Worldwide Disclosure Regime

The Worldwide Disclosure Regime describes the Israel Tax Authority disclosure architecture, effective January 1, 2026, requiring new olim and returning residents to report worldwide income and foreign assets to the ITA. The regime operates as layer three of the broader 2026 aliyah tax reform package.

The disclosure regime requires reporting of:

— Worldwide income across all jurisdictions and sources — Foreign financial accounts (bank, brokerage, custody, and trust-held positions) — Foreign real estate holdings — Foreign trusts where the new oleh is settlor, beneficiary, or controller — Foreign company ownership interests above specified thresholds

The regime is reporting-only: the underlying 10-year foreign-source income tax exemption preserves the favorable tax position. The disclosure removes the reporting privacy that prior aliyah cohorts enjoyed.

The structural implication is material for UHNW principals operating offshore positions with sensitive privacy considerations. Prior cohorts (those arriving before January 1, 2026) could maintain offshore structures with minimal Israeli reporting interface. Post-January 1, 2026, the same structures still benefit from the 10-year tax exemption — but they appear in Israeli reporting.

The regime has substantially expanded pre-aliyah cross-jurisdictional restructuring activity through 2024-2026 across the major Israeli law firms (Herzog Fox & Neeman, Meitar, Yigal Arnon-Tadmor Levy, Goldfarb Gross Seligman, and equivalent firms) covered across The Olam's Family Office Migration cluster.

The Israel Tax Authority coordinates the worldwide disclosure regime with the broader international tax-information-exchange architecture (CRS, FATCA, and bilateral tax treaty information-exchange provisions).

See also: /capital/worldwide-disclosure-regime-2026/, /glossary/aliyah-tax-reform-2026/, /glossary/fatca/