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Short Summary
Main recommendation: Israeli residents with US brokerage, joint, or IRA accounts should make sure their assets are set up correctly now, so heirs can collect the required documents (death certificate in English, Affidavit of Domicile, and IRS transfer certificate) and have the assets moved smoothly after death. The speaker, Doug Goldstein of Profile Investment Services, explains how each account type passes to heirs and stresses that he does not give legal or tax advice.
Key Points
- Joint accounts with rights of survivorship pass directly to the surviving spouse, and the assets are usually moved into a new individual account in the survivor's name without selling them.
- IRA accounts pass by the beneficiary form filled out at account opening, not to joint owners and not through the will. The form can be updated after events such as a divorce or new child.
- Individual brokerage accounts pass through the will, which requires a probate in Israel. The speaker says his firm has accepted Israeli wills for many years, so a separate US will is usually not needed for US brokerage or IRA assets.
- Real estate outside Israel, such as a US home being rented out, can complicate the process and should be addressed with legal and tax advisers before heirs need them.
Details Worth Noting
- Concrete instructions:
- Joint accounts: Collect a death certificate in English. If issued by the Israeli Ministry of the Interior (Misrad HaPnim), have it professionally translated, then obtain a "Report of a US Citizen Death Overseas" from the US Consulate, which counts as the official English death certificate.
- Joint accounts and all account types: Fill out an Affidavit of Domicile stating where the deceased lived. Get the form from the firm, complete it as fully as possible, have it notarized to confirm the signer's identity, then submit it.
- Get a transfer certificate: Ask your accountant to send a request to the IRS for a letter confirming the deceased owed no taxes and the account can be released. Timing is typically a few months, longer than before COVID but faster than it was during COVID.
- IRA accounts: Provide the death certificate, transfer certificate, and notarized Affidavit of Domicile, and follow the beneficiary form on file.
- Individual brokerage accounts: Have a will, with an official English translation if originally written in Hebrew or another language. Obtain an Israeli probate, which the speaker says could be up to about 60 days, sometimes quicker, though complicated estates could take longer, then submit the English death certificate, transfer certificate, will, and probate.
- Before death: Show a draft will to the firm for review, and work with an attorney familiar with both US and Israeli law.
- Israeli probates are usually straightforward in the speaker's experience, though complicated estates may take longer.
- Selling foreign real estate is a common way people avoid this complexity. The speaker explicitly says he is not recommending a sale.
- The speaker states that the firm handles the transfer through its Israeli office, so clients do not have to deal directly with overseas companies.
- The speaker says these are general practical points and not legal or tax advice. Health-related or estate decisions should be reviewed with a qualified attorney, accountant, and financial adviser.
Bottom Line
Estate planning for US accounts held by Israeli residents is mostly about having the right documents ready in advance, since the transfer process is manageable once they are in place.
