For families · Israel and abroad

Families in Israel and abroad – Israeli estate planning for olim and international families

An Israeli will alongside your will in the US or the UK, an attorney-in-fact who lives overseas, heirs in another country – and terms that sound the same but aren’t. The Israeli side, explained in plain English and coordinated with your advisers abroad.

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For Families · November 4, 2026

The short answer

When your family lives partly in Israel and partly abroad, your planning has to work under two legal systems at once. An American or British document is not always read in Israel the way you might expect.

In outline: a succession is governed by the law of the deceased’s domicile at death – the place where their centre of life was (sections 135 and 137 of the Succession Law, 5725-1965). A will made abroad can be valid in form in Israel (section 140), but a later will can revoke an earlier one, wherever either was made (section 36). And an ordinary power of attorney – including one signed abroad – ends when the grantor loses capacity (section 14(a) of the Agency Law, 5725-1965); in Israel, a lasting power of attorney (yipui ko’ach mitmashekh) continues (section 32KF of the Legal Capacity and Guardianship Law, 5722-1962).

We handle the Israeli side, in English or Hebrew, in coordination with your advisers abroad – and on tax and reporting, in coordination with your accountant.

1. An Israeli will alongside your will abroad

Under section 140 of the Succession Law, a will is valid in form if it is valid under any one of several laws: Israeli law, the law of the place where it was made, the law of the testator’s domicile or habitual residence, or the law of their nationality – at the time the will was made or at death; and, for immovable property, also the law of the place where it is situated. Israel is a party to the 1961 Hague Convention on the form of wills, in force for Israel since 10 January 1978.

Form is only one question. Under section 137, the succession is governed by the law of the deceased’s domicile at death, subject to sections 138 to 140; “domicile” means the place where a person’s centre of life is (section 135) – not their citizenship. Under section 139, capacity to make a will is governed by the law of the testator’s domicile when the will is made.

With two wills, the key question is revocation. Under section 36(b), a later will revokes an earlier one to the extent their provisions conflict; and under section 36(a), an express revocation of all prior wills, made in one of the forms for making a will, revokes them all – including a will made in another country. Where a foreign law governs the succession under section 137, that law’s revocation rules may apply.

When we draft an Israeli will (tzava’a) alongside an existing will abroad, the assets each will covers and the wording of each revocation clause are coordinated with your advisers abroad. Since 1 July 2023, where the original will is outside Israel and cannot be produced, and a probate order was granted abroad, the foreign order may be filed instead, proved as a foreign document (section 68(b)). Read more: An Israeli will alongside a foreign will, and our wills page.

2. A lasting power of attorney across borders

A lasting power of attorney lets you choose, while you are able to, who will make decisions for you – on property, personal and medical matters – if you can no longer do so yourself. Both the grantor and the attorney-in-fact may live outside Israel.

An attorney-in-fact who lives abroad

Your son in New Jersey or your daughter in London can be appointed. The attorney-in-fact signs their consent either by video conference – which the Administrator General (Apotropos Klali) has allowed for attorneys-in-fact since 14 February 2022 – or before an Israeli lawyer where they live. Once the power of attorney is in force, the attorney-in-fact can download a confirmation that it is in force, with a digital apostille, from their personal area on gov.il, for an official fee of NIS 41 (2026; the fee is updated from time to time).

A grantor who lives abroad

The grantor always signs in person before the lawyer; signing by video is not available to the grantor. A grantor living abroad may sign there, before an Israeli lawyer who has completed the Administrator General’s training. Israeli consulates do not certify signatures on a lasting power of attorney. Under section 77(b) of the Legal Capacity and Guardianship Law, the validity and scope of a lasting power of attorney are governed by the law of the grantor’s domicile on the day it is made; where the grantor is domiciled abroad, an opinion on the foreign law is required. Adv. Yona Schwebel is certified by the Administrator General to draft lasting powers of attorney. Read more: A lasting power of attorney when the children live abroad, and our lasting power of attorney page.

A power of attorney you already signed abroad

Under section 14(a) of the Agency Law, an agency ends on the grantor’s loss of capacity – and that is the rule in Israel even when the document is called “durable”. To have a lasting power of attorney made abroad recognised in Israel, the Administrator General suggests applying to the Family Court for declaratory relief, with proof of the foreign law. Read more: Is a US durable power of attorney valid in Israel?

3. When the heirs live abroad

A probate or inheritance order granted abroad does not replace an Israeli order (sections 39, 66 and 71 of the Succession Law). Since Amendment No. 18 to the Succession Law (in force 1 July 2023), an application concerning a deceased person domiciled abroad is no longer transferred automatically to the court, and the Registrar for Inheritance Matters (Rasham le’Inyanei Yerusha) may decide it. Heirs abroad can sign before an Israeli consul, who may exercise the powers of a notary abroad (section 50A of the Notaries Law, 5736-1976), or before a local notary with an apostille. According to the Administrator General’s 2025 activity summary, the average handling time at the Registrar is about 40 days, including the publication period. Step by step: Do heirs living abroad have to come to Israel?

4. Same words, different law

If you planned your estate in the US or the UK, some of the terms you know have an Israeli counterpart with a similar name – and different rules. The table shows the Israeli side only.

