A Parent Died Abroad and Left Assets in Israel: What Do U.S. and Canadian Heirs Need to Know?

When a loved one passes away and leaves assets in Israel, heirs living in the United States

or Canada may suddenly find themselves dealing with an unfamiliar legal system, language barriers, and procedures they were not expecting.

Many families assume that if there is already a valid U.S. or Canadian will, the inheritance process will automatically apply to assets located in Israel. However, this is not always the case.

Israeli authorities, banks, and other institutions generally require Israeli legal documentation before inherited assets in Israel can be transferred or accessed.

Does a U.S. or Canadian Will Apply to Assets in Israel?

A foreign will, such as a U.S. or Canadian will, may be recognized in Israel, but additional legal steps are usually required.

When a deceased person owned assets in Israel, such as:

•  An apartment or other real estate;

•  A bank account;

•  Investment accounts;

•  Other financial assets;

the heirs may need to apply for an Israeli Probate Order based on the foreign will.

The purpose of this process is to allow Israeli authorities and institutions to recognize the deceased person's wishes and permit the transfer of the Israeli assets to the rightful beneficiaries.

What Is an Israeli Probate Order?

An Israeli Probate Order is a legal order issued by the Israeli Inheritance Registrar confirming the validity of a deceased person's will and authorizing the distribution of the estate according to that will.

If there is no valid will, heirs may need to apply for a Succession Order, which determines

inheritance rights according to Israeli inheritance law.

The appropriate process depends on the circumstances of the estate and the documents available.

Why Can the Process Be Challenging for Overseas Heirs?

For heirs living in the United States or Canada, managing an Israeli inheritance can be complicated because:

•  The legal procedures are different from those in the U.S. and Canada;

•  Documents may need to be prepared, translated, notarized, and submitted in Israel;

  
  

•  Communication with Israeli authorities and financial institutions may be required;

•  The heirs may not be familiar with Israeli requirements or terminology;

•  Traveling to Israel may be difficult or unnecessary if the process is managed correctly.

• Many heirs are able to complete the process from abroad with proper legal guidance.

What Happens After the Probate Process?

Once the required Israeli legal order is obtained, additional steps may be needed to transfer and manage the inherited assets.

This may include:

•  Contacting banks and financial institutions;

•  Transferring funds;

•  Updating ownership of real estate;

•  Managing or selling inherited property;

•  Coordinating with other professionals, such as accountants or real estate attorneys.

Can Inherited Real Estate in Israel Be Sold?

If the inheritance includes Israeli real estate and the heirs wish to sell the property, additional legal and practical steps are required.

This may involve coordinating with Israeli real estate and tax professionals, handling documentation, and ensuring that the sale process is completed properly.

Having a professional familiar with both the inheritance process and the needs of overseas heirs can help make the process smoother and more efficient.

How We Help U.S. and Canadian Heirs

At Mirit Hoffman Law Office, we assist U.S. and Canadian heirs with Israeli inheritance matters, including recognition of foreign wills in Israel, obtaining Israeli Probate Orders or Succession Orders, and assisting with the transfer and administration of inherited assets.

We understand that many heirs are managing Israeli assets from a distance. Our goal is to provide guidance, reduce uncertainty, and help families navigate the Israeli legal process as efficiently as possible.

In many cases, our clients are able to complete the process without traveling to Israel.

The content of this article is intended to provide a general guide to the subject matter and is not a substitute for legal consultation. Specific legal advice should be sought in accordance with the particular circumstances.