Clients often wonder why I need to submit a US legal opinion to the Israeli 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 US legal opinion must be submitted, by an Israeli/US licensed lawyer.
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. This legal opinion must include relevant statutes and the most recent Illinois precedents.
In addition, the legal opinion must be in Hebrew, and refer to Israeli inheritance law, which is why it is prepared by an Israeli lawyer, also licensed in the US (in any state).