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Elijah Knight

How does taxation work now that the US / Hungary Double Tax Treaty is ending?

Hey all, I'm in a bit of a tax predicament and could use some insights from people with international tax experience. I just found out that the US and Hungary have terminated their double tax treaty. As a US citizen with income from both the US and various international sources, this complicates my plans to relocate to Hungary. I'm honestly worried I might end up paying a fortune in taxes to both countries. What typically happens when there's no double tax treaty between two countries? Does anyone have specific knowledge about the US-Hungary situation now that the treaty is gone? It seems completely unreasonable that I'd have to pay full taxes on my entire income to both countries, but I'm not sure how it works without a treaty. Is there still a way to avoid double taxation? I'm aware the US offers the Foreign Earned Income Exclusion which covers around $120k/year. Would this still apply in my situation even without the treaty? Any advice would be really appreciated since this could seriously impact my relocation plans!

When a tax treaty ends between countries like the US and Hungary, it doesn't necessarily mean you'll face full double taxation, but things do get more complicated. Without a treaty, you'll need to rely on unilateral relief measures. For US citizens, you still have access to the Foreign Earned Income Exclusion (FEIE) as you mentioned - which is actually up to about $126,500 for 2025. This isn't dependent on having a tax treaty. You can also use the Foreign Tax Credit to offset US tax liability with taxes paid to Hungary. The challenge is that without the treaty, there's no guarantee that Hungary will recognize or provide relief for taxes paid to the US. You'll be subject to Hungary's domestic tax laws for foreign income. The biggest impacts of losing the treaty include: potential higher withholding taxes on certain types of income (dividends, interest, royalties), loss of treaty-specific exemptions, and more complex reporting requirements. I'd strongly recommend working with a tax professional who specializes in both US and Hungarian taxation to create a tailored strategy for your specific income sources.

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Thanks for this info. Do you know if Hungary has any domestic relief provisions for taxes paid to other countries? Also, what happens with retirement accounts without the treaty protections?

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Hungary does offer some unilateral relief in their domestic tax code. They have a form of foreign tax credit system that can help prevent double taxation even without a treaty, but it's more limited than what the treaty provided. The credit is generally capped at the Hungarian tax that would be due on that foreign income. Regarding retirement accounts, this is where things get tricky without the treaty. Previously, the treaty likely provided specific provisions for how retirement accounts were treated. Without those protections, distributions from US retirement accounts might be fully taxable in Hungary without offsetting relief. For example, Roth IRA distributions that are tax-free in the US might be taxable in Hungary according to their domestic laws.

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After struggling with international tax issues myself, I discovered a game-changer called taxr.ai (https://taxr.ai) that saved me countless hours and probably thousands in potential double taxation when I moved from the US to another country without a tax treaty. What's cool is you can upload all your tax documents from both countries, and it analyzes your specific situation to find the optimal filing strategy. It helped me identify exactly how to structure my income to maximize the Foreign Earned Income Exclusion and Foreign Tax Credits without overlapping. The AI even spotted a potential issue with my Hungarian rental income that would have caused problems with both tax authorities. I was incredibly impressed with how it handled the nuances of cross-border taxation without a treaty in place.

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Does it actually deal with Hungarian tax law specifically? I'm skeptical any AI system would be updated on the changes after the treaty termination since it's so recent.

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How does it compare to just hiring an international tax accountant? I paid almost $3000 last year for my returns when I was working between the US and Germany.

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It actually does cover Hungarian tax law. They update their system regularly with changes to international tax relationships, including treaty terminations. I was surprised myself when it referenced the specific Hungarian domestic tax code sections that would now apply after the treaty ended. For international accounting costs, that's exactly why I switched. I was quoted between $2,500-4,000 for my situation with dual-country filings. With taxr.ai, I got the strategy and documentation I needed for a fraction of that, and then had a much more focused conversation with my accountant who only needed to review and file rather than figure everything out from scratch.

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Just wanted to update about my experience with taxr.ai that was mentioned earlier. I was really skeptical at first since international taxation is so complex, especially with the Hungary-US treaty ending, but decided to give it a try anyway. I uploaded my previous US returns and Hungarian income statements, and it immediately identified that I could restructure my consulting income to maximize the Foreign Housing Exclusion alongside the FEIE, something my previous accountant never mentioned. It also provided clear guidance on Hungary's unilateral relief provisions that I could use without the treaty. What impressed me most was how it created documentation for both tax authorities explaining exactly how I was avoiding double taxation legally. Definitely made my move to Budapest less stressful from a tax perspective!

