News
The long tentacles of the IRS
So, you realize that you didn’t report all your income or foreign bank accounts to the IRS and decide that rather than paying a penalty, you sell all your US assets and move to another country far from the IRS. Or maybe you live already in another country and liquidate all your US assets and think that now there is nothing the IRS can get their hands on.
בעלי אזרחות אמריקאית? רפורמת המס של ביידן עשויה להשפיע עליכם
אם הנשיא הנבחר ג'ו ביידן יממש את מדיניות המס שעליה הצהיר בקמפיין הבחירות, יהיו לכך השלכות גם על אזרחים אמריקאים החיים בישראל וגם על חברות ישראליות. מי ירוויח ומי ויפסיד, האם תוכניתו היא בהכרח רעה לישראלים, ואיזה חלון הזדמנויות נפתח בימים אלה.
Americans in Israel Beware of Biden's tax plans
Israeli residents with US citizenship could find themselves in a taxation tangle if president-elect Joe Biden keeps his campaign promises.
Biden's taxation policy may look like the opposite of that of Trump. High-earning individuals can expect a heavier tax burden on their incomes and reduced exemptions from gift tax and estate tax.
USE IT OR LOSE IT – הפטור ממס המתנות ומס העזבון האמריקאי על הכוונת
דייב וולף ואיתן אסנפי
הבחירות המתקרבות בארה"ב מציבות אתגרי מס משמעותיים לא רק למיליוני נישומים אמריקאיים אלא גם למאות אלפים מהם, החיים בישראל או שיש להם משפחה או נכסים בישראל.
USE IT OR LOSE IT: US GIFT AND ESTATE EXEMPTIONS COULD BE LOWERED DRAMATICALLY
by Dave Wolf and Eitan Asnafy
The upcoming U.S. elections pose some serious tax challenges not only for millions of U.S. taxpayers who live in the U.S but also for hundreds of thousands of them who live in Israel or have family or assets in Israel.
Joe Biden announced to undo some of the tax regulations introduced by the Trump Administration through the Tax Cuts and Jobs Act of 2017 if he is elected. Under Biden, high-income taxpayers will see both an increase in individual taxes and a reduction of the current gifts and estate tax exemptions.
Israel's Bank Hapoalim Offers $870 Million to Settle With U.S.
Bank Hapoalim, Israel’s largest financial institution, said it expects to pay $870 million to end investigations by U.S. authorities into allegations that the bank helped clients evade their U.S. tax obligations.
Enduring Power of Attorney (EPA)
Israeli law has recently changed the way it deals with the elderly and incapacitated by empowering them with a legal option that enables them to decide how they would like their medical, financial and personal affairs to be handled once they do not have the mental capacity to do so themselves. An Enduring Power of Attorney form (EPA), is one of these legal options.
And You Thought U.S. Taxation of Trusts Was Complicated
What if a trust beneficiary moves to Israel?
Warning - Israeli Banks will transfer your info to foreign countries
Recently, foreign residents with accounts in Israel have been receiving letters from Israeli banks stating that they bank would transfer information about their accounts to their state of residency through the Israel Tax Authority (ITA) as part of the CRS information exchange agreements that Israel signed on.
Cash payment report helps government combat money laundering
Federal law requires a person to report cash transactions of more than $10,000 by filing IRS Form 8300, Report of Cash Payments Over $10,000 Received in a Trade or Business. The information on the form helps law enforcement combat money laundering, tax evasion, drug dealing, terrorist financing and other criminal activities.
IRS Warns of Variation of Form W-8BEN Scam
The Internal Revenue Service (IRS) recently warned of a new twist tied to an old scam aimed at international taxpayers and non-resident aliens. In this scam, criminals use a fake IRS Form W-8BEN to solicit detailed personal identification and bank account information from victims.
In the past, fraudsters typically target non-residents of the U.S. and use the W-8BEN format to acquire personal details such as:
Limiting the Use of Cash in Israel
Use of cash can be used to enhance tax evasion, money laundering, and various other offenses including the financing of terrorism, because it is anonymous, easy to conceal and can be moved from one person to another without being reported.
