> Cross-border note. This page explains rules, not choices. It is educational and is not personal tax advice. It keeps Israeli treatment, home-country treatment, United States domestic law and treaty treatment in separate labelled sections on purpose, because those four answers are different and blending them is how olim arrive at the wrong number.
Start with the inversion. While you were still a foreign resident, section 97(b2) of the Income Tax Ordinance exempted you from Israeli tax on capital gains from securities traded on the exchange in Israel, provided the gain was not in a permanent establishment of yours here 4. That exemption attaches to your residence status rather than to the bond, so it ends when the status ends. And the same subsection ends by disapplying itself to a defined class: gain on a bond or loan of the State of Israel or guaranteed by it, listed for trading on the exchange in Israel, whose redemption date is not more than 13 full months from the day it was issued, which the subsection itself names a short-term state loan, plus any futures contract whose underlying is directly or indirectly such a loan 4. Read that test literally, because it runs from the day of issue and not from today: a long bond with eleven months left to run was issued years ago and is not in the class. So a foreign resident sat outside the exemption on paper that was short when it was issued, and inside it on everything longer. After aliyah the long end stops being exempt as well. A lifelong Israeli never held that exemption and cannot lose it. You can lose it, and you lose it by arriving.
What does the State of Israel actually issue, and what will it be called on the screen?
Four families under one exchange classification, plus a fifth security class of its own. The Tel Aviv Stock Exchange sorts listed government debt into a Government Bonds main class with four named secondary classifications, and lists T-Bills as a separate main class alongside Shares, Convertible Bonds, Warrants and Corporate Bonds. As of 25 August 2026 the government-bond table carried 34 listed records across those four families 12.
- Shahar, which TASE labels in English `Government bond- "SHAHAR"` and classifies in Hebrew as אג"ח ממשלתי שחר. Its series are named ממשל שקלית, shekel, and each carries a stated coupon in the name itself. This is the plain vanilla Israeli government bond and the closest thing on the screen to a conventional gilt or a Treasury note 12.
- Galil, `Government bond - "GALIL"`, אג"ח ממשלתי גליל. Its series are named ממשל צמודה, linked, and the same table's linkage filter carries a CPI-Linked class 12.
- New Gilon, `Government "NEW GILON"`, אגח ממשלתי גילון חדש. Its series are named ממשל משתנה, variable, and on the English screen they are prefixed ILFRNO, floating rate note 12.
- Government Global Bond, אג"ח ממשלתית גלובלית, the fourth secondary classification in the same table, with series named ממשל גלובל. TASE's linkage filter over that table also carries a Dual Listed class 12.
- Makam is not a bond at all in the Israeli scheme. TASE files it under a main class of its own, labelled T-Bills on the English screen, sitting next to and separate from Government Bonds 12. The Bank of Israel issues it, gives its full name as מילווה קצר מועד, short-term loan, puts its redemption date at up to one year, and describes it as issued at a discount below face value, paying the face value at the end, and used by the Bank as a tool for managing monetary policy 3.
Three newcomer traps sit in that list. The first is romanisation: TASE writes שחר as "SHAHAR" on its own English screens, so that is the string to search for, not "Shachar". The second is that TASE's English word for makam is "T-Bills", which is the single most useful bridge word an American or a Briton has here and also the most misleading one, because the class sitting beside it on the same screen is a different security class with a different tax answer. The third is that the classification label and the security name are different strings, so the class reads אג"ח ממשלתי שחר while the series themselves are named ממשל שקלית, and the same split runs through ממשל צמודה for Galil, ממשל משתנה for New Gilon and ממשל גלובל for the global family 2.
There is even a spelling trap inside the word itself. The Bank of Israel writes the abbreviation with a final mem, מק"ם 3; the Tel Aviv Stock Exchange writes its main security class with a plain mem, מק"מ 2. Both mean the same instrument, and a newcomer searching one Hebrew string will miss pages carrying the other.
The Bank of Israel describes makam as considered a risk-free investment channel with a return known in advance, and as a tradable asset you can buy and sell on any exchange trading day. On the same page, last updated 25 February 2025, it sets out the structure as 12 series outstanding at any time, with one series maturing and one new series issued in its place each month 3.
