US-ISRAEL INHERITANCE

Reference . Term decoder

A short bilingual decoder

The terms below are the ones that cause the most confusion in the first few weeks. Many do not map cleanly between the two languages, so each is defined by what it means, not by a translation.

This is orientation, not legal or tax advice. Definitions are general; how a term applies to your case is a question for a licensed professional.

Domicile
The country a person treats as their permanent home. It drives US estate tax exposure and is not the same as the place of death or current address.
Situs
Where an asset is legally located for tax purposes. A US property or US company shares are US-situs even if the owner lived in Israel.
Tzav Yerusha Succession Order
The Israeli court order issued when there is no will, naming the legal heirs so assets can be released.
Tzav Kiyum Tzava'a Probate Order
The Israeli court order that validates an existing will so it can be acted on.
Registrar of Inheritance Matters
The Israeli authority that issues Succession and Probate Orders.
Apostille
An international certification that authenticates a public document, such as a foreign will or death certificate, for use in another country.
Mas Shevach land appreciation tax
Israel's tax on the gain when real estate is sold, generally 25 percent on the real gain.
Form 706 / 706-NA
The US estate tax return. The NA version applies to a nonresident who is not a US citizen.
Form 3520
The US information return a US person files after receiving more than 100,000 dollars from a foreign estate or person in a year.
Carryover basis
The rule that an inherited asset keeps the deceased's original cost history, which matters when the heir later sells.