Consequently, as part of the increasing efforts of the Israeli government to combat money laundering, unreported transactions and economic crimes, the Knesset passed legislation on March 12, 2018, designated to limit the use of cash in transactions whether business or personal.
2014 Offshore Voluntary Disclosure Program Is Coming to an End
On March 13, 2018, the Internal Revenue Service (IRS) announced that it is planning on closing the 2014 Offshore Voluntary Disclosure Program (OVDP) on Sept. 28, 2018. This gives U.S. taxpayers a little over six months to come forward with previously undisclosed foreign financial assets.
Cryptocurrency US and Israeli Taxes and Voluntary Disclosure
Authored by Mirit Hoffman (Reif), Adv. & Dave Wolf, Adv.
New Israeli Voluntary Disclosure Program - A Holiday Present from the ITA
In light of the expected implementation of the CRS agreement in Israel for automatic exchange of information between tax authorities, and as part of the increasing efforts of the Israeli Tax Authorities (“ITA”) to detect tax evaders and to expose unreported worldwide income of Israeli tax residents together with the success of the last voluntary disclosure procedure that expired at the end of 2016, the ITA published a new "voluntary disclosure procedure" on December 12, 2017.
Money Laundering Law Changes
The amendment to the Israeli Money Laundering Law (hereinafter; “the Law”), which was approved by the Knesset on December 4th and 5th, will take effect in the coming days. The amendment lowered the threshold for reporting any cash brought into or taken out of Israel, from NIS 100,000 to NIS 50,000. For land crossings, the threshold is NIS 12,000.
Virtual Currency and FBAR Reporting
According to U.S. law, if you have a financial interest in or signature authority over a foreign financial account, including a bank account, brokerage account, mutual fund, trust, or other type of foreign financial account, exceeding certain thresholds, the Bank Secrecy Act may require you to report the account yearly to the Department of Treasury by electronically filing a Financial Crimes Enforcement Network (FinCEN) 114, Report of Foreign Bank and Financial Accounts (FBAR).
Israel’s Bank Hapoalim to Close Swiss Unit as Talks With U.S. Continue
By William Hoke
Reproduced with permission from Tax Notes International, Oct. 9, 2017, pp. 136-137. Copyright 2017 by Tax Notes (https://www.taxnotes.com/)
Five days after Israel’s central bank told banks under its supervision to scale back their foreign activities following investigations by U.S. authorities, Bank Hapoalim Ltd. said its board of directors has authorized the termination of its Swiss subsidiary and the sale of the unit’s assets.
New Israeli Voluntary Disclosure Program to Open in January 2018
After months of discussions between the Israel Tax Authority (ITA), the Ministry of Finance, and the Ministry of Justice, it seems that the Israeli Voluntary Disclosure Program (Israeli VDP) will be renewed in January 2018. The new program will be similar to the previous Israeli VDP that commenced on December 31, 2016. In the event that all conditions of the program are met, which includes a voluntary disclosure made out of good faith effort, the taxpayer will be able to disclose the unreported income, and pay the taxes due.
The Tax Changes in the UK and the PPLI Advantage
If you are a Non-UK Domiciled individual (hereinafter: "ND") who is tax resident in the UK, there are two different systems of taxation that could apply to you.
New Israeli Tax Ruling Regarding Israeli Residence Certificates for New Immigrants
Israeli resident individuals are subject to Israeli tax on their worldwide income and capital gains. Effective January 1, 2007, "New Residents" and "Senior Returning Residents" (Israelis who have lived abroad for at least 10 years) are both entitled to the same package of tax benefits, which include a 10-year exemption from reporting and payment of tax from all non-Israeli sourced income and capital gains, even if the foreign assets were acquired after moving to Israel.
Increased FBAR penalty for 146 Foreign Banks and Facilitators
According to the 2014 Offshore Voluntary Disclosure (hereinafter: “OVDP”), the offshore penalty of 27.5% increases to a 50% penalty in any of the following circumstances:
Israel Steps Up Campaign Against Tax-Evading Airbnb Landlords
Reproduced with permission from International Tax Monitor, 165 ITM, 8/28/17. Copyright 2017 by The Bureau of National Affairs, Inc. 800-372-1033 http://www.bna.com
Israel Supreme Court Ruling Regarding Tax Residency
By Mirit Reif, Adv.
