In the past, the Firm’s partners were involved in all essential decision-making areas of the Israel Tax Authority and were among the leaders in planning the Authority’s policy. The cumulative experience of the partners is reflected in their handling of hundreds of different issues, many of which are complex and unique, reflecting the Firm’s quality and professionalism.
Advocate Moshe Mizrahi is the Firm’s founding partner. Advocate Mizrahi is one of the top lawyers in the field of taxation in Israel and served as the Legal Advisor of the Tax Authority between 2004-2011. Previously, he served as Legal Advisor to the Customs and VAT Department and as Head of the Fiscal Department of the Jerusalem District Attorney’s Office (Civil and Criminal), while leading many legislative processes in the various taxation fields and was responsible for drafting the legal positions of the Tax Authority. His extensive understanding of the various legislative processes, which incorporates the various aspects of the law, is expressed in his representation of many clients vis-à-vis the tax authorities, in presenting creative solutions in the framework of dealing with the Tax Authority, both in the civil and criminal fields, and in managing complex litigation cases, which involve the development of new precedents. Advocate Mizrahi is considered one of the most acceptable tax lawyers in Israel, being accepted by the highest-ranking decision-makers of the Israel Tax Authority. Under this umbrella, Advocate Mizrachi has represented the Ministry of Absorption, the Federation of Hedge Funds and the Institute of Certified Public Accountants, in various issues with the Tax Authority.
Advocate Eldad Noach is a partner and has extensive knowledge and experience in a variety of fields of tax law. During his tenure at the Tax Authority, Advocate Noach served as Head of the Mergers and Acquisitions Department (Structural Changes), and between 2007-2011, as Head of its Professional Practice Department. As head of this division, he was in charge of various units including structural changes, capital markets, employees’ options, and provident funds. Advocate Noach has headed the Tax Ruling Institute and was a prominent player in pre-ruling tax decisions for key Israeli businesses on various tax issues. In recent years, Advocate Noach has been involved in several innovative and systemic taxation decisions in the area of restructuring and the capital markets – investment funds. Advocate Noach represents many voluntary disclosure cases with the various Income Tax Assessing Offices.
Amit Kriegel is a partner and is among Israel’s leading tax attorneys. Advocate Kriegel headed the Encouragement of Capital Investment Laws Department, played a crucial role in setting policy for industrial tax incentives, and took part in the formation and legislation of Amendment 68 to the Capital Investment Encouragement Laws. He has also served as Legal Advisor to the Large Enterprises Tax Assessing Office, the Gush Dan Income Tax Assessing Office. Since the establishment of the Firm, Advocate Kriegel has dealt with a variety of complex legal issues in the various areas of taxation (income tax, value-added tax, encouragement laws), in many cases in the framework of in-depth opinions that would influence the market’s conduct vis-à-vis the Tax Authority.
Areas of Specialization
Income tax – taxation of corporations and individuals – The Firm provides legal counsel to companies and individuals in all tax aspects. The Firm is involved in the analysis of tax aspects at the stage of transaction planning, including initial and unique transactions, where the business world precedes the development of tax laws, and representation in the framework of assessment and appeal proceedings in the courts, including the Supreme Court. In addition, the Firm handles preliminary approvals from the pre-ruling department and provides legal opinions.
International taxation – The practice of international taxation focuses on trust structures, tax benefits for new immigrants and returning residents, reporting requirements to the tax authorities, and taxation arrangements applying to foreign companies with an affinity to Israel.
Encouragement laws, incentives and research and development laws – The Firm advises on all aspects of the various encouragement laws, including solutions to meet eligibility requirements, and support requests for approval from the state authorities, tax benefits for research and development activities, tax benefits for rental buildings, and for renewable energy projects. The Law of Encouragement field at the Firm is managed by Advocate Amit Kriegel, who was one of the outstanding designers of the Tax Authority’s policy in this area.
Structural changes (mergers, divestitures, and asset transfers) – The involvement in structural changes is intended to enable corporations operating within a corporate framework to organize the structure of its holdings to reduce the friction between the economic-legal considerations of the group’s structure and the tax considerations in Israel and abroad. This field is headed by Advocate Eldad Noach, who served as Head of the Mergers and Divestitures Department at the Tax Authority and was one of the prominent designers of the Tax Authority’s policy on the subject.
Tax offenses (criminal taxation) – The involvement in tax offenses work includes handling plea bargains and applying for ransom and is not detached from dealing with the treatment of the civilian assessment. Advocate Moshe Mizrahi is involved in this sub-practice and has accumulated extensive experience in criminal cases during the period during which he served as the Head of the Tax Department of the Jerusalem District Attorney’s Office and during his tenure as the Legal Advisor of the Tax Authority.
Voluntary disclosures – Many Israelis hold bank accounts abroad. Income from these accounts may be subject to tax in Israel. The tax authority acts to increase enforcement in this matter and even offers taxation arrangements relief in the context of voluntary disclosure procedures, which enable immunity from criminal prosecution concurrent with regulating liability. The Firm advises and represents many clients in various voluntary disclosure processes.
Value-Added Tax – The Firm specializes in indirect taxes, including value-added tax, customs, purchase tax and excise tax, unique questions relating to the handling of financial institutions, non-profit organizations and transactions involving the provision of services to foreign residents or abroad, inter alia in the areas of finance, investment funds, and tourism and travel.
Real estate taxation – The Firm represents individuals and corporations in all matters related to real estate taxation, including combination transactions, sale of residential apartments, eviction transactions, trusts, liquidation of companies and transfer of land to shareholders, allocation of rights in real estate entities, TAMA 38 issues, and more.
Taxation of non-profits, voluntary associations, and public institutions – The Firm represents large non-profit organizations with the Income Tax and Value Added Tax authorities, both for preliminary tax decisions regarding the classification of the entity and for negotiations in the tax assessment process and in the courts.
The professional knowledge, the vast experience accumulated by the partners and integrating forces as a synergetic think tank, enable the Firm to provide its clients with qualitative, sincere and creative legal solutions in tax law. The Firm’s staff has set out to act in the highest professional manner, with the close and intensive support of the clients by the partners.
The Firm represents leading public and governmental organizations, financial institutions, industrial concerns, stakeholders, international corporations and foreign investors operating and investing in Israel, as well as banks, financial institutions, infrastructure, energy, aviation, real estate, industry, and commercial concerns.
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