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United States
US foreign law expert: the opinion is prepared and signed by one of the firm's attorneys licensed in the United States, who under the Berg ruling may opine on the law of all 50 states.
The United States is our largest source of engagements. We cover all 50 US states - from New York and California through Florida, Texas, New Jersey, Illinois, Massachusetts, Pennsylvania, Arizona and every other state. Each state has its own probate code; the opinion is tailored to the specific state of the deceased's domicile. We also handle US Living Trusts and Testamentary Trusts in Israeli proceedings.
The Power of Attorney is executed before a US notary and apostilled by the relevant State Secretary of State. The firm maintains a Los Angeles office (+1-310-735-4210). Coordination with US tax counsel is straightforward - we provide documentation suitable for IRS Form 8938 (FATCA), FBAR (FinCEN 114), and Schedule D filings.
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Canada
Canadian law expert: the opinion is prepared and signed by a lawyer called to the bar of the relevant province - Ontario, Quebec, British Columbia or Alberta.
We represent Canadian families and heirs across all provinces. The legal framework differs significantly by province - Quebec operates under civil law (the Code civil du Québec), while Ontario, BC, Alberta and other provinces operate under common-law inheritance principles. The opinion addresses the relevant provincial law: Ontario's Succession Law Reform Act, BC's Wills, Estates and Succession Act, Quebec's droit successoral, or the applicable Alberta legislation.
Two examples of why the province matters. In Ontario, where there is no will, the surviving spouse first receives a preferential share of $350,000 under Part II of the Succession Law Reform Act, and only the rest is shared with the children. Ontario's own probate document, the Certificate of Appointment of Estate Trustee, is not acted on by Israeli institutions, so the Israeli assets still need an Israeli order. In Quebec, a notarial will needs no probate at all at home, and the opinion has to explain this to the Registrar, who expects one. Canada has been a party to the Hague Apostille Convention since January 2024.
The Power of Attorney is executed before a Canadian notary or lawyer and apostilled or authenticated under provincial procedures. We provide documentation suitable for CRA reporting on inherited Israeli assets, including coordination with Canadian estate counsel where needed.
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United Kingdom
English law expert: the opinion is prepared and signed by a solicitor or barrister admitted in England and Wales and regulated by the relevant professional body.
We represent British heirs and executors across England, Wales, Scotland and Northern Ireland. The opinion addresses the relevant succession law - including intestacy under the Administration of Estates Act 1925 for England and Wales, or the Succession (Scotland) Act 1964 for Scotland - and the relationship between an English Grant of Probate (or Scottish Confirmation) and Israeli proceedings.
The Power of Attorney is executed before a UK notary public or solicitor, then apostilled by the FCDO in Milton Keynes. We provide documentation suitable for HMRC reporting on inherited foreign assets and coordinate with UK probate solicitors for parallel proceedings where needed.
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Australia
Australian law expert: the opinion is prepared and signed by a solicitor admitted in the relevant State or Territory - NSW, Victoria, Queensland or Western Australia.
We represent Australian heirs and executors from Sydney, Melbourne, Brisbane and elsewhere. The opinion addresses the inheritance law of the relevant Australian state or territory - New South Wales Succession Act 2006, Victoria's Administration and Probate Act 1958, Queensland's Succession Act 1981, and equivalent legislation in WA, SA, ACT and Tasmania.
The Power of Attorney is executed before an Australian notary public and apostilled by DFAT. Zoom calls are scheduled at hours that suit Australia. We provide documentation suitable for ATO reporting on inherited foreign assets.
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South Africa
South African law expert: the opinion is prepared and signed by one of the firm's attorneys admitted in South Africa.
The South African Jewish community has close family ties to Israel, and many estates include an apartment or savings here. Where there is no will, the opinion addresses the Intestate Succession Act 81 of 1987; where there is one, the Wills Act 7 of 1953 on its formal validity. It also explains the role of the Master of the High Court and of letters of executorship, which settle the estate in South Africa but are not acted on by Israeli banks or the Land Registry.
South Africa is a party to the Hague Apostille Convention, so South African death certificates, wills and court documents are apostilled for use in Israel. Consultations are by Zoom, phone or WhatsApp, in English.
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Israelis Living Abroad
We regularly represent Israelis living abroad who need such an opinion in Israel - either because they themselves are the deceased's heirs domiciled abroad, or because they are managing an estate that includes both Israeli and foreign elements. The firm's longstanding bilingual practice (Hebrew and English) is particularly suitable for this population.
Service is provided in Hebrew or English according to the client's preference. The Power of Attorney can be executed before an Israeli consulate abroad or before a local notary with subsequent Apostille - we provide instructions specific to the country and city where the client resides.
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France
French law expert: the opinion is prepared and signed by an avocat admitted to a French bar, in coordination with a notaire where the estate requires it.
The Franco-Israeli connection runs deep - many French families hold property in Netanya, Tel Aviv, Herzliya, Ashdod and Jerusalem alongside their French estates. The opinion addresses the French Civil Code rules of forced heirship (réserve héréditaire), the role of the notaire in French succession, and the application of EU Succession Regulation 650/2012 where relevant.
The Power of Attorney is prepared in English and executed before a French notaire, then apostilled by the relevant cour d'appel. We coordinate closely with French notaires on parallel succession proceedings where the estate spans both jurisdictions.
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Spain
Foreign law expert: the opinion is prepared and signed by an attorney holding an active practising licence in the relevant jurisdiction - meeting the standard set by the Israeli Supreme Court in the Berg ruling (CA 6796/97).