Recently, the Israeli Supreme Court ruled that a married businessman’s tax residency was in Israel, thus impacting his tax obligations in Israel, even though he spent a significant amount of time outside of Israel, tending to his businesses abroad and had “marital relationships” with other women while he was there.
The taxpayer had a wife and four children living in Israel. He worked in Israel and since 1991, started to engage in business activities in two other unspecified countries.
The Third Apartment Tax Bill Has Been Revoked
As mentioned in our previous articles on this subject, the Economic Arrangement Bill (Legislative Amendments to Implement the 2017-2018 State Budget) 5776-2016, was published by the Israeli government on December 29, 2016. Various tax amendments were made including the new Third Apartment Tax Bill.
This Bill imposed a tax on anyone who owns 3 apartments and more, at a maximum amount of NIS 18,000 tax per year, per apartment. The Israeli Tax Authority (ITA) recently postponed the deadline for reporting and payment under this new Bill until September 1, 2017.
IRS International Enforcement Group
On August 2, 2017, Mr. Donald Fort, the new IRS Criminal Investigation (CI) Division Chief, announced the establishment of two investigation initiatives: a nationally coordinated investigations unit and a dedicated international tax enforcement group. Fort explained that the new unit will provide a way to more effectively coordinate investigations that have nationwide impact, since it will report to CI’s frontline executives. The unit will use data analytics “to help identify and develop areas of noncompliance,” Fort said.
Deadline Deferral for Reporting & Payment of Tax under the Multiple Apartment Tax Bill
As mentioned in our previous article on this subject, the Economic Arrangement Bill (Legislative Amendments to Implement the 2017-2018 State Budget) 5776-2016, was published by the Israeli government on December 29, 2016.
This Bill included a tax to be imposed on anyone who owns 3 apartments and more, at a maximum amount of NIS 18,000 tax per year, per apartment.
Closed your account in 2009? Bank Hapoalim still wants you to report it to the IRS
Lately, we were contacted by several American citizens who received letters from Bank Hapoalim requesting that they provide proof that their account at the bank was properly declared to the Unites States tax authorities (the IRS). In addition, the bank requested from the clients to sign on a waiver of confidentiality and consent to report to the IRS information regarding the account. Even if the American citizen refuses to sign the waiver, the bank may still be required to transfer the information to the United States.
Deadline Deferred for Reporting & Payment of Tax under the Multiple Apartment Tax Bill
As mentioned in our previous article on this subject, the Economic Arrangement Bill (Legislative Amendments to Implement the 2017-2018 State Budget) 5776-2016, was published by the Israeli government on December 29, 2016.
Various tax amendments were made including the new Multiple Apartment Tax Bill. This Bill imposes a tax on anyone who owns 3 apartments and more, at a maximum amount of NIS 18,000 tax per year, per apartment.
6,000 Taxpayers Affected by New OVDP Campaign
IRS’s Large Business and International (LB&I) Division announced in January 2017, thirteen initial issue-based campaigns as a new audit strategy. The campaigns span a broad range of topics and intended to offer a comprehensive response to compliance risks.
Israeli Voluntary Disclosure Program (Israeli VDP)
Rumors have it that a new Israeli Voluntary Disclosure Program (Israeli VDP) will be announced in September 2017. This was mentioned by an Israeli Tax Authority representative during the tax forum meeting of the Israeli Bar Association. In the event that all conditions of the program are met, which includes a voluntary disclosure made of good faith effort, the taxpayer will be able to disclose the unreported income, and pay the taxes due.
The United States Tax Authority Released Information on 30,000 More Accounts to the Israeli Tax Authority
The Israel Tax Authority (ITA) recently received information of approximately 30,000 accounts owned by Israeli residents that were held in financial institutions in the United States during 2014. This list is added to the previous information that was released by the United States in January of over 35,000 accounts owned by Israeli residents that were held in financial institutions in the United States during 2015, and to the account information of 8,000 Israelis obtained from HSBC Switzerland recently.