How do you actually buy makam, and what replaces the TreasuryDirect or NS&I habit?
Through a securities account. The Bank of Israel's published instructions are: open a securities account at a bank or investment house, deposit the required amount and place a buy order. Makam is issued by the Bank roughly once a month and can be bought by submitting a bid into the issuance auction, which the Bank calls the primary market, and held to redemption. It can also be bought and sold on the exchange, the secondary market, on any trading day 3.
Now read that route for what is not in it. No direct-from-the-issuer retail channel appears anywhere in those published instructions. That absence is the first collision, and it is passport-shaped. An American arrives with the TreasuryDirect reflex, where the Treasury sells bills for terms running from four weeks to 52 weeks, at a minimum purchase of $100 in $100 increments, and says of the one exception, Cash Management Bills, that they "are only available through a bank, broker, or dealer. We do not sell them in TreasuryDirect", as that page read on 25 August 2026 5. A Briton arrives with the NS&I reflex, an issuer that describes itself as both a government department and an Executive Agency of the Chancellor of the Exchequer, and puts it plainly: "When customers invest in our products, they're lending to the Government" 8. Both of those are state issuers describing a counter you walk up to. The Israeli counterpart of both is a brokerage relationship you have to open before you can buy anything at all.
Opening that account is covered at investing through an Israeli bank and brokerage options. What is worth knowing before you get there is what the account is for. It is the door the Bank of Israel's own instructions point to for both the monthly auction and the exchange 3, and it also sits on the tax-collection path: section 164 of the Ordinance puts a deduction duty on whoever pays interest or is responsible for paying it, to be applied in the manner and at the rates prescribed, and closes with a sentence extending that duty to the State itself 4.
Israeli treatment: what rate applies to each family?
Not one rate. Israel splits the answer by linkage, which is not where an American or a Briton expects the line to fall. TreasuryDirect prints one tax answer for every Treasury bill it sells, whatever the term 5; GOV.UK answers the gilt capital-gains question by putting gilts on the list of assets carrying no Capital Gains Tax at all 6. Israel instead asks whether the instrument is index-linked, and lands on a flat 15% for the unlinked instruments and a ceiling of 25% for the CPI-linked one, both as of 25 August 2026.
Two provisions do the work. Section 125C(a) defines "interest" to include discount fees (`"ריבית" – לרבות דמי ניכיון`), which is the sentence that turns a makam's discount into interest rather than a capital gain in Israeli law. Section 125C(c)(1) then charges an individual's interest income at a flat 15% where the interest was paid on an asset that is not index-linked, or is only partly linked, or is not linked until redemption or repayment, while section 125C(b) charges interest at a rate not exceeding 25% elsewhere and treats that income as the top rung of the taxable-income ladder. On the capital-gains side, section 91(b)(3)(a) charges a gain on the sale of a bond, commercial paper, a milveh or a loan that is not index-linked at a rate not exceeding 15%, or 20% for a substantial shareholder, and treats the whole gain as real gain 4.
| What you hold | What it is | Coupon or discount, rates as at 25 August 2026 | Gain on sale, rates as at 25 August 2026 |
|---|---|---|---|
| Makam | Bank of Israel bill, redemption up to one year, issued at a discount and paying face value at the end 3 | The discount is interest by definition under s.125C(a), and nothing between purchase and redemption is index-linked, so the flat 15% in s.125C(c)(1) applies 4. The Bank of Israel's own page prints 15% 3 | Up to 15%: a mid-life sale is a gain on an unlinked debt instrument under s.91(b)(3)(a) 4 |
| Shahar | Shekel series, coupon stated in the name 12 | Flat 15% under s.125C(c)(1) 4 | Up to 15% on the whole nominal gain, because s.91(b)(3)(a) deems all of it real 4 |
| New Gilon | Shekel series named variable, floating rate note on the English screen 12 | Flat 15% under s.125C(c)(1) 4 | Up to 15% on the whole nominal gain, same provision 4 |
| Galil | CPI-linked series 12 | Up to 25% under s.125C(b), the ceiling that applies where the 15% limb does not 4 | Up to 25% on the real gain under s.91(b)(1) 4 |
Government Global Bond is deliberately absent from that table. The 15% limb in both sections turns on the instrument not being index-linked, and section 125C(a) makes the exchange rate the index for an asset that is denominated in or linked to foreign currency 4, so the answer for that family is not settled on the face of the Ordinance and this page does not supply one. Do not assume 15% reaches it.