Spain is particularly relevant following the Sephardic citizenship laws, which created significant new legal and family ties between Spain and Israel - including property purchases and inheritance.
The Código Civil establishes the legítima - two-thirds of the estate is reserved for children and cannot be freely disposed of by will. Spain also has separate regional inheritance regimes (derecho foral) in Catalonia, Navarre, Aragon and Galicia, which differ substantially from the general Civil Code. The opinion must therefore identify the precise autonomous community. Spain is bound by EU Succession Regulation 650/2012.
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Portugal
Foreign law expert: the opinion is prepared and signed by an attorney holding an active practising licence in the relevant jurisdiction - meeting the Berg standard (CA 6796/97).
Like Spain, Portugal became highly relevant to Israeli families through its Sephardic citizenship programme, producing a marked increase in cross-border estates.
The Portuguese Código Civil establishes the quota indisponível - the reserved portion protecting the surviving spouse, descendants and ascendants. Portuguese succession proceeds through the habilitação de herdeiros before a notary rather than through a court, and the opinion must explain this distinction to the Israeli Registrar. Portugal is bound by EU Succession Regulation 650/2012.
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Italy
Foreign law expert: the opinion is prepared and signed by an attorney holding an active practising licence in the relevant jurisdiction - meeting the Berg standard (CA 6796/97).
We represent Italian families - one of the oldest Jewish communities in Europe. Many Italian families hold assets in both countries.
The Italian Codice Civile, Book Two, establishes the legittima - the reserved share protecting the spouse, children and parents. Where one child survives, half the estate is reserved; with two or more, two-thirds. The presence of a surviving spouse alters the calculation. In the absence of a will, successione legittima rules determine the order of heirs by degree of kinship. Italy is bound by EU Succession Regulation 650/2012.
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The Netherlands
Foreign law expert: the opinion is prepared and signed by an attorney holding an active practising licence in the relevant jurisdiction - meeting the Berg standard (CA 6796/97).
Under Section 137 of the Succession Law, the estate of a Dutch resident who left assets in Israel is governed by Dutch law - the law of the deceased's domicile - and not by Israeli law. Dutch succession rules differ from Israel's in ways the Registrar will not expect, so the opinion has to spell them out.
Dutch succession law is codified in Book 4 of the Burgerlijk Wetboek. The legitieme portie gives children a reserved claim equal to half of their intestate share - a monetary claim rather than a right in specific assets. The Netherlands also applies a distinctive regime under which the surviving spouse receives the entire estate while children hold a deferred monetary claim - a structure with no Israeli equivalent, requiring express explanation in the opinion.
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Brazil
Brazilian law expert: the opinion is prepared and signed by an advogado registered with the OAB.
The Brazilian-Israeli community is one of the largest Jewish communities in Latin America, with deep ties between São Paulo and Tel Aviv. The opinion addresses the Brazilian Civil Code inheritance rules - particularly the legítima (forced share) for descendants, ascendants and spouses under Articles 1.845 and 1.846.
The Power of Attorney is executed before a Brazilian tabelião and apostilled under the Hague Apostille Convention. Service is provided in Portuguese, Spanish, English or Hebrew.
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Argentina and Latin America
Argentine law expert: the opinion is prepared and signed by an abogado admitted to the local bar, in coordination with an escribano público where required.
The Argentine Jewish community is the largest in Latin America. We represent Argentine heirs and clients across Latin America (Argentina, Chile, Uruguay, Mexico, Peru, Colombia). The opinion addresses the Argentine Civil and Commercial Code rules of sucesión, including forced heirship and partición.
Full service in Spanish. The Power of Attorney is executed before an Argentine escribano público and apostilled under the Hague Convention.
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Russia, Ukraine and the CIS
Russian and Ukrainian law expert: the opinion is prepared and signed by an attorney licensed in the relevant jurisdiction and registered with its local bar.
The Russian-speaking community is one of the largest in Israel. We represent heirs and clients in Russia, Ukraine, Belarus, Moldova, Uzbekistan and other CIS countries. The opinion addresses the relevant national inheritance code - the Russian Civil Code Articles 1110-1185 on succession, the Ukrainian Civil Code, or equivalent legislation.
The Power of Attorney is executed before a local notary; apostille and authentication procedures vary by country, and we provide specific country-by-country instructions. Service is available in Hebrew, English and Russian.
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Belarus, Moldova and Uzbekistan
Foreign law expert: the opinion is prepared and signed by an attorney holding an active practising licence in the relevant jurisdiction - meeting the Berg standard (CA 6796/97).
Following the large waves of immigration to Israel, many Israeli families retained apartments, bank accounts or registered rights in these countries - and vice versa.
All three jurisdictions inherited the Soviet Civil Code structure: a statutory order of heirs by degree of kinship, alongside recognition of wills executed before a local notary. Each maintains a reserved share for minors, spouses and parents unable to work. Succession proceedings in these countries are generally conducted before a notary rather than a court - a procedural point the opinion must make explicit to the Israeli Registrar.
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Clients Worldwide
We provide foreign legal opinions for clients across the world - including the Jewish communities of Germany, Switzerland and Belgium. Each country has its own inheritance law and apostille procedure; the principles of the Hague Apostille Convention generally apply where the country is a member.
The first consultation includes a country-specific assessment of the apostille requirements, the relevant inheritance law to be addressed in the opinion, and the local notarization procedures. Over 19+ years of cross-border practice, the firm has handled opinions for clients in more than 20 countries.
