonus” for those who buy a property before they officially immigrate

A new immigrant or returning resident from the United States faces a dual tax system — Israeli and American. This duality creates complex situations involving double taxation, interpretation of the Israel–U.S. Tax Treaty, and direct implications for existing American trusts (Grantor, Non-Grantor, Inter Vivos, and Crummey Trusts).
Without proper coordination, these issues can lead to double taxation, amended filings, or even retroactive tax exposure.