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Kai Rivera

How will the US-Hungary tax treaty termination affect dual citizens living in US?

I'm a US-Hungarian dual citizen (born in US, Hungarian citizenship through my parents) and have lived in the US my entire life. I'm getting worried about the upcoming termination of the double tax treaty between the US and Hungary. Starting next year, will I need to file or pay taxes in Hungary too? My situation is pretty straightforward - I work a regular full-time job here in the US and have some minor capital gains from investments, all US-based. I don't have any income sources, property, or assets in Hungary whatsoever. Most of the information I've found online focuses on Americans living in Hungary or people with Hungarian income sources. Nothing seems to address dual citizens like me who've never actually lived in Hungary but hold a Hungarian passport. Anyone familiar with how the US-Hungary double tax treaty termination will impact someone in my situation? I'm trying to figure out if I need to prepare for additional tax filing requirements next year.

Tax treaties primarily affect people who have income in both countries or who live in one country while having citizenship in another. Since you live in the US and all your income is from US sources, the treaty termination shouldn't significantly impact your tax situation. For Hungarian tax purposes, they generally only tax residents or Hungarian-source income. Since you don't live in Hungary (not a resident) and don't have income from Hungary, you likely won't have Hungarian tax obligations even after the treaty ends. That said, Hungary does have a concept of "tax residency" that could technically apply to citizens regardless of where they live, but in practice, they don't typically pursue taxation of citizens who permanently live abroad with no Hungarian income.

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Thanks for explaining! So even though I'm a Hungarian citizen, because I'm not a tax resident there and have no Hungarian income, I shouldn't have to file anything with them? I was worried that the treaty ending meant all dual citizens would suddenly have to start filing in both countries.

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You're welcome! Correct - citizenship alone doesn't typically trigger tax filing requirements in Hungary. What matters is tax residency (where you actually live) and source of income. The treaty ending mainly affects people with cross-border income situations or those living in one country while earning from the other. Since your situation is entirely US-based, you should be fine without filing Hungarian taxes.

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I was in a similar situation last year with tax residency questions across multiple countries and used https://taxr.ai to get clarity. It analyzes your specific situation against the relevant tax treaties and residency rules. After answering some questions about my citizenship, residence history, and income sources, it confirmed I only needed to file in my country of residence. It actually explained that Hungary follows a territorial tax system primarily focused on residents and Hungarian-source income, not on citizenship. The tool also provided relevant Hungarian tax code references that I could share with my accountant.

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How accurate was the info from that site? Did you verify it with an actual international tax specialist? I've been burned before by online tax tools that don't account for the nuances of international situations.

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Does it handle the fact that this treaty is being terminated? I mean, all the old rules are changing, so I wonder if the tool is updated for this specific US-Hungary situation that's happening right now.

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The information was very accurate - I cross-checked it with my accountant who specializes in expat taxes, and everything aligned with what she told me. The difference was I saved about $400 in consultation fees by having the research done beforehand. Yes, the tool is regularly updated with recent tax treaty changes, including terminations. When I used it, it specifically flagged the US-Hungary treaty termination and explained how the basic rules would change. It distinguishes between rules under the treaty versus standard tax law that applies without a treaty.

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Just wanted to update that I used https://taxr.ai after seeing it mentioned here. As a dual US-German citizen with family ties to Hungary, I was worried about similar issues. The analysis confirmed that I don't need to file Hungarian taxes since I have no income there and don't meet their residency criteria. It explained that even after the treaty termination, Hungary's domestic tax laws still primarily focus on residence and source of income rather than citizenship alone. The tool even provided specific sections of Hungarian tax code that exempt non-residents with no Hungarian income from filing requirements. Saved me from unnecessarily hiring an international tax specialist for what turned out to be a non-issue in my situation!

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If you're having trouble getting clear answers about this tax treaty situation, I'd recommend using https://claimyr.com to get through to the IRS international tax department. I spent WEEKS trying to get clarification on a somewhat similar issue with the US-Canada tax treaty changes, but kept hitting automated systems and ridiculous wait times. With Claimyr, I got through to an actual IRS agent in under 30 minutes who specialized in international tax matters. They confirmed exactly which forms I needed and which ones I could skip. You can see how it works in this demo: https://youtu.be/_kiP6q8DX5c This saved me from unnecessarily filing forms that didn't apply to my situation and potentially raising red flags in the system.

