One of the defining characteristics of the Jewish people is their presence all across the globe. This international dispersion frequently manifests in inheritance matters—after all, many of us have that proverbial "uncle in America." But what happens when a foreign resident passes away abroad, leaving assets and property to a beneficiary in Israel? We have dedicated this brief article precisely to this complex issue.

Why Do You Need to Issue an Inheritance Order in Israel for a Foreign Resident?

On the face of it, the mere fact that you are the beneficiary of a deceased foreign resident shouldn't necessarily concern the State of Israel. After all, Israel has no inheritance or estate tax, and the estate itself is generally governed by the succession laws of the country where the deceased resided. While this is true in theory, what happens when a portion of the estate includes property and assets located physically within the State of Israel and shielded under its laws? This is where matters become legally intricate and demand specialized attention. Under Israeli statutory law, the liquidation or transfer of an estate located or deposited in Israel—even if it belongs to a foreign citizen or non-resident—cannot be executed without a formal Inheritance Order or Probate Order issued by the Israeli Inheritance Registrar or a competent religious tribunal. Essentially, this is the standard procedure for any inheritance in Israel. So, where does the challenge lie? The "challenge" (which is a much more accurate term than "problem" in this scenario) is that you must navigate a dual-track legal process. This means you must first secure an inheritance order or a probated will in the country where the deceased was a resident, and only then file the petition for a reinforcing Probate Order in Israel. Furthermore, because the petition in Israel relies on foreign law and foreign sovereign documents, the procedure is substantially more complex. It requires an expert practitioner who is well-versed in both foreign and Israeli law, and who knows how to utilize specialized instruments such as notarized legal translations.

How Do You Obtain an Israeli Inheritance Order for a Foreign Resident's Estate?

As noted, in any case where a portion of a non-resident's estate is located in Israel (whether it is real estate property or capital deposited in an Israeli bank account), the only way to legally claim and liquidate those assets is through an Israeli-issued inheritance decree. Superficially, there is no difference in this regard between an inheritance order for a deceased Israeli citizen and one for a foreign resident. Historically and technically, that is correct; however, in practice, when a foreign resident passes away abroad leaving behind assets in Israel, executing the estate is far more complicated.

It is crucial to remember that before you can even initiate the process in Israel, the inheritance must be legally settled—meaning you must obtain a probate or inheritance decree—in the deceased's country of domicile. In most jurisdictions, succession principles follow a similar logic: If the deceased left a valid will, the provisions of the will govern the distribution. If the deceased passed away intestate (without a will), the estate is distributed according to statutory intestate succession rules (surviving spouse and lineal descendants). Only after the foreign jurisdiction grants the official decree can the Israeli beneficiaries initiate the corresponding application in Israel to claim the domestic component of the estate. 

What Documents Must Be Prepared for the Application?

Once the foreign inheritance order has been granted or the will has been formally probated abroad, the application process in Israel can begin. Although the statutory framework mirrors standard local applications, the fact that the primary source materials are foreign documents necessitates rigorous translation and legal authentication protocols.

While a standard application for an Israeli citizen simply requires submitting a local death certificate, a foreign resident's estate demands much more: Apostille Authentication & Notarial Translation: You must submit the foreign death certificate authenticated via an international Apostille seal, accompanied by a certified notarized translation into Hebrew.

Heir Affidavits & Asset Mapping: Detailed statutory declarations from the heirs and an itemized breakdown of the specific assets located in Israel must be prepared. Foreign Law Expert Opinion: The foreign probate orders and wills must be similarly translated and authenticated. To verify to the Israeli court or Registrar that these documents were indeed validly executed under the governing laws of the foreign jurisdiction, you must obtain a formal Expert Legal Opinion on Foreign Law drafted by a qualified international legal jurist specializing in cross-border successions.

In this article, we have outlined the general procedure and its underlying legal rationale, which centers on verifying and confirming that the inheritance was executed lawfully, even when the core of the proceedings took place in the deceased’s country of residence. While it may sound straightforward on paper, in reality, it demands an intimate understanding of multiple civil and common-law systems, alongside deep familiarity with the bureaucracy and regulations bridging foreign and Israeli civil procedures. Ultimately, this expertise is what allows Israeli beneficiaries to successfully realize their share of the estate. Therefore, in any matter involving the execution of a foreign resident's estate, we highly recommend partnering with a law firm that specializes in representing foreign nationals and cross-border estates. Typically, such firms possess a tailored orientation toward specific destination jurisdictions (for instance, the English-speaking Anglo-Saxon world or the European Union), enabling them to assist heirs in navigating the estate execution in the fastest, simplest, and most financially viable manner possible.