With tax authorities growing more assertive and information flowing easily across borders, individuals with global footprints face increased risk. STL will help to ensure that your tax outcomes are predictable, efficient, and defensible, both in Israel and abroad.
Services
Cross-Border Tax Planning: If you move between countries or make cross-border investments, we will help you manage your international tax liabilities. We explain the implications of dual residency or change of residency, utilize tax treaties to avoid double taxation, and leverage treaty benefits for income, capital gains, and estate taxes.
For Israelis investing abroad, we provide guidance on tax-efficient structures. Our solutions leverage differences in tax treatment across jurisdictions and harness Israel’s tax treaties and other benefits to minimize liabilities and optimize your tax position.
Tax Treaty Analysis: Our review of applicable tax treaties will help you avoid double taxation and maximize treaty benefits. We will show you how to structure payments to minimize withholding tax on dividends, royalties, and interest charges across borders.
Pre-/Post-Immigration Planning: We help new immigrants and returning residents plan their move and residency to optimize the ten-year exemption on foreign-source income. We also position assets before the move, set up appropriate holding vehicles and trusts, and sequence disposals and contributions to ensure an optimal cross-border tax profile.
Severance of Israeli Tax Residency: We advise individuals who wish to end their Israeli tax residency. We determine the exit date, analyze residency status by day counts and the “center of life” test, and structure the exit year. We apply treaty tie-breakers; build the evidentiary record based on factors such as housing, employment, banking, schooling, and travel; and prepare legal opinions and applications for tax rulings and certificates of residency or non-residency.
Controlled Foreign Corporations (CFC) and Foreign Personal Services Companies: We advise Israeli-resident shareholders on control tests for the effective place of management, effective tax-rate thresholds, and character of income. We map Israeli deemed dividend consequences and design operating and holding structures that deliver favorable outcomes in Israel while aligning
with relevant foreign jurisdictions. When necessary, we coordinate with foreign counsel for local implementation, but without providing foreign tax advice.
Global Mobility and Expatriate Tax Services: We recommend ways to structure expatriate assignments to optimize tax outcomes for both employer and employee.