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Wait, how does that even work? The IRS phone system is notoriously impossible to navigate. Is this just them calling repeatedly until they get through or something?

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Sounds fishy to me. The IRS international department barely answers their own phones - how would some third party service get preferential access? And why would an IRS agent give advice on Hungarian tax requirements anyway? They only know US tax law.

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They use a combination of technology that navigates the IRS phone system and secures your place in line. It's completely legitimate - they don't have "special access" but rather a system that handles the most frustrating part of contacting the IRS. You're right that the IRS won't advise on Hungarian tax law specifically, but they can definitively clarify the US side of things - which forms you need to file as a dual citizen, how the treaty termination affects your US filing requirements, and whether you need to report certain types of foreign accounts or assets. In my case, this clarity on the US requirements was exactly what I needed.

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I'm eating crow right now. After posting my skeptical comment yesterday, I decided to try https://claimyr.com myself since I've been trying to reach the IRS about my FBAR requirements as a dual citizen for MONTHS. Not only did I get through to an actual human at the IRS in about 20 minutes, but they transferred me to someone in the international department who answered all my questions about my reporting requirements as a dual citizen. The agent confirmed that for dual citizens, the treaty termination mainly impacts people with income sources in both countries or those living in one country with citizenship in the other. Since my situation is similar to yours (all US income), it shouldn't create new filing obligations. Didn't expect it to actually work, but it absolutely did. Worth every penny to finally get clear answers from an official source.

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I work for an accounting firm that handles international tax situations. Here's a quick breakdown of what the US-Hungary treaty termination means for someone in your position: 1) If you're a US resident with only US income, Hungary generally won't require you to file there, treaty or no treaty 2) The "tie-breaker" rules in the treaty that determined where you're taxed won't apply anymore 3) If you ever have Hungarian income or assets in the future, you might face double taxation in some cases 4) There could be implications for retirement accounts or investments, but that doesn't apply to your situation Generally speaking, citizenship alone doesn't create tax obligations in Hungary - they focus on residency and source of income.

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What about inheritances? I'm in a similar situation (dual US-Hungarian citizen living in US) but expecting an inheritance from Hungary in the next few years. Will the treaty termination affect how that's taxed?

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Inheritance taxation is an important consideration. Without the treaty, Hungary's inheritance tax would apply to any assets physically located in Hungary, regardless of your residency status. The US also taxes worldwide estates of US citizens. So yes, you could potentially face inheritance tax in both countries on Hungarian assets. Hungary generally applies inheritance tax on property within its borders, with rates varying based on relationship to the deceased and value. You may be eligible for foreign tax credits in the US to offset some double taxation, but the process is more complicated without the treaty provisions.

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Has anyone actually contacted the Hungarian consulate about this? I'm also a dual citizen and when I called them about the tax treaty last month, they told me that Hungarian citizens who are permanent residents of another country typically don't have tax filing obligations in Hungary unless they have Hungarian-source income or spend more than 183 days in Hungary.

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Great suggestion. I emailed the Hungarian consulate in Chicago last week with almost this exact question (dual citizen, live in US). They confirmed what you said - as long as you're a tax resident of the US with no Hungarian income, you don't have Hungarian tax filing requirements. The treaty ending doesn't change this fundamental approach.

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This is really helpful information from everyone! I'm in a nearly identical situation as the original poster - US-Hungarian dual citizen, born in US, never lived in Hungary, all income from US sources. From what I'm gathering from all the responses, it sounds like the treaty termination shouldn't create new tax filing obligations for people like us since Hungary primarily taxes based on residency and source of income, not citizenship alone. I'm particularly interested in the suggestions about contacting the Hungarian consulate directly. It sounds like they're giving consistent answers that dual citizens who are permanent US residents without Hungarian income don't need to file there. Has anyone here actually gone through a treaty termination situation before with another country? I'm curious if there are any unexpected complications that tend to pop up during the transition period that we should be aware of.

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