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Practices

Israeli and International Tax Issues

Capital Markets and Private Investments

In recent years, amendments to the Income Tax Ordinance have significantly affected the taxation of investors in Israeli resident and foreign companies as well as investors in capital markets and funds. Our firm represents a wide range of clients including VCs, private equity funds, family offices, angel investors, fund managers and investors in their Israeli tax strategy and before the Israel Tax Authority.

Trusts

We assist trusts in formation, and in understanding and complying with their reporting and tax liabilities. Our firm also provides ongoing tax consultation for existing trusts. We have extensive experience in reaching settlements with the tax authorities regarding the tax liability of existing or dissolved trusts.

International Tax

We specialize in providing solutions for Israelis with activities abroad and for foreign resident investors in Israel, advising international ventures on tax-efficient structures, international transactions, and transferring activities (in Israel or abroad). We also advise individuals regarding changes in residency status and relocation, including the optimal utilization of tax benefits granted to new immigrants and returning residents.

Arrangements with the ITA (Pre Rulings)

We work with the ITA to reach preliminary tax decisions in the areas of international taxation, residency, trusts, mergers and reorgs, the Encouragement of Capital Investments Law, employee options, transfer pricing, and capital markets. These arrangements provide the taxpayer certainty regarding its Israeli operations and the tax implications deriving therefrom.

Representation in tax appeal litigation

Our firm has extensive and proven experience in representing individuals and companies in all areas of civil taxation litigation and before all judicial forums. The firm's attorneys regularly appear before the civil courts in various income tax, value added tax and land taxation appeals and conduct various and diverse appeal proceedings, which even reach the Supreme Court.

Real Estate Tax

We have significant experience the tax aspects of real estate transactions, including sales, combination transactions, urban renewal (TAMA 38, “Pinui v’Binui), “Kvutzot Rechisha”, building rights, liquidation of real estate companies, options, trusts, sale of luxury residential apartments, etc. The firm advises contractors, developers and private individuals, and represents a large number of developers in urban renewal transactions.

Equity Compensation

Our firm specializes in advising on equity compensation, including employee options, and provides solutions to international companies making grants to employees of Israeli subsidiaries. We have extensive experience with securing approved option plans for employees vis-à-vis the tax authorities and tax decisions regarding the tax status of employees at the time of merger or acquisition. Adv. Yair Binyamini is a member of the Global Equity Organization and has lectured on the Israeli aspects of equity compensation at conferences in Europe and in the United States.

Crypto-currencies

Our firm is currently one of the market's foremost practices for providing solutions concerning the taxation of individual and corporate Blockchain activity with proven experience in guiding and advising companies on initial coin offerings (ICO or TGE), and the provision of Blockchain services or products. Our firm specializes in writing legal opinions concerning the application of Israeli tax laws to Blockchain operations, such as investment and trading in crypto-assets, mining, crypto-asset exchange transactions and loans, etc.

Voluntary disclosure

In recent years the Tax Authority has invested substantial resources in its quest to identify taxpayers whose assets and earnings have gone unreported and who have not paid the tax pertaining thereto. At the end of 2017, the Tax Authority renewed its voluntary disclosure procedure whereby a taxpayer who makes voluntary disclosure within the framework of the procedure and whose earnings and assets at the time of reporting were unknown to the Tax Authority, shall receive immunity from prosecution. Our firm has extensive experience in conducting voluntary disclosure proceedings, including those involving substantial amounts of tax. The legal services which our firm provides in the area of voluntary disclosure are carried out under attorney-client privilege and totally discreetly.

Advising on merger and acquisition transactions

Our firm has a wealth of experience in advising shareholders and companies on the taxation aspects of merger and acquisition transactions, from the perspective of both the purchasing party and the acquired party. Our firm's attorneys plan the transaction in a way that minimizes tax liability, including by obtaining pre-rulings from the tax authorities. Within this framework we are involved at all stages of the transaction, from the preliminary planning stage, recommendation of the tax strategy, the carrying out of due diligence, drafting of the merger documents, assistance with filing the necessary reports to the tax authorities, overseeing closure of the deal and, in so far as necessary, management of the post-transaction assessment proceedings with the tax authorities.

Legal opinion

Legal opinions regarding taxation provide a legal gloss on various issues arising during the course of the taxpayer's business activities, determine whether tax exposure exists in relation to given works and occasionally also legitimize various activities. Our firm has extensive experience in writing legal-taxation opinions in various areas of expertise.

Value added tax

Our firm specializes in all aspects of value added tax. The firm offers a range of support services in these areas, including guidance of transactions, legal opinions, tax planning and advice, representation at tax authority assessment hearings and representation in tax appeals filed with the various courts.