The term you know	The Israeli instrument	The foreign side
Durable POA / Lasting POA	Lasting power of attorney (yipui ko’ach mitmashekh): made on the prescribed form (section 32M(a) of the Legal Capacity and Guardianship Law), signed before a lawyer who has completed the training (section 32N(a)) and deposited with the Administrator General – deposit is a condition of its taking effect (section 32Q(a)). The agency does not end merely because the grantor has ceased to have capacity (section 32KF). Lasting powers of attorney →	In coordination with your advisers abroad
Special needs trust	A trust (ne’emanut) under the Trust Law, 5739-1979: created by law, by contract with a trustee or by an endowment deed (section 2). An endowment (hekdesh) requires a written deed – signed before a notary, a will, or a payment instruction under section 147 of the Succession Law (section 17). A beneficiary’s right cannot be assigned, pledged or attached unless the deed allows it, or the court allows it to meet maintenance or taxes owed by the beneficiary or, in special circumstances, other debts (section 20). The effect on benefits is checked with the relevant authorities. Planning for a child with a disability →	In coordination with your advisers abroad
Living will	Advance directives (hanchayot mukdamot) within the lasting power of attorney – on personal, property and medical matters (sections 32M(b) and 32LA–32LB of the Legal Capacity and Guardianship Law). Directives under the Dying Patient Law, 5766-2005 are not part of the lasting power of attorney (sections 32F(b)(5) and 32LC).	In coordination with your advisers abroad
A prenuptial agreement (also called a premarital or financial agreement)	An Israeli prenuptial agreement (heskem mamon) under the Spouses (Property Relations) Law, 5733-1973: in writing (section 1), approved by the Family Court or the religious court (section 2(a)); before or at the wedding it may instead be authenticated by the marriage registrar (section 2(c)), and before the wedding also by a notary (section 2(c1)). Without an agreement, the statutory balancing-of-resources regime applies (sections 3–5). Second marriages and prenuptial agreements →	In coordination with your advisers abroad

On the law that governs a prenuptial agreement: under section 15 of the Spouses (Property Relations) Law, property relations between spouses are governed by the law of their domicile at the time of the marriage, but the spouses may, by agreement, set and change them in accordance with the law of their domicile at the time the agreement is made.

5. Working in English

Meetings, correspondence and drafts are in English or Hebrew – your choice – on Teams, or if needed at your home or at the office, at a time that suits your time zone. Some Israeli documents are still prepared in Hebrew. A lasting power of attorney is made on the prescribed online form (section 32M(a)), and that form is in Hebrew; the Administrator General has published official English translations of the forms. The lawyer explains the document to the grantor in plain language the grantor understands (section 32N(c)), and where the grantor does not read Hebrew, the translation and explanation are recorded in the form’s adjustments section.

For wills, sections 19 and 20 of the Succession Law do not prescribe the language of a will. A will made before an authority in a language the testator does not understand is read to them in translation (section 22(c)), and a document filed with the Registrar in a foreign language other than English needs a notarised translation (regulation 54A of the Succession Regulations, 5758-1998).

6. Where to start

The cross-border dimension runs through every family service:

Wills – including an Israeli will alongside a foreign will.
Lasting powers of attorney and advance directives – including a grantor or attorney-in-fact abroad.
Planning for a child with a disability – a trust, turning 18 and a letter of wishes.
Second marriages and blended families – a prenuptial agreement, mutual wills and the family home.

Every family matter begins with a Roadmap Meeting – 60 minutes, on Teams, or if needed at your home or at the office:

Mapping – who is in the family, what you own and where, and what is already signed in each country.
Written recommendations – what to do and in what order, with a clear written quote before any work starts.
Drafting, signing and deposit – drafts reviewed with you, in English or Hebrew, followed by formal signing and deposit.

Frequently asked questions

I already have a will in the US or the UK. Is it valid in Israel?

As to form – yes, if it is valid under one of the laws listed in section 140 of the Succession Law, including the law of the place where it was made. Other questions, such as which law governs the succession, are decided under sections 137 to 139. See An Israeli will alongside a foreign will.

Will a new Israeli will cancel my will abroad?

Under section 36 of the Succession Law – if it expressly revokes all prior wills, or to the extent its provisions conflict with the earlier will. These are the rules of Israeli law; where a foreign law governs the succession, its revocation rules may apply. That is why the revocation clauses are coordinated with your advisers abroad.

Our children live abroad. Can they be our attorneys-in-fact?

Yes. An attorney-in-fact may live abroad, and signs their consent by video conference or before an Israeli lawyer where they live. See A lasting power of attorney when the children live abroad.

I live abroad. Can I make an Israeli lasting power of attorney without coming to Israel?

The grantor signs in person before an Israeli lawyer who has completed the Administrator General’s training, and the signing can take place abroad. Israeli consulates do not certify these signatures. Where the grantor is domiciled abroad, the validity and scope of the document are governed by the law of the grantor’s domicile on the day it is made, and an opinion on the foreign law is required (section 77(b) of the Legal Capacity and Guardianship Law).

I have a US durable power of attorney. Will it work in Israel?

Under section 14(a) of the Agency Law, an agency ends on the grantor’s loss of capacity. An Israeli lasting power of attorney continues after loss of capacity (section 32KF of the Legal Capacity and Guardianship Law). See Is a US durable power of attorney valid in Israel?

I don’t read Hebrew. Can I sign Israeli documents?

Meetings, correspondence and drafts can all be in English. The lasting power of attorney form is in Hebrew; the lawyer explains it in a language you understand (section 32N(c) of the Legal Capacity and Guardianship Law), and the translation and explanation are recorded in the form’s adjustments section.

The above is general information on Israeli law only, current as of the date of publication, and does not constitute legal advice or a substitute for advice on your specific circumstances. Consult a lawyer before acting.

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