Read the column headings carefully, because the Ordinance does not phrase these two rates the same way. Section 125C(c)(1) is a flat charge, worded at a rate of 15%. Sections 125C(b), 91(b)(1) and 91(b)(3)(a) are ceilings, worded at a rate not exceeding 4. Neither number is fixed by nature either: the Minister of Finance may vary the section 125C(c)(1) rate under s.125C(c)(2), and the section 91(b)(3)(a) rate under s.91(b)(3)(b), in line with a change in the index. Section 125C(d) separately displaces both the 25% ceiling and the 15% flat rate in favour of the section 121 marginal ladder in six situations, including where the interest is business income, where you claimed an interest or linkage-expense deduction on the asset, and where you are an employee of or a service provider to the payer 4.
One habit to unlearn. TreasuryDirect answers the tax question for a Treasury bill on the product page itself, in two lines, "Federal tax due on interest earned" and "No state or local taxes" 5, so an American arrives expecting the issuer to tell him the answer. The Bank of Israel's makam page does print one figure, 15% 3, but every other rate in the table above comes out of the Ordinance rather than off an issuer page 4. The place you look the answer up moves. Which of these rates are ceilings and which are flat charges, and the crossover point where a real-basis 25% and a nominal-basis 15% produce the same bill, belong to how Israel taxes an investment account; what happens when nothing was deducted at source belongs to self-reporting Israeli CGT through a foreign broker.
Israeli treatment: why does the ten-year exemption not reach any of this?
Because the interest is Israeli-source by definition, and the exemption is scoped to income produced abroad or originating in assets abroad. Section 4A(a)(5) of the Ordinance provides that for interest, discount fees and linkage differentials, the place the income is produced is the payer's place of residence 4. The payer here sits in Israel. Section 14(a) then confines the first-time-resident and veteran-returning-resident ten-year exemption to income from the listed sources "produced or accrued outside Israel, or originating in assets outside Israel", and section 97(b)(1) grants the parallel capital-gains exemption only for an asset the individual had outside Israel, sold within ten years of becoming an Israeli resident 4. Note that those are two different tests: the interest and the discount are settled by the source rule, while a gain is settled by where the asset is, and a security registered for trading on the exchange in Israel and held in an Israeli securities account is not an asset outside Israel.
This is one of the more expensive assumptions a new oleh can make about this asset class. The ten-year window covers your foreign portfolio. It does not cover the paper issued by the country you just moved to. The exemption itself, including the one-year adjustment year under section 14(b), which is taken by giving notice of the choice within 90 days of the day of arrival in Israel, on a form the Director prescribed 4, is set out at the ten-year exemption guide, and the separate reporting change is tracked at tax reform 2026.
Israeli treatment: which Israeli state paper stays taxable in a foreign resident's hands?
The class section 97(b2) names and then takes back out. The subsection exempts a foreign resident from Israeli tax on capital gains from securities traded on the exchange in Israel, provided the gain is not in a permanent establishment of his in Israel. It then disapplies itself to a REIT share, and to gain on a bond or loan of the State of Israel or guaranteed by it, listed for trading on the exchange in Israel, whose redemption date is not more than 13 full months from the day it was issued, which the subsection labels a short-term state loan, and to any futures contract whose underlying is directly or indirectly such a loan 4.
