For people relocating from Israel to the United States

Moving to the US From Israel: Your First US Tax Year

Relocating from Israel? The US decides tax residence by its own tests, your first year is usually split in two, and the US-Israel treaty settles dual residence. Here is how each piece works.

Substantial presenceGreen card testDual-status yearTie-breakerSocial security

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Quick answer

When does someone moving from Israel start paying US tax on worldwide income?

From the residency starting date: the first day in the US in a year you meet the substantial presence test, or the first day as a permanent resident under the green card test (IRS Pub 519). Before that you are a nonresident, so the first year is usually dual-status. If you are also resident in Israel, Article 3 (Fiscal Residence) of the treaty decides which country you are resident in for treaty purposes.

Prepared by Illuminous Accounting · Sources checked November 11, 2026

At a glance

When you become US resident: Green card test or substantial presence test (Code section 7701(b))
First year: Usually dual-status: nonresident, then resident
Treaty tie-breaker: Article 3 (Fiscal Residence)
Social security agreement: None on the SSA list
Accounts in Israel: FBAR, Form 8938 and PFIC rules can apply once resident

The residency starting date

Expect your first year to have two halves. Income from Israel before you became resident is generally outside US tax unless it is US-source; income after the residency starting date is taxed worldwide (IRS Pub 519). The starting date is your first day in the US in that year under the substantial presence test, or your first day as a permanent resident under the green card test. People who arrive near year end may be able to opt in early under the first-year choice. Getting the date right decides which Israeli salary, bonuses and investment income the IRS sees.

When someone from Israel becomes a US tax resident

The US decides tax residence with two tests in Code section 7701(b), not by your visa label (IRS Pub 519). Arriving from Israel, you become a US resident for tax purposes in a year if either applies:

Green card test: you are a lawful permanent resident at any time in the year.
Substantial presence test: at least 31 days in the US this year, and 183 days over three years counting all days this year, one third of last year's and one sixth of the year before.

Count your days with our substantial presence calculator.

Resident in both countries: the US-Israel treaty tie-breaker

During the move you can be resident in both Israel and the US under each country's law. Article 3 (Fiscal Residence) of the treaty has the tie-breaker for someone resident in both countries: it looks first at where you have a permanent home available, then at the further tests the article lists, in the order it sets them. If the treaty makes you a resident of Israel, you can be taxed as a nonresident of the US for the treaty's purposes, but that position must be disclosed on Form 8833 under Treas. Reg. section 301.7701(b)-7 (IRS Form 8833).

Green card holders should be careful: a long-term resident who claims treaty residence abroad this way may be treated as having expatriated under section 877A (IRS).

Your accounts back home

Once you are a US resident, bank, pension and investment accounts you keep in Israel can bring the FBAR and Form 8938, and funds held there are often treated as PFICs (Form 8621, IRS). See FBAR and FATCA and Form 8938 for who files and the thresholds.

Sources for moving from Israel

Treaty

The IRS lists the 1975 income tax treaty. General effective date (IRS Table 3): treaty Jan. 1, 1995 (IRS treaty documents for Israel; treaty text; IRS Table 3).
Residence and tie-breaker: Article 3 (Fiscal Residence).
Saving clause: Article 6 (General Rules of Taxation).
Article 20 (Private Pensions and Annuities) and Article 21 (Social Security Payments), pensions.
Article 26 (Relief from Double Taxation), relief from double taxation.
Article 17 (Dependent Personal Services), employment income.

US law

US residency tests and starting dates: Code section 7701(b) (IRS Pub 519).
Treaty residence for dual residents: Treas. Reg. section 301.7701(b)-7, Form 8833 and section 6114; long-term residents: section 877A (IRS Form 8833).
Social security agreements: SSA list.

The rules of Israel on leaving the country also apply; check them with a local adviser.

How we help

Send us your arrival date, visa or green card dates and a summary of income and accounts in Israel. We confirm your US status for the year, prepare the dual-status or resident return with the reporting it needs, and Gurleen Kaur, CPA licensed in British Columbia and Washington State, signs. Quote before any work.

Common questions

When do I become a US tax resident after moving from Israel?

When you meet the green card test or the substantial presence test (31 days this year and 183 weighted days over three years). Your residency starting date is generally your first day in the US that year, or your first day as a permanent resident.

What if I am resident in both Israel and the US?

Article 3 (Fiscal Residence) of the treaty breaks the tie, starting with where you have a permanent home. Claiming treaty residence in Israel on a US return needs Form 8833.

Do I report my accounts in Israel after moving to the US?

Once you are a US resident, yes: the FBAR when foreign accounts total more than US$10,000, Form 8938 above higher thresholds, and PFIC rules for many foreign funds.

Is there a US social security agreement with Israel?

No, Israel is not on the SSA list of agreement countries.

Sources

Every rule and figure on this page links to the IRS, CRA or other official source it comes from. Amounts change; we re-check them before each engagement.

Gurleen Kaur, CPA licensed in British Columbia and Washington State. Last updated November 11, 2026. This page is general information, not tax or legal advice for your situation.

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