Our tax lawyers are highly skilled in counseling businesses of every size in understanding and managing the complexity of Israeli tax laws and how they affect commercial transactions and corporate finance. Yigal Arnon & Co. advises individual and corporate clients on investment and tax planning matters, identifies and resolves tax issues as they arise, represents clients before the tax authorities and undertakes litigation when necessary. Our tax expertise covers corporate taxation, international tax and treaty implementation, mergers and acquisitions, real estate taxation, transfer pricing, value added tax, venture fund formation, employee stock options, financial instruments, trust taxation and numerous other specialist areas. We are frequently asked to give tax opinions and to apply for pre-rulings from the Israeli tax authorities. Our clients rely on our ability to look beyond the identification of tax problems and find innovative and timely solutions. Yigal Arnon & Co.’s Tax Group has significant experience in many areas, such as:

M&A Transactions

We handle all tax aspects of mergers and acquisitions, including employee stock options, taxation of founders, withholding at source by purchasers, tax due diligence and post-merger tax optimization.

Litigation

We are involved in tax litigation matters, underlining our full capacity to offer all types of tax advice. These include multi-million dollar tax litigation concerning:

  • Valuation of IP sold to a non-Israeli affiliate of the taxpayer company;
  • Largescale litigation on valuation of IP sold to a non-Israeli affiliate of the taxpayer and whether a deemed intercompany debt was created as a result;
  • Largescale real estate tax litigation on the inclusion of various installations and equipment in the scope of the term "real property" for tax purposes in the case of shopping center acquisitions;
  • Litigation on the recognition of nominal (shekel) capital losses from securities transactions resulting from changes in the exchange rate;
  • Litigation on the recognition of income from future transactions;

Negotiation of Arrangements and Pre-Rulings; Representation in ITA Audits

We negotiate arrangements and pre-rulings concerning reorganizations, tax treaty application, expatriate taxation, trusts, stock options and value added tax, among other things.

Tax opinions

We provide legal opinions on a wide variety of topics, including specialized areas such as corporate tax, immigrant (olim) and returning resident rights, tax treaty interpretation, financial market products, controlled foreign corporations and place of corporate residence (control and management).

Tax Planning

We provide tax planning for Israeli-owned corporations operating abroad and for multinational corporations operating in Israel. The firm advises Israeli and multinational corporations on various legal and tax-related aspects of equity-based forms of employee compensation.

Family Wealth Management

In this area, our Tax Department advises individuals and families how to optimize their wealth management with regard private and business assets, including by use of trusts, tailoring solutions for the specific needs and sensitives of each family. The team offers expertise in the relevant fields, such as Israeli and international taxation, land tax, estate and gift tax, trusts, prenuptial agreements and legal guardianships.

Real Estate Tax

The tax implications of real estate transactions can be especially complex. Our Firm is among the only ones in Israel which, in addition to a large real estate practice, offers also land tax expertise. We provide clients with tax consulting on all real estate transactions, starting with optimal tax planning ahead of the deal, through obtaining a pre-ruling from the tax authority, assistance in execution of the deal, and filing the necessary reports to the land tax authorities. We also help in tax rate negotiations in largescale real estate projects. Our clients include leading real estate companies, and individuals and foreign residents purchasing real estate assets and operations in Israel.

Our services include:

  • Consultation and legal opinions about the various tax implications of real estate deals, such as betterment tax, purchase tax and VAT, including tax calculations and reporting the transaction to the tax authorities;
  • Tax planning and consultation in complex real estate transactions and in financing transactions ancillary to the purchase and development of real estate, including international tax implications if and as relevant;
  • Representation of clients in assessment procedures vis-à-vis the various Land Tax Offices, including representation before the various tax authorities throughout the assessment process, drafting and management of appeals on the Tax Director’s “best of judgment” assessment, and negotiations with the tax authorities toward a final assessment;
  • Drafting of and representation in appeals before the various appellate committees and the courts;
  • Family wealth management – real estate assets;
  • Consultation, tax planning and representation vis-à-vis the tax authorities on all tax matters ancillary to complex urban renewal projects, such as pinui binui and Tama 38.

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