clerk has the power to question them even 20 years later, changing one's citizenship status to "on hold", and putting them in jeopardy of deportation. The two biggest communities affected by these documentation issues are: Immigrants from the former Soviet Union (FSU) – a study conducted between 2003 and 2005 showed that 83% of people from the FSU who started the Judaism test process successfully finished it. An estimated 10% left the process before completion. In a later study, in 2011, a 90% success rate was achieved in the FSU immigrant community. Many Jews in the former Soviet Union took steps to hide their Jewishness. Besides post-Soviet copies of documents are suspected by the tribunal after widespread falsification, and the archived originals are difficult to access for genealogists. Immigrants from the United States, where government documents generally do not show religion or Jewish ethnicity. Law of Return Following the birth of the modern State of Israel in 1948, the Law of Return was enacted in 1950 to give any Jew the right to immigrate to Israel and become a citizen. However, due to an inability on the lawmakers to agree, the Law did not define who was a Jew, relying instead on the issue to resolve itself over time. As a result, the Law relied in form on the traditional halakhic definition. But, the absence of a definition of who is a Jew, for the purpose of the Law, has resulted in the divergent views of the various streams of Judaism competing for recognition. Besides the generally accepted halakhic definition of who is a Jew, in 1970, the Law extended the categories of person who are entitled to immigration and citizenship to the children and grandchildren of Jews, regardless of their present religious affiliation, and their spouses. Also, converts to Judaism whose conversion was performed outside the State of Israel, regardless of who performed it, are entitled to immigration under the Law. Once again, issues arose as to whether a conversion performed outside Israel was valid. The variation of the definition in the Law and the definition used by various branches of Judaism has resulted in practical difficulties for many people. It has been estimated that in the past twenty years about 200,000 non-Jews and even practicing Christians have entered Israel from the former Soviet Union on the basis of being a child or grandchild of a Jew or by