The names line up almost exactly. The Bank of Israel gives makam's full name as מילווה קצר מועד, a short-term loan, and its redemption date as up to one year 3; the Ordinance's defined class is מילווה מדינה קצר מועד, the same phrase with "state" inserted, measured over a slightly wider window of 13 full months from issue 4. The overlap is close enough that the carve-out is plainly drawn around the shortest state paper on the market, and far enough apart that you should apply the subsection's own three-part test to a particular series rather than to a family name: a State of Israel issuer or a State guarantee, listed for trading on the exchange in Israel, and a redemption date within 13 full months of issue. Nothing on this page establishes how any given series answers that test.
Held up against the residence timeline, the class produces a result that runs backwards from every intuition. Before aliyah, a foreign resident buying Shahar, Galil or New Gilon on the exchange in Tel Aviv sat inside the exemption while short-dated state paper sat outside it. After aliyah the exemption goes with the status that carried it, and all of it becomes taxable. Two things worth pinning: the carve-out is drafted for capital gains, so do not read it across to interest, and the whole subsection is about foreign residents, so once you are an Israeli resident it is history rather than planning. The general-terms version of section 97(b2) is at how Israel taxes an investment account; what is new here is that the carved-out class has an instrument-shaped name.
Home-country treatment: what does your own system do once you have gone?
It stops, but not all at the same moment and not by the same mechanism, and in two cases it charges you on the way out.
### United States
The US does not stop, because it taxes citizens. What changes instead is characterisation. IRS Publication 550, under "Discount on Short-Term Obligations", says that when you buy a short-term obligation, one with a fixed maturity date of one year or less from the date of issue, other than a tax-exempt obligation, you generally can choose to include any discount and interest payable on it in income currently. If you do not make that choice, you must treat any gain when you sell, exchange or redeem the obligation as ordinary income, up to the amount of the ratable share of the discount, and your deduction for interest is limited if you borrowed money to buy or carry it. Publication 550 identifies that current-inclusion choice on the return as being made under section 1282(b)(2) of the Internal Revenue Code, and says it applies to all short-term obligations you acquire during the year and in all later years, and cannot be changed without the consent of the IRS 13.
So the two systems land on the same broad answer for the makam discount and disagree on the rate. Israel reaches 15% on either characterisation, flat under section 125C(c)(1) if the return is read as a discount fee, and as a ceiling under section 91(b)(3)(a) if it is read as a gain on unlinked debt 4, and 15% is also the figure the Bank of Israel prints on its own makam page 3. The United States charges your ordinary rate, and the gap between the two is closed by a credit rather than by a treaty rate. They can also disagree on the year: Israel's charge lands at redemption or sale, while a US person who has made the section 1282(b)(2) choice takes the discount into income as it accrues, so a series that straddles 31 December can put the income in one US year and the Israeli tax in the next. Separately, the American instinct that government bonds can be tax-free does not come from Treasuries, whose tax line reads "Federal tax due on interest earned" 5; it comes from municipal bonds, and that is dealt with in full at US muni bonds after aliyah.
Because the US return is computed in dollars while the Israeli one is computed in shekels, the same holding is measured twice against two different yardsticks. The IRS states that you must express the amounts you report on a US tax return in US dollars, that the US dollar is the functional currency for all taxpayers except some qualified business units, and that you use the exchange rate prevailing when you receive, pay or accrue the item 15. What that does to a shekel-denominated gain is argued out at shekel-measured gains on foreign assets.
### United Kingdom
The UK stops on residence, and it takes an exemption with it. GOV.UK lists "UK government gilts and Premium Bonds" among the assets on which no Capital Gains Tax is due, alongside ISAs or PEPs and betting, lottery or pools winnings, as that page read on 25 August 2026 6. The structural map into the Israeli market is clean at first glance: the UK Debt Management Office describes a gilt as a UK Government liability denominated in sterling, issued by HM Treasury and listed on the London Stock Exchange, and describes the market as comprising two types, conventional gilts, which pay a fixed coupon every six months to maturity, and index-linked gilts 7. A conventional gilt maps to a Shahar. An index-linked gilt maps only loosely to a Galil, because the DMO adjusts index-linked gilts in line with the UK Retail Prices Index 7 while TASE's linkage class for Galil is CPI-Linked 1, so the same idea is measured against a different index in each country. And the DMO's two-type description of the gilt market has no floating-rate type in it at all, which is the New Gilon leg.
