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Complex Tax, Crypto & Voluntary Disclosure

Complex tax disputes, crypto assets and Voluntary Disclosure

Sound tax planning saves years of pain. We advise entrepreneurs, companies and international investors on complex Israeli and cross-border tax matters — structuring transactions, obtaining Pre-Rulings, defending audits, managing crypto compliance, and running Voluntary Disclosure programs — with the same partners you speak to on day one.

  • Corporate & personal tax planning
  • Pre-Rulings (החלטות מיסוי) from the Israel Tax Authority
  • Reorganizations under Sections 103–105
  • Objections (השגה) and District Court appeals
  • Crypto tax compliance — Bitcoin, DeFi, NFT, staking
  • AML/KYC to move crypto capital into Israeli banks
  • Voluntary Disclosure (גילוי מרצון) — foreign accounts
  • FATCA, FBAR and CRS reporting
  • Residency planning (returning resident, exit tax)
Tax planning documents on an executive desk

Planning that anticipates the Exit

Effective tax planning happens before transactions close, not after. We work with founders, executives and boards to model the tax implications of fundraising, M&A, secondaries, spin-offs and Exit — and choose the structure that maximizes after-tax outcome.

Pre-Rulings (החלטות מיסוי)

For material or novel transactions we prepare and negotiate written Pre-Rulings with the Israel Tax Authority. A well-prepared ruling gives certainty to founders, employees, buyers and investors — and often unlocks the deal.

Crypto Tax Compliance

The Israel Tax Authority classifies Bitcoin, Ethereum and digital assets as property for tax purposes — every sale, coin-to-coin swap or purchase-in-crypto is a taxable event. We advise on digital assets, DeFi, NFT and staking — including certified reports and moving capital into the Israeli banking system in strict alignment with Bank of Israel policy. Cross-border holders should also review our international tax practice, and independent crypto traders should see our CPA for freelancers:

  • Full blockchain P&L: Binance, Coinbase, Kraken, KuCoin, MetaMask
  • Real capital-gain calculation using FIFO/LIFO at transaction-date FX
  • DeFi handling: Liquidity Mining, Yield Farming, Lending, Airdrops
  • NFT taxation: minting, primary sale, secondary market, royalties
  • Staking and Mining — ordinary income vs. capital gains classification
  • Pre-Ruling on trader (business) vs. investor (capital) classification
  • End-to-end AML/KYC and Israeli banking onboarding for crypto proceeds
  • Reporting under ITA Circular 05/2018 and subsequent guidance

Voluntary Disclosure (גילוי מרצון) for undeclared foreign accounts

If you hold undeclared foreign bank accounts, securities, real estate, crypto or business activity, Voluntary Disclosure is the safe path to legalize the position — paying the tax with limited interest and obtaining criminal immunity. Acting before the ITA reaches you is essential — with FATCA and CRS, exposure is nearly automatic:

  • Anonymous preliminary track — assess issues without disclosing the taxpayer
  • Regular track / short-form track for accounts below defined thresholds
  • Full asset schedule, activity mapping and historic income reconstruction
  • FATCA handling (US accounts), FBAR and Form 8938 coordination
  • CRS — global automatic exchange of information between tax authorities
  • Bringing the funds into Israel through the local banking system
  • Legalizing undeclared foreign inheritances and complex estates

Complex tax audits and District Court appeals

For material assessments — cross-border issues, Pocket Company, Section 3(J1), Transfer Pricing, Preferred Enterprise or crypto taxation — you need advisors who know current case law and ITA practice. We lead complex matters from objection through District Court appeal:

  • Professional dissection of the assessment and identification of attack points
  • Evidence file: source documents, expert opinions, supporting case law
  • Negotiation with the ITA — settlements that save interest and penalties
  • Appeal to the District Court, Civil Tax Division
  • Joint representation with leading tax-law counsel

Objections, settlements and criminal-tax matters

If the ITA challenges a position, we represent the client through every stage: initial response, assessment (שומה), objection (השגה), settlement negotiations and — where needed — District Court appeal. In criminal-tax matters we build the accounting defense file jointly with tax-law counsel, including kofer (settlement in lieu of prosecution) applications.

FAQ

+What is a Pre-Ruling and when should we get one?

A Pre-Ruling is a binding written position from the Israel Tax Authority on a specific transaction (M&A, reorganization, ESOP structure, residency, crypto activity). We recommend one whenever the tax exposure is material and precedent is unclear.

+Do you handle tax disputes, audits and appeals?

Yes — from responding to ITA information requests, through the assessment process (שומה), objections (השגה), settlement negotiations and appeals to the District Court.

+Can you handle crypto tax compliance?

Yes. We provide crypto tax services — Bitcoin, DeFi, NFT, staking. We produce certified blockchain P&L reports, obtain Pre-Rulings, and manage AML/KYC to move capital into the Israeli banking system in strict alignment with Bank of Israel policy.

+What is Voluntary Disclosure (גילוי מרצון)?

A structured ITA process to legalize previously undeclared foreign accounts, assets or income — paying the tax with limited interest and receiving criminal immunity. With FATCA and CRS in force, exposure is nearly automatic; acting proactively is essential.

+Can you plan a corporate reorganization tax-efficiently?

Yes — we plan and execute tax-deferred reorganizations under Sections 103–105, including mergers, spin-offs and asset transfers between related entities.

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