Pre-Aliyah planning is about getting three things right before you become an Israeli tax resident: when residency starts, what you hold on that date, and how each asset will be taxed in Israel and in the country you leave. Mistakes here are expensive because many of them cannot be fixed after the move.
1. Pin down your residency start date and status
Your status — new immigrant (Oleh Hadash), veteran returning resident (10+ years abroad) or returning resident — decides which benefits you get and for how long. Your residency start date decides which rules apply: from 1 January 2026, new arrivals lose the exemption from reporting foreign income (the tax exemption itself stays). See returning resident vs. new immigrant and Olim reporting rules from 2026.
Also check when you stop being resident in your current country. The two dates rarely line up neatly, and treaty tie-breaker rules (permanent home, center of vital interests) decide years where both countries claim you.
2. List what you will own on day one
- Bank and brokerage accounts, including funds that may be PFICs for US citizens
- Shares in private companies and any company you control
- Stock options, RSUs and other equity — including the grant and vesting timeline
- Pensions and retirement accounts (401(k), IRA, SIPP, RRSP, occupational plans)
- Real estate abroad and any rental income
- Trusts where you are settlor or beneficiary
- Crypto assets, with acquisition records
3. Decide what to realize before vs. after the move
In Israel, gains on foreign assets during the exempt period are generally exempt. That does not mean selling after Aliyah is always better: your current country may tax you on departure or keep taxing for a period after you leave (for example Canada's departure tax, or the UK's temporary non-residence rules), and US citizens are taxed by the US wherever they live. Run both sides before selling anything.
4. Equity compensation
Options and RSUs granted for work done abroad but vesting after Aliyah are split by source: part relates to work abroad, part to work in Israel. The Israeli part is taxable. Plan grant timing and keep records of where you worked. See RSU taxation in Israel and equity when changing countries.
5. Companies, LLCs and trusts
A foreign company you manage from Israel after the move can become Israeli-resident. US LLCs raise classification issues. Trusts with an Israeli-resident settlor or beneficiary fall into specific Israeli trust regimes. Each needs a decision before you arrive — see foreign companies and Aliyah and foreign trusts and Olim.
6. Pensions
Foreign pension income and withdrawals have their own rules, which can continue past the exempt period. Check treaty treatment and whether to keep, roll over or draw down before moving. See pensions and 401(k) after Aliyah.
7. Build the record you will need later
Keep year-end statements on the residency date, acquisition costs, travel records showing where you worked, and copies of your Teudat Oleh or returning-resident certificate. These records support the exemption now and the transition in year 11.
Sources
- Income Tax Ordinance [New Version], Sections 1 (residency), 14 (new immigrants and returning residents) and 97(b) (gains).
- Income Tax Ordinance, Amendment 272 — reporting by new residents from 2026.
- Israel Tax Authority — guidance for new immigrants and returning residents (gov.il).
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