The benefit does not travel, and the Israeli statute shows why with unusual precision. Israel does carry a state-debt capital-gains exemption: section 97(a)(2) exempts gain on the sale of a certificate or loan certificate issued by the State or guaranteed by it, but only where the certificate was issued or put out before 8 May 2000 4. Anything issued after that date is outside it, and a gain on a Shahar instead runs through section 91(b)(3)(a), at a rate not exceeding 15% as of 25 August 2026, with the entire nominal gain deemed real, so there is no inflation shelter underneath it either 4.
The second half of the UK collision is about safety rather than tax, and both halves of it come from a state source. NS&I says it is backed by HM Treasury, that its origins trace back more than 160 years to 1861, and that it offers 100% security on all deposits 8. That is the mental model a UK oleh brings for a government-secured cash home. The Bank of Israel, in a paper published on 16 June 2015, states that "In Israel, there is no deposit insurance mechanism, but there is an implicit government guarantee" 9. Those two sentences are the reason a UK oleh ends up reading about makam at all, and the Bank of Israel's own description of makam as considered a risk-free channel with a return known in advance 3 is the sentence that pulls them there. The parking-cash decision itself, deposit versus fund versus bill, is argued at short-term savings for olim.
On when the UK actually lets go: GOV.UK states that non-residents only pay tax on their UK income and do not pay UK tax on their foreign income, and that you are UK resident only if you meet one or more of the automatic UK tests or the sufficient ties test and do not meet any of the automatic overseas tests. The three automatic UK tests, as the page read on 25 August 2026, are 183 or more days in the UK in the tax year; your only home being in the UK for 91 days or more in a row with at least 30 days' stay in the tax year; and full-time UK work over any 365-day period with at least one day of it in the year being checked. The same page adds that the year of a move is usually split into a non-resident part and a resident part 10. Treaty mechanics are at the UK tax treaty, and Premium Bonds specifically at UK Premium Bonds after aliyah.
### Canada
Canada charges you on the way out. The CRA states that when you leave Canada you are considered to have sold certain types of property, even if you have not sold them, at fair market value and to have immediately reacquired them for the same amount, which is a deemed disposition and may mean reporting a capital gain, known as departure tax; and that after you leave, as a non-resident, you pay Canadian income tax only on your Canadian source income, as that page read on 25 August 2026 11. The mechanics, including the property listing form and its threshold, are at Canada's departure tax and deemed disposition and the Canada tax treaty. For this page the point is narrower: the departure charge settles the Canadian side before you buy anything here, so nothing you do in the Israeli government-debt market is measured against a Canadian holding period, and the Israeli door is a securities account.
### South Africa
South Africa also charges on the way out. SARS states that a deemed disposal for capital gains tax purposes takes place at the time an individual breaks tax residence, that the individual is deemed to have disposed of worldwide assets excluding immovable property situated in South Africa, and that once a person has ceased to be a tax resident they are taxed only on South African sourced income. A physical-presence resident ceases to be a resident when physically outside the Republic for a continuous period of at least 330 full days, while for an ordinarily resident taxpayer it is a factual enquiry into intention supported by objective factors, both as that page read on 25 August 2026 12. Treaty mechanics are at the South Africa-Israel tax treaty.
United States domestic law: does the PFIC regime reach a directly held Israeli government security?
This section is US domestic law, not Israeli law and not treaty law, and it matters only if you hold a US passport or a Green Card. The short answer is that the regime tests a corporation, and a bond is not one. The Instructions for Form 8621 say a foreign corporation is a PFIC if it meets either the income test, where 75% or more of the corporation's gross income for its tax year is passive income, or the asset test, where at least 50% of the average percentage of assets held during the tax year are assets that produce passive income or are held for the production of passive income 14.
