A foreign legal opinion in Israel is a mandatory legal document required by the Registrar of Inheritance Affairs under the Israeli Succession Law 5725-1965 when the deceased was a foreign resident who left assets in Israel. It is prepared by an attorney licensed in Israel who is expert in the law of the relevant country. The opinion explains which inheritance laws apply so Israeli authorities can issue a succession order or will probate order. Without a valid foreign legal opinion, no inheritance proceeding in Israel can advance. If the testator's residence was outside of Israel when they passed away, a foreign legal opinion is necessary to proceed with inheritance issues relating to the will or estate in Israel.

Our firm provides foreign legal opinions for many countries around the world, including all over the United States (all 50 states including New York, California, Texas, Arizona etc.), Australia, Canada, England — United Kingdom, Brazil, Portugal, Spain, Argentina, France, Russia, Ukraine, Belarus, Moldova, Uzbekistan, Holland, South Africa and more. Contact us if your country is not listed — we regularly work with attorneys in additional jurisdictions worldwide.

Yes. Each US state has its own inheritance and succession laws. The foreign legal opinion must specifically address the laws of the state where the deceased was domiciled at the time of death. R. Eliyahu Law Office provides foreign legal opinions for all 50 US states, including New York, California, Florida, Texas, Arizona, New Jersey, Illinois, Pennsylvania and all others. Contact us to confirm coverage for your specific state.

Preparation of a foreign legal opinion is prepared quickly — once we receive the necessary information, we work fast. The exact timeline depends on the specific circumstances of the case. Once filed with the Registrar of Inheritance Affairs, a succession order or will probate order is generally issued within 2 to 6 months for straightforward cases. We will give you a clear timeline at the free initial consultation.

R. Eliyahu Law Office charges fair and competitive prices for foreign legal opinions in Israel. The exact fee depends on the country involved and the complexity of the inheritance case. We provide a clear, transparent fee quote at the free initial consultation, with no hidden costs. Contact us for an affordable quote. The service can be arranged entirely remotely, with no travel required.

Yes. R. Eliyahu Law Office regularly handles inheritance matters and foreign legal opinion cases for clients in the United States, Canada, the UK, Brazil and other countries entirely remotely. All documents can be sent electronically or by post. Powers of attorney are notarized and apostilled abroad. The application is filed with the Registrar of Inheritance Affairs in Israel entirely by our office on your behalf. You will receive updates by email, phone or video call. No visit to Israel is required at any stage.

A succession order (Tzav Yerusha) is issued when the deceased died without a valid will. The estate is distributed according to the inheritance laws of the country of domicile as explained in the foreign legal opinion. A will probate order (Tzav Kiyum Tzavaa) validates and enforces an existing will. In both cases, when the deceased was a foreign resident, a foreign legal opinion is required as part of the application to the Registrar of Inheritance Affairs.

Under the Israeli Supreme Court ruling in CA 6796/97 Berg Jacob & Sons v. Berg East Imports, a foreign law expert is an attorney or jurist who practices within the foreign legal system — either in active practice or in an academic capacity — and who has acquired genuine knowledge and experience in that system. Where the expert's opinion is not contradicted by other evidence, the court will generally accept it. The Court also adopted the criteria of Prof. Menachem Shava z"l: (1) an attorney or judge actively practicing in the foreign system; (2) a jurist in an official role requiring knowledge of foreign law; or (3) any person who has acquired comprehensive knowledge of the foreign legal system through their work. R. Eliyahu Law Office operates in full compliance with these requirements for every foreign legal opinion we prepare.

Yes. We provide foreign legal opinions specifically addressing the validity and enforceability of US Trusts, including Living Trusts and Testamentary Trusts, in the context of Israeli inheritance proceedings. In the United States, Trusts are widely used for estate planning to avoid probate. However, Israeli authorities may not automatically recognise a Trust without a formal legal opinion. Our opinion explains the legal status of the Trust under the relevant US state law, identifies the beneficiaries and their rights, and provides guidance on how to transfer Trust assets held in Israel to the rightful beneficiaries.