Legal Opinion on US Law for Israeli Inheritance

Clients often wonder why I need to submit a legal opinion on “foreign law” to the Israeli family court, during an Israeli probate process. This is simple: if a decedent passes away OUTSIDE of Israel, but leaves Israeli assets, Israeli law requires that a legal opinion on the law of the country, where the person lived and passed away, be submitted, by an appropriate legal expert, well versed in Israeli inheritance law and the law of the US/UK/France etc (wherever the person passed away).

The easiest way to understand this is by looking at an example: if a Chicago resident passes away, and owned an apartment in Jerusalem, a legal opinion is necessary stating that Illinois law refers to Israeli law, and that Israeli law will apply to the probate and transfer of Israeli real estate, owned by a Chicago resident.

These legal opinions are in Hebrew and generally written by an Israeli lawyer, who is also licensed in another country.