U.S. Passport Restrictions & Delinquent Taxpayers
by Mirit Reif
In 2015, a new section of the tax code, called “Revocation or Denial of Passport in Case of Certain Tax Delinquencies", was approved by both the House of Representatives and the Senate.
Taxation of Virtual Currencies - ITA Draft Regulations
On January 11, 2017, the Israel Tax Authority (ITA) posted draft regulations relating to the taxation of virtual currencies.
Alternative Methods for Proving Lack of a Residential Home for Foreign Residents
By Mirit Reif, Adv.
When one sells a property in Israel he is obligated to pay capital gains (CG) tax on the profit of the sale. CG tax will apply whenever there is a value difference between the original purchase price and the current sale price (not including inflation increase).
A CG tax exemption will apply when an Israeli resident that owns a single home which is his only property in Israel, wants to sell it. In this case, he may sell his only home in Israel once every eighteen months with a full tax exemption on any profit gained.
“C’MON MAN!” Ridiculous Law Suits
In Georgia, USA a woman was awarded $161,000 after she was found only slightly liable for walking into a ladder while looking at her cell phone. The incident caused an indentation in the woman's head. She also suffered from headaches and a mild concussion as reported by Georgia legal journal The Daily Report.
Israel and Switzerland Sign the Agreement of Automatic Transfer of Financial and Banking Information
December, 2016
A declaration of intent for mutual cooperation was signed on November 27, 2016 between Israel and Switzerland. This agreement intends to increase the cooperation between the two countries for automatic exchange of financial information, which will assist in the enforcement of payment of Israeli tax and the combat against money laundering.
Increased FBAR penalty for 144 Foreign Banks & Facilitators
On October 14th, 2016, the IRS added 47 entries to the list of foreign financial institutions or facilitators that trigger the increased 50 percent penalty under the offshore voluntary disclosure program.
Giving Someone the Power to Choose for You
When giving one the “power” to make choices for another, and the legal aspects this entails. In this short summary we clarify some of the issues that can arise.
Israeli Tax Code Proposal to Reduce Evasion & Increasing Enforcement Laws
On August 12, 2016, the Israeli budget proposal for 2017-2018, was approved by the Israeli governmen, includes twelve clauses that were suggested as amendments to the Israeli tax code, and that are expected to be discussed for approval in November in the Knesset. These clauses all have the same goal of reducing tax evasion and increasing tax enforcement laws.
Do veggies get equal protection?
A South Florida couple forced to dig up the organic vegetable garden they had in their front yard for 17 years, due to threats of $50-a-day fines by Miami Shores, is now pursuing a constitutional case over a front-garden ban.
Dave Wolf & Co. Law Firm is Proud to Announce that Mirit Hoffman Reif Has Been Promoted to Partner
Dave Wolf & Co. Law Firm is proud to announce that Mirit Hoffman Reif has been promoted to Partner at the firm on April 1, 2016.
Receiving money from abroad? Make sure you have back up information.
If you plan on receiving money from abroad in the near future we highly recommend that you prepare proof of funds, and if possible, have it confirmed in writing by a lawyer, otherwise, that money might never reach you.
Funny Tax News: Cookie Seller's Tax Evasion Excuse
During a random inspection by the local tax authorities, a cookie seller at a booth in Kiryat Shemona in the north of Israel was found to not have registered her income for that day. Her excuse? She claimed that she didn't have a pen at hand and that she had sent someone else to buy one for her, but that this person had not yet returned...
Odd News: Identify Thief Sets Up New York Law Firm
A Brooklyn man has been arrested for allegedly stealing a lawyer's identity and setting up a law firm where he met clients and filed lawsuits on their behalf.
هل تم فصلك من العمل؟اعلم ما هي حقوقك!
