Two Countries, Two Systems, One Family
If you live in Israel but still hold US real estate, accounts, a US retirement plan, or US citizenship, the US side of your estate is governed by US law, and an Israeli-only will may not control it cleanly. Left unplanned, your family can face a US probate from abroad. The answer is a coordinated plan: a US will or trust and powers of attorney for your US assets, drafted to fit alongside your Israeli documents, not fight them. We handle the US side and coordinate with your Israeli attorney.
The Non-Citizen-Spouse Trap
If you are a US citizen married to an Israeli (non-US-citizen) spouse, the usual rule that lets spouses pass assets estate-tax-free does not apply. For larger US estates, a QDOT preserves the benefit. It is a common and costly trap for American-Israeli couples, and one we plan around.
We work across the ocean and the time difference.
Everything by phone and video, for your US estate and your US parents alike.
Book your free consultUS Parents, and the Halachic Side
Many olim are also managing aging parents back in the US, a power of attorney, a Medicaid or care plan, or settling an estate. We handle that remotely too. And we draft your secular documents to work alongside a halachic will prepared with your rabbi or beth din, so your plan honors both US law and halacha. For the broader US-paperwork picture, see our checklist for Americans in Israel. And if you are weighing whether to eventually give up US citizenship, read the US exit tax guide first, because the planning has to happen before you renounce. If you hold Israeli investment funds or a pension (kupot gemel, keren hishtalmut, keren pensia), see the PFIC trap and the US tax on foreign pensions, both of which hit olim hard. And if you have a US retirement account, ask about a Roth conversion during your new-immigrant tax window.
Frequently Asked Questions
I Live in Israel but Have US Assets. Do I Need a US Estate Plan?
Almost certainly, yes. If you hold US real estate, US bank or brokerage accounts, a US retirement account, or US citizenship, the US side of your estate is governed by US law, and your Israeli will may not control it cleanly. Without US documents, your family can face a US probate from abroad, which is slow and expensive. The fix is a US will or trust that handles your US-situs assets and coordinates with your Israeli plan, so the two systems work together instead of colliding.
Do I Need Both an Israeli and a US Will?
Usually you want coordinated documents: an Israeli plan for your Israeli assets and a US plan for your US assets, each drafted so it does not accidentally revoke the other. We handle the US side, your will or trust, powers of attorney, and directives for US purposes, and coordinate with your Israeli attorney so the whole picture fits. Trying to cover US assets with an Israeli-only will is where families get stuck.
My Spouse Isn’t a US Citizen. Does That Matter?
It can matter a great deal. The unlimited marital deduction that normally lets spouses pass assets estate-tax-free does not apply when the surviving spouse is not a US citizen. For larger US estates, a special trust called a QDOT is used to preserve the benefit. For an American married to an Israeli, this is a common and important trap. See estate planning for non-US citizens.
I Made Aliyah but My Parents Are Still in the US. Can You Help Them?
Yes, and this is one of the most common situations we see: an oleh in Israel whose aging parents in the US need a power of attorney, a Medicaid or care plan, or help settling an estate. We work entirely by phone and video across the time difference, so you can get your US parents’ affairs in order without flying back, and handle your own US estate at the same time.
Do You Handle Halachic Wills?
We draft the secular US documents to work alongside a halachic will (a shtar chatzi zachar) prepared with your rabbi or beth din, so your estate honors both US law and halacha. Kevin understands the observant community and coordinates respectfully with your rabbinical authorities. See halachic estate planning.
Can I Invest in Israeli Mutual Funds or a Keren Hishtalmut as a US Citizen?
Be careful before you do. US tax law treats most ordinary Israeli pooled investments, mutual funds, ETFs, and investment savings funds like a keren hishtalmut, as PFICs (passive foreign investment companies), a punitive regime that taxes the gains at the highest rates with an interest charge added, plus a separate IRS form for each fund every year. Israeli banks and advisors rarely warn about this, because they do not advise on US tax. The usual answer is to hold US-domiciled funds through a US brokerage instead, which stays outside the PFIC rules entirely. We screen for this on every olim file and coordinate any cleanup with a cross-border tax CPA.
Updated on July 12, 2026. Reviewed by Kevin D. Klagge, Esq., Fla. Bar No. 99502. Attorney Kevin Klagge represents families, businesses, and international clients in estate planning and international law, with a focus on Florida legal tools. He litigates estate and business issues in court. General information about US and Florida law, not legal advice. The firm advises on US and Florida law and coordinates with Israeli counsel on Israeli-law matters; it does not practice Israeli law. Do not send confidential information until we have agreed to represent you.