Run a makam or a Shahar bought directly through that definition and there is no corporation to test, because sovereign debt is not stock in one. What has to be run through the gate instead is any pooled Israeli vehicle holding the identical paper, whether a money-market fund (keren kaspit, קרן כספית), a government-bond mutual fund or an Israeli-domiciled ETF, because a vehicle whose assets are bonds produces passive income by construction. That inverts the ordering an Israeli investor takes for granted, in which the pooled fund is the obvious wrapper for short-dated government paper: on the Israeli side the fund is the convenient default, and on the US side the fund is the thing that needs clearing while the bare bill does not. Whether a particular Israeli vehicle is a foreign corporation for this purpose, and what follows if it is, belongs to the PFIC problem and cleaning up a PFIC you already own. The same instrument-level answer for non-tradable State of Israel paper bought in the Diaspora before aliyah, and the reporting question that turns on the account rather than the bond, are at Israel Bonds tax treatment; this page does not answer the reporting question and no source cited here covers the FBAR or Form 8938.
Treaty treatment: what does the US-Israel Convention do to a makam discount?
It confirms Israel's taxing right, preserves the United States' own, and leaves a US citizen a credit. Read for interest rather than for capital gains, the Convention's own table of articles points at four. Article 4, Source of Income, provides at paragraph 2 that interest shall be treated as income from sources within a Contracting State only if paid by that State, a political sub-division or a local authority of it, or by a resident of that State 16. Israeli government paper is therefore Israeli-source under the treaty exactly as it is under Ordinance section 4A(a)(5) 4, and the two systems point the same way. Article 13, Interest, closes the loop on characterisation at paragraph 7, defining "interest" as income from money lent and other income which, under the taxation law of the State in which the income has its source, is assimilated to income from money lent 16. Israel's section 125C(a) assimilates דמי ניכיון to interest 4, so the makam discount is treaty interest, and the chain from Ordinance to Convention holds.
Article 13(1) then says that interest derived by a resident of one State from sources within the other may be taxed by both Contracting States 16. Article 13(2) caps the source State's rate at 17.5% of the gross amount, or 10% for interest derived from a loan of whatever kind granted by a bank, savings institution or insurance company or the like 16, and this is the trap readers fall into: that cap is close to irrelevant to you, because it governs the State of source taxing a resident of the other State, and once you are an Israeli resident Israel is taxing Israeli-source income in the hands of its own resident.
Keep reading Article 13 to the end, because paragraph 3 is the provision a reader will find on their own and then wonder why this page ignored it. It provides that interest beneficially derived by a Contracting State, or by an instrumentality of it not subject to that State's tax on its income, or by a resident of that State with respect to debt obligations guaranteed or insured by that State or an instrumentality of it, shall be exempt from tax by the other Contracting State 16. Two things stop that from being the answer for a US-citizen oleh. Article 6(3), which the Convention's own table of articles identifies as the saving clause, provides that notwithstanding any provisions of the Convention except paragraph 4, a Contracting State may tax its residents and its citizens as if the Convention had not come into effect, and paragraph 4(a) preserves the benefits of Articles 10, 21, 26, 27 and 28, a list that does not include Article 13 16. And the paragraph turns on a State guarantee or State insurance, which is a fact about a particular instrument and is not established anywhere on this page. So the United States keeps taxing its citizen oleh on the makam discount, and the treaty does not stop it. The position of a US person who is not a citizen is a different question and this page does not answer it.
That leaves Article 26(1), which is the relief. In accordance with the provisions and subject to the limitations of United States law, the United States allows a citizen or resident of the United States a credit against United States tax for the appropriate amount of taxes paid or accrued to Israel, and directs that for the purpose of applying that credit the Article 4 source rules determine the source of income 16. Because Article 4(2) puts this income in the Israeli basket, the Israeli charge is creditable foreign tax against the US tax on the same interest. Note the mechanism: it is a credit against tax, subject to US-law limitations, so it reduces a US bill rather than removing the income. Broader treaty context is at the US tax treaty and tax treaties generally.
Keep this section in proportion if you are not American. UK, Canadian and South African olim generally end their home country's taxing rights through their own residence and non-residence rules rather than through a treaty tie-break 101112, so the double-tax problem this section solves is mostly a US-passport problem. Do not apply the warnings above to yourself if the passport is not American.
