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    Maya Ziv Law
    Protecting Your Family Across Borders

    Protecting Your Family Across Borders

    Areas of Guidance

    Families with assets in Israel and ties to other countries face a specific challenge, ensuring that wealth passes to the next generation efficiently, in accordance with your wishes, and without unnecessary tax events or procedural delays. When foreign wills, foreign beneficiaries, or assets in multiple countries are involved, the complexity increases. We develop structured estate plans that integrate Israeli inheritance law with the relevant foreign legal frameworks, to prevent disputes, minimize probate delays, and reduce exposure to double taxation.

    Wills and Succession Orders

    We prepare Israel specific wills and comprehensive estate plans for clients who hold assets or maintain family connections across jurisdictions, drafted to meet Israeli formal and evidentiary requirements while coordinating with any existing foreign instruments. We represent heirs in obtaining a Probate Order (Kiyum Tzava'a) where a valid will exists, or a Succession Order (Tzav Yerusha) where no will was left, through the Registrar of Inheritance or the Family Court.

    Enduring Power of Attorney

    An Enduring Power of Attorney lets you designate trusted individuals to manage your personal, medical, and financial affairs in Israel should you become unable to do so. Unlike court appointed guardianship, it allows you to define the scope of authority, the identity of your representatives, and the conditions under which the instrument takes effect. We prepare comprehensive, court compliant documents that preserve your autonomy and provide your family with clear instructions.

    Prenuptial and Postnuptial Agreements

    For domestic and international couples, we prepare bilingual agreements in English and Hebrew that address property ownership, financial arrangements, and asset protection across borders. Each agreement is drafted with precision and, where required, approved by a court or notary to ensure enforceability under Israeli law.

    How We Work

    1

    Discovery and Mapping

    We identify and map your assets, jurisdictions, beneficiaries, and family dynamics to understand the full legal and financial picture.

    2

    Strategy and Structure

    We propose a structure consisting of documents and coordination steps aligned with your objectives and the requirements of each jurisdiction involved.

    3

    Drafting and Execution

    Documents are drafted bilingually where required and executed in the form prescribed by Israeli law. For clients abroad, execution can take place at a consulate or before a notary with apostille.

    4

    Safekeeping and Guidance

    We provide instructions for secure storage and practical guidance for executors on future activation, so that the plan works when it is needed.

    Clear scope, defined next steps, and documentation requirements are established from the outset.

    Tax Considerations for Cross-Border Estates

    Israel's tax treatment of inheritance and lifetime transfers differs from that of many Western jurisdictions. Transferring assets, whether during one's lifetime or after death, may trigger tax events that vary depending on the nature of the asset, the residency of the parties, and the timing of the transfer.

    We identify potential tax exposure at the outset and coordinate with relevant advisors in other jurisdictions where needed. The objective is to structure the estate in a way that reduces avoidable liability and protects the value of the legacy passing to the next generation.

    Our Clients

    We act for families and private clients with assets in Israel and ties to other jurisdictions, clients living abroad and dual citizens, and non resident heirs who need to obtain a Succession Order or a Probate Order. An engagement may center on preparing a specific planning document or on guiding an estate matter over time. In both cases, counsel is available in Hebrew and English, with familiarity with the requirements of the Registrar of Inheritance and the Family Court in Israel.

    Commonly Asked Questions

    A foreign will can be recognized in Israel but it must go through a probate process that includes expert opinions on the relevant foreign law. This process adds time, cost, and uncertainty, particularly when the estate includes Israeli real estate. The more reliable approach is to draft a separate Israeli will that addresses Israeli assets specifically, coordinated with your foreign will so that the two instruments do not conflict. We advise on both the drafting and the coordination across jurisdictions.

    Yes, though Israeli courts may require additional procedural steps including the provision of guarantees before appointing a non resident administrator. The practical implications depend on the composition of the estate and the complexity of the proceedings. We advise on executor selection as part of the estate planning process, with attention to the realistic demands of the role and the client's family and asset structure.

    A probate order, Kiyum Tzava'a, is issued by the Israeli Registrar of Inheritance when the deceased left a valid will. It confirms the will's validity and authorizes its execution. An inheritance order, Tzav Yerusha, is issued when there is no valid will, and estate distribution then follows the statutory provisions of Israel's Succession Law. In cross-border estates, coordinating the Israeli process with foreign proceedings is essential to avoid conflicts between jurisdictions.

    Yes. We handle the entire process with the Registrar of Inheritance or the Family Court, as well as coordination with banks and the Land Registry, through a power of attorney. You are not required to be physically present in Israel to obtain the order or to administer the estate.

    Structured legal planning that supports your interests today and safeguards your family's position over time.

    Counsel available in Hebrew and English.

    Contact the Firm

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