• Monte Silver, Tax lawyer

Israeli banks become agents of the US for Estate Tax enforcement

True, the Israel

i government was the only government to file a comment to the GILTI proposed regulations that raised the issue of the impact of GILTI on Americans living abroad. See www.silvercolaw.com/blog/israel-comes-out-against-the-impact-of-gilti-on-small-busineses

However, Israeli banks have started sending out letters to account holders who own US shares in these accounts that they may be subject to the draconian US Estate tax on these holdings. The letter says that the bank may freeze the account unless proof of payment of the US estate tax is made. I remind you - non-Americans (ordinary non-American Israelis for example) holding shares/bonds in US companies, in an Israeli bank, only have a $60,000 estate tax exemption. After that - its 20-40% estate tax!! Insane!

Does it make sense for a non-American to invest in US companies? No. Is this dis-incentive good for America? No.

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