Many Americans who make aliya keep their investment and retirement accounts in the U.S., which makes good sense for access, diversification, and continuity. The accounts themselves are not usually the problem. If a brokerage firm does not want to keep clients overseas, it is usually easy to switch to a cross-border investment specialist. The real trouble begins when someone passes away and the estate plan was never updated after the move to Israel.
Israeli Wills Usually Work Well
In my experience, an Israeli will, once officially translated into English, is usually accepted by American custodians like banks and brokerage firms. Where families run into delays is when they rely on an old American will. It may look fine in New York, but it often does not follow Israeli probate requirements. That mismatch forces heirs to jump through extra hoops just to release assets that should have been available much sooner.
The Transfer Certificate Hurdle
Even with a solid Israeli will, U.S. custodians sometimes require additional paperwork. If the account holder was an American citizen, they often ask for a transfer certificate from the IRS, which confirms that estate tax obligations have been settled. This process takes time, so heirs need to apply quickly or risk months of waiting.
Why Shortcuts Rarely Help
Some people turn to Transfer on Death (TOD) accounts as a supposed workaround. While TODs can bypass probate in the U.S. when everyone lives in America, they don’t eliminate the need for Israeli probate or IRS clearances once the family is living in Israel. They also fall short in more complex family situations.
The Better Approach
The smarter solution is simple: keep your U.S. accounts, but make sure your estate plan is updated for life in Israel. A well-drafted Israeli will, supported by cross-border professionals, ensures your heirs avoid unnecessary delays. The designation of Trust and Estate Practitioner (TEP) signals advisors who are trained to anticipate multi-jurisdictional issues and help design plans that truly work across borders. It’s worth asking: is your estate plan truly in order?
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This article provides general information, not legal or financial advice. Always consult with a qualified professional about your specific situation. Douglas Goldstein, CFP®, TEP is the director of Profile Investment Services, Ltd. www.Profile-Financial.com. He is a licensed financial professional both in the U.S. and Israel. Call (02) 624-2788 for a consultation on how to set up your American assets to meet your financial goals. Securities offered through Portfolio Resources Group, Inc. Member FINRA, SIPC, MSRB, FSI. The opinions expressed are those of the author and not those of Portfolio Resources Group, Inc. or its affiliates. Neither PRG nor its affiliates provide tax or legal advice.
Published December 17, 2025.