Worked example: what does one makam holding actually cost in tax?
ILS 600 to Israel on an illustrative ILS 4,000 discount, and then whatever your passport adds on top. The numbers below are chosen to make the arithmetic legible. They are not a quoted price, the ratio between them is not a quoted yield, and no yield is printed here at all, because a makam's yield moves with market expectations for the Bank of Israel rate 3.
An oleh opens a securities account, bids into an issuance auction and takes a makam series with a face value of ILS 100,000 at a cost of ILS 96,000. She holds it to redemption and receives the face value.
- The discount. ILS 100,000 minus ILS 96,000 is ILS 4,000. That is the whole return; there is no coupon.
- Israel. Section 125C(a) makes the discount interest, and nothing between purchase and redemption is index-linked, so section 125C(c)(1) charges a flat 15% as of 25 August 2026 4, the same 15% the Bank of Israel prints on its own makam page 3. 15% of ILS 4,000 is ILS 600. Net ILS 3,400. Nothing is index-adjusted, because there is nothing to index. Section 164 puts a deduction duty on whoever pays, in the manner and at the rates prescribed, and extends it expressly to the State 4, so where that duty bites the figure reaching the account is already net.
- If she holds a US passport. The same ILS 4,000 is ordinary income under Publication 550's short-term-obligation rules rather than a capital gain 13. Suppose her US ordinary rate produced a US charge of ILS 880 on that ILS 4,000; that figure is illustrative and is not a published bracket, and the real computation happens in dollars, not shekels 15. Article 26(1) makes the Israeli ILS 600 creditable against it 16, leaving ILS 880 minus ILS 600, so ILS 280 payable to the IRS. Had the US charge come out at or below ILS 600, the credit, being a credit against US tax and subject to the limitations of US law 16, would have absorbed it and produced no payment either way.
- If she made the section 1282(b)(2) choice. The US income accrues year by year rather than landing at redemption 13, so a series maturing after 31 December splits the US recognition from the Israeli charge, and the credit has to be lined up with the year the income was recognised.
Total on that hold-to-redemption ILS 4,000: ILS 600 to Israel, and either nothing more or the residual difference to the IRS depending on the passport.
Selling early changes the base and the provision, not the headline number. Say she sells at ILS 98,000 partway through instead. The gain is ILS 98,000 minus ILS 96,000, so ILS 2,000, and it is a gain on unlinked debt, which section 91(b)(3)(a) charges at a rate not exceeding 15% as of 25 August 2026 while deeming the whole ILS 2,000 real 4. At that ceiling the charge is ILS 300 on the smaller gain, not ILS 600 on the full discount.
Next step: before you place a first buy order, read how Israel taxes an investment account, so the deduction line on your first statement is arithmetic you already recognise rather than a surprise.
Frequently asked questions
Israel lists government debt in four exchange families, Shahar, Galil, New Gilon and Government Global Bond, and files makam, the Bank of Israel's discount bill, under a separate T-Bill class. The Bank of Israel's published route is a securities account, and the ten-year oleh exemption, scoped to foreign income and foreign assets, does not reach this paper.
Not in the Israeli classification. The Tel Aviv Stock Exchange files makam under a main security class of its own, labelled T-Bills on the English screen, separate from the Government Bonds class where Shahar, Galil, New Gilon and Government Global Bond sit [[1]][[2]]. The Bank of Israel describes makam as a security it issues with a redemption date of up to one year, issued at a discount below face value and paying face value at the end, and used as a tool for managing monetary policy; its full name on that page is מילווה קצר מועד, short-term loan [[3]]. Watch the abbreviation: the Bank of Israel writes מק"ם and the exchange writes מק"מ.
The Bank of Israel's published instructions name no direct-from-the-issuer retail door. They tell you to open a securities account at a bank or investment house, deposit the required amount and place a buy order, then either bid into the monthly issuance auction, which the Bank calls the primary market, or buy and sell on the exchange on any trading day [[3]]. That is the whole published route. Compare TreasuryDirect, where the Treasury sells bills for terms of four weeks to 52 weeks at a $100 minimum in $100 increments and says that Cash Management Bills, unlike the rest, "are only available through a bank, broker, or dealer", as that page read on 25 August 2026 [[5]].
No, and it is one of the more expensive wrong assumptions on the subject. Section 4A(a)(5) of the Income Tax Ordinance sources interest, discount fees and linkage differentials to the payer's place of residence, and the payer here sits in Israel, so the income is Israeli-source [[4]]. Section 14(a) confines the ten-year exemption to income produced or accrued outside Israel or originating in assets outside Israel, and section 97(b)(1) grants the capital-gains version only for an asset the individual had outside Israel [[4]]. Those are two different tests, and a security registered for trading on the exchange in Israel and held in an Israeli securities account fails both.
The exemption you relied on was section 97(b2), which exempts a foreign resident from Israeli tax on capital gains from securities traded on the exchange in Israel where the gain is not in a permanent establishment of his in Israel [[4]]. It attaches to residence status, not to the bond, so it stops applying once you are an Israeli resident. Note which way it ran before: the same subsection already disapplies itself to state paper listed in Israel and redeemable within 13 full months of issue, measured from the day of issue and not from today, so a foreign resident was exempt on the longer bonds and taxable on paper that was short when issued. After aliyah all of it is taxable.
No, and Israel's own state-debt exemption is closed to anything you could buy today. GOV.UK lists UK government gilts and Premium Bonds among the assets on which no Capital Gains Tax is due [[6]], and a conventional gilt, which the UK Debt Management Office describes as paying a fixed coupon every six months to maturity [[7]], maps structurally to a Shahar. Israel does have a state-debt exemption, at section 97(a)(2) of the Ordinance, but only for a certificate issued or put out before 8 May 2000; a gain on anything issued after that runs through section 91(b)(3)(a) instead, at a rate not exceeding 15% as of 25 August 2026, with the whole nominal gain deemed real [[4]].
The regime has nothing to test. The Instructions for Form 8621 define a PFIC as a foreign corporation meeting an income test, 75% or more of gross income for the tax year passive, or an asset test, at least 50% of the average percentage of assets producing passive income or held for the production of passive income [[14]]. A makam or a Shahar bought directly is sovereign debt, not stock in a foreign corporation. What does have to be run through that gate is an Israeli pooled vehicle holding the same paper, whether a money-market fund, a government-bond mutual fund or an Israeli-domiciled ETF, because its assets produce passive income by construction. Whether a given vehicle is a foreign corporation for this purpose is a separate question and this page does not answer it.
No. Article 4(2) treats interest as sourced in a Contracting State if paid by that State, a political sub-division or a local authority of it, or by a resident of it, and Article 13(7) defines treaty interest to include income that the source State's law assimilates to income from money lent, which is exactly what Ordinance section 125C(a) does to a discount fee [[16]][[4]]. Article 13(1) then lets both States tax it. Article 13(3) does carry an exemption for interest derived by a resident of a State on debt obligations guaranteed or insured by that State, but Article 6(3), which the Convention's own table of articles identifies as the saving clause, lets the United States tax its citizens as if the Convention had not come into effect, and the paragraph 4(a) carve-out list does not include Article 13 [[16]]. The relief is Article 26(1), a credit against US tax for Israeli tax paid or accrued, subject to the limitations of US law, which reduces a US bill rather than removing the income [[16]].
Galil is the CPI-linked family, and yes, it changes the tax on both sides of the ledger. TASE names Shahar series ממשל שקלית, shekel, and New Gilon series ממשל משתנה, variable, prefixed ILFRNO for floating rate note on the English screen [[1]][[2]], so section 125C(c)(1) charges a flat 15% on the coupon and section 91(b)(3)(a) charges a rate not exceeding 15% on a gain, with the entire nominal gain deemed real, both as of 25 August 2026 [[4]]. Galil is index-linked, so the coupon falls under the section 125C(b) ceiling of 25% and a gain falls under section 91(b)(1), also a 25% ceiling, measured on the real gain [[4]]. Read the wording: 125C(c)(1) is a flat charge while the others are ceilings.