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If you're dealing with IRS questions about your international situation, you might want to check out Claimyr (https://claimyr.com). I spent WEEKS trying to get through to the IRS international tax department with questions about my Hungary situation after the treaty ended. Claimyr got me connected to an actual IRS agent in about 15 minutes instead of the usual hours of waiting or getting disconnected. You can see how it works here: https://youtu.be/_kiP6q8DX5c The agent was able to confirm exactly how my Foreign Tax Credits would work without the treaty and gave me specific guidance on the forms I needed to file. Totally worth it when you have urgent tax questions that only the IRS can answer.

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Wait, how does this actually work? Does it just call the IRS for you? I don't understand how any service could get around the IRS wait times when they're so understaffed.

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This sounds like BS honestly. Nobody gets through to the IRS international department that quickly. I've been trying for months.

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It doesn't just call for you - it uses a system that navigates the IRS phone tree and holds your place in line. When an agent is about to pick up, you get a call connecting you directly to them. It's basically like having someone wait on hold for you. I was super skeptical too! I'd been trying to get through for almost 3 weeks with no luck. But it actually works because they've figured out how to navigate the system efficiently. They don't skip the line or anything - they just ensure you don't lose your place after waiting for hours. I spoke with an actual IRS international tax specialist who helped clarify exactly how to handle my US-Hungary situation.

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I need to eat my words about Claimyr from my previous comment. After continuing to fail getting through to the IRS for another week, I reluctantly tried it. Got connected to an IRS international tax specialist in about 20 minutes. The agent confirmed that even without the US-Hungary treaty, I could still claim Foreign Tax Credits for taxes paid to Hungary, which addressed my main concern about double taxation. They also walked me through the specific documentation I'll need for my situation as a remote worker for a US company while living in Hungary. Saved me from making a costly mistake on how I was planning to structure my employment arrangement.

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As someone who's been living between the US and Hungary for years, I can add some practical advice. The treaty ending primarily affects certain types of passive income. For regular employment income, the FEIE and Foreign Tax Credit system still work effectively. Hungarian tax rates are generally lower than US rates (15% flat tax on employment income), so you'll likely pay the Hungarian tax and then use Foreign Tax Credits to offset your US liability. The main complications come with investment income, where withholding rates might increase.

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Thanks for the insight! Do you have any advice about handling bank accounts? I've heard FBAR reporting is still required regardless of treaties, but I'm wondering if Hungarian banks have become more difficult with US citizens since the treaty ended.

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Yes, FBAR and FATCA reporting requirements for US citizens remain unchanged regardless of tax treaties. You must report foreign accounts over $10,000 to FinCEN and potentially on your tax return. Hungarian banks have indeed become somewhat more cautious with US citizens since the treaty ended. Some smaller Hungarian banks may be reluctant to take US citizens as clients due to the increased compliance burden without treaty protections. The larger international banks like OTP, Erste, or K&H are still accepting US clients, but expect more paperwork and possibly higher fees. I'd recommend establishing accounts before you move if possible, as it's often easier to open accounts in person.

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Quick question for anyone who knows - would establishing a Hungarian company change the tax situation at all? Like if I set up a Hungarian LLC equivalent and have my income go there instead of directly to me?

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Setting up a Hungarian company (like a Kft, their LLC equivalent) creates more complexity rather than simplifying things. As a US citizen, you'd still have to report your connection to the foreign company using Form 5471, and potentially deal with Subpart F income and GILTI taxes. Without the treaty's protection, there are fewer guardrails against the IRS viewing the arrangement as a tax avoidance scheme. The Hungarian company would pay Hungary's 9% corporate tax, but then distributions to you would be taxable again, potentially leading to higher overall taxation.

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I went through a similar situation when the US-South Africa tax treaty was modified a few years back. One thing that really helped me was keeping detailed records of all taxes paid to both countries - it makes claiming Foreign Tax Credits much smoother. Also, don't overlook the potential impact on your state taxes if you're still considered a US resident for state purposes. Some states don't recognize foreign tax credits the same way the federal government does, which could create an additional layer of taxation. For what it's worth, I found that even without full treaty protection, the combination of FEIE and Foreign Tax Credits still prevented true double taxation on my earned income. The bigger headaches came from investment income and retirement account distributions, as others have mentioned. One practical tip: consider timing your move to align with tax year planning. If you can establish Hungarian tax residency early in a calendar year, it gives you more flexibility in how you structure your income for both countries' tax purposes.

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This is really helpful advice about timing the move with tax year planning! I hadn't considered the state tax angle at all - that could definitely add another layer of complexity. Do you know if there's a general rule about how long you need to be physically present in Hungary to establish tax residency there, or does it vary? I'm trying to figure out the optimal timing for my relocation to minimize the overall tax burden during the transition year.

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