Our firm prepares formal legal opinions on Israeli tax matters for clients, auditors, financial institutions, and counterparties who require expert analysis to support business decisions, financial reporting, and transaction execution. With deep experience in Israeli tax law and international tax planning, we deliver opinions that combine rigorous legal analysis with practical, decision-ready conclusions.
Services
Transaction Tax Opinions: We issue “should” and “more likely than not” opinions on the tax treatment of mergers, acquisitions, restructurings, and reorganizations. Our opinions support deal certainty and provide the analytical foundation for closing conditions and indemnity allocation.
Financial Statement Opinions (ASC 740 / IAS 12): We provide tax opinions to support uncertain tax position analysis under U.S. GAAP and IFRS, helping companies and their auditors evaluate Israeli tax exposures and recognition thresholds.
Cross-Border Structuring Opinions: We opine on the application of Israeli tax law to international structures, including treaty benefit eligibility, controlled foreign corporation rules, transfer pricing, and beneficial ownership analysis.
Capital Markets and Securities: We deliver tax disclosure opinions for IPOs, secondary offerings, and debt issuances, addressing investor-level tax consequences and required prospectus disclosures.
Specialized Tax Issues: We provide focused opinions on specific issues such as Section 104 reorganizations, trust taxation, residency determinations, exit tax consequences, and the Israeli tax treatment of digital assets and emerging financial instruments.
Pre-Transaction Diligence Opinions: For buyers, sellers, and lenders, we evaluate target tax positions and quantify exposures, presenting findings in a form suitable for inclusion in due diligence reports and transaction documents.
