Could another option be contributing the property in exchange for a larger LLC interest? So instead of maintaining the 75/25 split, the mother receives additional LLC interest proportional to the property value, increasing her percentage ownership. Later on she could gift LLC interests gradually to her child using the annual gift tax exclusion ($16k/year for non-resident aliens).

As a non-resident alien myself who went through a similar property transfer, I'd strongly recommend getting a professional appraisal of the Florida property before proceeding with any option. The IRS will scrutinize the valuation heavily, especially for non-resident alien transactions. One approach that worked for my family was structuring it as a contribution to capital where your mother receives additional LLC interests proportional to the property value, then gradually gifts LLC interests back to you over several years using the annual exclusion. This spreads out any potential tax impact and gives you more control over timing. Also keep in mind that Florida has no state gift tax, but you'll still need to comply with federal requirements. Make sure to file Form 3520-A if the LLC is treated as a foreign trust for tax purposes, which can happen with certain ownership structures involving non-resident aliens. Document everything meticulously - the IRS pays extra attention to related-party transactions involving real estate and non-resident aliens. Consider having the LLC formally adopt a resolution authorizing the capital contribution and get independent valuations to support the transaction.

Based on your situation as a married person with one working spouse at 30 hours/week, $20 total additional withholding is likely more than you need. I'd suggest starting with just $5 federal and maybe $3 state to be safe. The key thing for your W-4: since your spouse doesn't work, you should NOT check the box in Step 2(c) - that's only for when both spouses work. This actually helps your withholding accuracy. Here's what I'd recommend: Start conservative with small additional amounts, then check your first few paystubs to see how the withholding looks. You can always submit a new W-4 to increase it if needed. It's much easier to adjust upward than to try to get back money you've overwithhelded. Also keep in mind that at 30 hours/week in fast food, your annual income will likely be on the lower side where standard withholding tables are pretty accurate already. The additional withholding might just result in a bigger refund than necessary - essentially an interest-free loan to the government.

I work in tax preparation and see this situation all the time with new workers! For someone in your position - married with one working spouse at 30 hours/week - $20 additional withholding is definitely overkill. Here's what I typically recommend: Start with $3-5 additional federal withholding and maybe $2-3 for state. That should give you a small cushion without tying up too much of your money throughout the year. Since you're new to this, a few key points: - Don't check Step 2(c) on your W-4 since your spouse doesn't work - The standard withholding tables are actually pretty accurate for lower income situations like yours - You can always file a new W-4 with HR if you need to adjust after seeing a few paychecks Remember, a huge refund isn't necessarily a good thing - it means you gave the government an interest-free loan all year. Better to keep that money in your pocket and maybe put it in a savings account where it can at least earn a little interest. Start conservative and adjust as needed. You've got this!

I've been following this thread closely as someone in a very similar situation - US-Hungarian dual citizen, born in US, never lived in Hungary, all income US-sourced. The consensus here seems reassuring that the treaty termination shouldn't create new filing obligations for us. One thing I wanted to add based on my research: Hungary's tax law actually has specific provisions for "non-resident Hungarian citizens" that generally exempt them from Hungarian tax obligations unless they have Hungarian income or spend significant time there. This is codified in their domestic tax law, not just the treaty, so it should remain in effect after termination. I also contacted a Hungarian tax advisor who confirmed that Hungary doesn't have the same "citizenship-based taxation" approach as the US. They're primarily interested in people who are actually conducting economic activity in Hungary or using Hungarian resources/infrastructure. That said, I'm definitely going to follow the advice here about getting written confirmation from the Hungarian consulate, just to have official documentation. Better to be overly cautious with international tax matters! Has anyone found any official IRS guidance specifically about the US-Hungary treaty termination and its impact on dual citizens? I've seen general guidance about treaty terminations but nothing Hungary-specific yet.

I've been researching this exact issue and found some helpful information about the transition timeline. The US-Hungary tax treaty termination takes effect January 1, 2025, with no phase-out period - it's a clean break. The treaty notification was given in 2024, providing the required one-year notice period. What's interesting is that I found IRS Publication 901 has been updated to reflect upcoming treaty terminations, though it doesn't get into specific scenarios like dual citizens with no Hungarian income. The publication does confirm that when treaties terminate, you fall back on each country's domestic tax laws. For those looking for official US guidance, I'd recommend checking Form 8833 instructions, which deals with treaty-based return positions. While it's mainly for claiming treaty benefits, it might provide insight into reporting requirements when treaties no longer exist. I'm also planning to contact both the Hungarian consulate and IRS as others have suggested. Given how many dual citizens this affects, it would be great if someone could compile the official responses we get and share them back with this community.

I worked in corporate tax planning for 15+ years and here's the reality: whenever one structure gets shut down, teams of high-paid lawyers and accountants immediately develop alternatives. The Double Irish may be technically ending, but "single malt" structures (Ireland-Malta) emerged as replacements. The OECD agreement is a step forward, but it has significant carve-outs. Companies can still exclude 5% of tangible assets and payroll from the calculation, creating new incentives to shift certain operations. My prediction? Effective tax rates will increase slightly for the biggest multinationals, but they'll still pay far less than the headline 15% minimum through careful planning and exploitation of technical exceptions in the agreement.

As someone who's been tracking these developments closely, I think we're seeing real progress but it's going to be gradual. The Double Irish is genuinely winding down - Ireland has been pretty firm about not allowing new arrangements since 2020, and the grandfathered structures have a hard cutoff in 2025. What gives me hope about the OECD framework is that it's not just about setting a minimum rate - it's about creating a coordinated response. When 140+ countries agree to implement "top-up taxes" if companies pay below 15% anywhere, it fundamentally changes the game. Tax havens lose their advantage because the home country can just collect the difference. That said, I agree with Joy that we'll see new planning strategies emerge. But each time we close a loophole, it gets harder and more expensive for companies to avoid taxes. Eventually, the cost of aggressive tax planning starts to outweigh the benefits. The real test will be enforcement starting in 2026. If major economies like the US, EU, and UK actually implement these rules robustly, I think we'll see meaningful change in corporate effective tax rates for the first time in decades.

If you're filing as a resident alien after passing the substantial presence test, don't forget about FBAR requirements! If you had foreign bank accounts with a combined total of over $10,000 at any point during the year, you need to file an FBAR (FinCEN Form 114). This is separate from your tax return and has really steep penalties if you miss it.

This is such a common situation that catches so many former international students off guard! I went through the exact same thing a couple years ago. One thing I'd add that hasn't been mentioned yet - make sure you understand the "closer connection" exception. Even if you pass the substantial presence test, you might still be able to file as a nonresident if you can demonstrate that you have a closer connection to your home country than to the US. Since you moved back to your home country in August 2024, you might qualify for this exception for the portion of the year you were back home. You'd file Form 8840 (Closer Connection Exception Statement) to claim this. It considers things like where your permanent home is, where your family lives, where your personal belongings are, etc. Also, regarding software - yes, you can generally use regular tax software like TurboTax now, but be careful because most mainstream software isn't great at handling the dual-status alien situation or treaty benefits. The specialized services mentioned above might be worth considering given your specific circumstances with the scholarship income and the mid-year move back home.