هل تم استدعاؤك لجلسة استماع قبل فصلك من العمل؟من واجب صاحب العمل أن يعقد مع العامل جلسة استماع قبل فصله من العمل، وهكذا يتسنى له التفكير بصراحة وبشكل جدي في مسألة فصله من العمل. وهذا التفكير لا يمكن أن يتم أثناء الجلسة، إنما بعدها، ويتم بعد تفكير مليّ. وأثناء تلك المحادثة يتعين عليك كعامل مرشح للفصل من العمل أن تطرح كل ادعاءاتك ضد الفصل من العمل، مثلاً: حالة مادية/عائلية صعبة، بل وبوسعك إبراز أوراق ومستندات تسند ادعاءاتك و/أو أن تُتاح لك إمكانية طرح فكرة أخرى بدل الفصل من العمل، ومنها على سبيل المثال: نقلك إلى وظيفة أخرى في الشركة، طالما كانت هناك وظيفة أنت مؤهل للقيام بها. نوضح هنا أن المحاكم لا تتردد في الحكم على أصحاب العمل بدفع تعويضات إذا لم يتيحوا لمستخدميهم المفصولين عن العمل إمكانية المحادثة لسماع اقوالهم و/أو إذا تصرفوا بطريقة مخالفة للإجراءات المتبعة.
Been fired? Know your rights!
Been fired from your job in Israel - or concerned you're about to be laid off? Do you know your rights to prior notice, a hearing and severance pay? Knowing your power as an employee can ensure you get what you deserve - and sometimes even prevent the loss of your job.
Вас уволили? Знайте свои права!
Проводилось ли с Вами собеседование перед увольнением? Перед увольнением работника работодатель обязан провести с ним собеседование ("шимуа"), с тем чтобы взвесить вопрос о его увольнении самым честным и добросовестным образом, а такое серьезное рассмотрение этого вопроса возможно не в течение самого собеседования, а только после него...
פיטרו אותך? דע את זכויותייך!
האם נעשתה לך שיחת שימוע טרם הפיטורים? חובה על המעסיק לקיים שיחת שימוע לעובדטרם פיטוריו וכך לשקול בכנות וברצינות את פיטוריו ולכן שקילה מעין זו אינה יכולה להיעשות באותו מעמד של שיחת השימוע, אלא לאחריה ובכובד ראש כאמור
Portland pimp sues Nike for $100 million for lack of warning label after beating victim with Jordans
The Oregonian reported on January 13, 2014 that 26-year-old Portland pimp has filed a $100 million lawsuit against Nike, claiming the shoe manufacturer is partially responsible for a brutal beating that helped net him a 100-year prison sentence.
Taxpayer Scores $862,000 from IRS after Tripping over a Phone Cord
A taxpayer undergoing an audit at an Internal Revenue Service office on Long Island successfully sued the IRS for $862,000 after he was injured by tripping over a phone cord.
Bitcoin Israel - Q & A
Bitcoin is digital virtual currency run by a system based on open source software. No country, company, bank or organization owns or controls Bitcoin.
ביטקוין ישראל (Bitcoin Israel)
שאלות ותשובות ביטקוין ישראל | ביטקוין הוא מטבע דיגטלי וירטואלי המנוהל על ידי מערכת מבוססת קוד פתוח. שמאחוריו לא עומדת אף מדינה, חברה, בנק או ארגון
Attorneys at Hacohen Wolf Law Offices Meet MK Rabbi Dov Lipman
Dave Wolf and Mirit Reif, attorneys at Hacohen Wolf Law Offices, met MK Rabbi Dov Lipman, who is a member of the Knesset (Israeli parliament), to discuss FATCA problems in Israel
Nothing is Certain but Death and Taxes or is it?
It seems that in 2013 you cannot be certain about the meaning of death anymore. An Ohio man who appeared in court is legally dead, a judge has ruled.
What Are My Rights? A brief guide for the working woman
Most of us are educated to believe that we can have it all if we only apply ourselves. We can have the perfect home, the relaxed well behaved kids and the perfect satisfying job. In pursuit of this challenging goal, we find ourselves being plunged into the complex world of "Working Mothers". The goal of this short article is to give you, the working woman, a basic summary of some of the rights Israeli women have at work.
Question from the web: US Citizens can`t own a securities account in an Israeli bank?
A user on a popular Israeli online forum recently posted a tax compliance issue that their Israeli bank notified them about. This type of question has become more common since the new changes in US tax and SEC requirements for US citizens living abroad went into effect. Please see the question and Dave Wolf's response below: