Your Digital Estate Across Two Countries

You Have an Israeli Will and Nobody Has Your Passwords

A will transfers ownership. It does not grant access. Every foreign platform you still use, the brokerage in New York, the pension portal in London, the cloud drive holding twenty years of documents, decides who gets in under its own terms of service and its own country’s law. Not under the Israeli inheritance order your family will be holding.

That gap is specific to olim. A lifelong Israeli with an Israeli bank, an Israeli תיק השקעות (Tik Hashkaot) and an Israeli pension has one legal system, one language and one court document to produce. You have two or three of each, spread across accounts that were opened before you ever heard the word aliyah, and the only bridge between them is a login.

Why can’t my Israeli will open a foreign account?

Because succession law and platform access are two different questions. Israeli succession law decides who owns the account after you die. The provider’s contract decides who it will let in, and that contract was written under Delaware, English or Irish law by a company with no obligation to read Hebrew.

Practically, your family produces an Israeli court document: an inheritance order where there is no will, or a probate order confirming one, both issued through the Registrar of Inheritance Affairs¹⁰. A compliance officer abroad then decides whether that document satisfies internal policy. It usually needs a certified translation and an apostille, and the answer can still be that they want a domestic grant instead. Each step is measured in months, and the account stays frozen throughout.

What actually unlocks each kind of account?

Different asset types have different keys, and only one row here is solved by a will.

Why is an unrecorded seed phrase different from everything else?

Because there is no issuer to appeal to. A frozen bank account is a delay; a self-custody wallet whose seed phrase died with you is a permanent loss that no court, registrar or exchange can reverse. The distinction is custody, not asset class: coins on an exchange sit with a company that has a bereavement desk and can verify an heir, while coins in a wallet you control are secured by twelve or twenty-four words and nothing else. An Israeli inheritance order is a legal fact about ownership that the network cannot read.

The Israeli side: no tax on the transfer, but the records still matter

Israel has levied no estate or inheritance tax since 1981. The transfer itself costs nothing, and succession runs through the Registrar of Inheritance Affairs¹⁰. Two Israeli consequences still depend on your digital records.

First, Israeli heirs step into the deceased’s original cost basis rather than receiving a stepped-up one, so the capital gains tax due on eventual sale is computed from a purchase price and date that may exist only inside a foreign broker’s statement archive¹¹. Lose the login and your heirs may be unable to prove a basis they are entitled to. Second, olim who became Israeli residents on or after 1 January 2026 must now report foreign income and assets to the רשות המסים (Rashut HaMisim) even while the ten-year benefit keeps that income exempt from Israeli tax¹². Your inventory of foreign accounts is now a live compliance document, not only an estate one.

The home-country side: Israel charging nothing changes nothing abroad

The expensive assumption is that moving to a country with no estate tax takes estate tax off the table. Your home country’s claim usually rests on citizenship or on where the asset sits, and your aliyah changed neither.

The treaty side: what relief exists between Israel and your home country?

On estate tax, essentially none. The IRS publishes the countries it has estate or gift tax treaty provisions with, and the list runs Australia, Austria, Canada, Denmark, Finland, France, Germany, Greece, Ireland, Italy, Japan, Netherlands, South Africa, Switzerland and the United Kingdom³. Israel is absent. The 1975 US-Israel convention is an income tax treaty and does not reach estate tax. HMRC’s inheritance tax double taxation conventions cover Ireland, South Africa, the USA, the Netherlands, Sweden and Switzerland, plus pre-1975 agreements with France, Italy, India and Pakistan⁴. Israel is absent there too.

There is a sting in the tail of Israel’s zero rate. Unilateral relief works by crediting the tax another country charged on assets sited there⁴, so when Israel charges nothing there is nothing to credit. Israel having no estate tax is not a shield against the US or UK claim; it simply means the relief machinery has no Israeli figure to work with. For the mechanics of the US side, see US estate tax exposure for American olim, and for how the wills themselves should be structured, see cross-border wills.

Does PFIC come into this?

This article does not cover how to fix PFIC exposure; that belongs with the investing articles. The estate-side point is narrower. If the deceased held non-US pooled funds, an Israeli kupat gemel or keren hishtalmut, a TASE-listed fund, an Irish-domiciled UCITS, and an heir is a US citizen or green-card holder, that heir now holds a passive foreign investment company interest and picks up Form 8621 reporting on it¹³. Quantifying it requires the fund’s annual statements, which frequently live behind the deceased’s portal login. Access is a precondition for compliance, not an afterthought to it.

The inventory and access checklist

1. Inventory by platform, not by asset class. For each one: institution, country, account type, the identifier you log in with, and which of your currencies it holds. A dormant מטבע חוץ (Matbea Chutz) account is easy to forget and hard to find.
2. Record the second factor, not just the password. Most families are stopped by two-factor authentication tied to a phone number cancelled on aliyah. Note the authenticator device and store the recovery codes.
3. Set the platform-level designation everywhere one exists. Legacy contact, inactive-account manager, online tool. This is the layer no will reaches.
4. Update מוטב (Mutav) (beneficiary) forms separately. Pension, keren hishtalmut and life insurance pay the named beneficiary regardless of the will, and those forms often predate the aliyah.
5. Export purchase records out of the platform. Cost basis and purchase dates drive the Israeli tax bill on eventual sale, so keep them somewhere that survives the account.
6. Handle self-custody keys physically and separately from the document that lists everything else.
7. Note per provider which country’s document it accepts, and keep a certified translation of the Israeli order ready where you know it will be demanded.
8. Point to the master document from the will without embedding secrets in it, and review the whole thing once a year.

An Israeli will decides who owns your assets; it does not decide who can log in. Foreign brokerages, pension portals, email and cloud providers apply their own terms of service and their own country's law, so an Israeli inheritance or probate order usually needs translation, an apostille and a compliance decision before it opens anything, and some providers will insist on a domestic grant instead. A self-custody crypto seed phrase that was never recorded is unrecoverable, because there is no issuer to reissue it. On tax, Israel has charged no estate or inheritance tax since 1981, but that removes nothing abroad: US estate tax follows citizenship on a worldwide estate, non-US-citizens meet a $60,000 US-situs filing threshold, UK inheritance tax has been residence-based since 6 April 2025, and South African estate duty reaches worldwide property of someone ordinarily resident there. Neither the IRS nor HMRC has an estate-tax treaty with Israel, and because Israel charges nothing there is no Israeli tax for either to credit. The practical fix is an inventory built by platform rather than by asset class, covering the second factor as well as the password, plus the in-platform legacy designations that a will cannot reach.