What Hungarian High Tech Companies Need to Know Now that the U.S.-Hungarian Tax Treaty Will be Terminated

What Hungarian High Tech Companies Need to Know Now that the U.S.-Hungarian Tax Treaty Will be Terminated

Tax Treaty
By Anthony Diosdi and Istvan Csovari On July 8, 2022, the Biden administration announced that it will terminate the United States-Hungary Income Tax Treaty that was enacted in 1979. The provisions of the tax treaty will no longer apply beginning on January 1, 2024. According to a July 8, 2022, article in the Wall Street Journal entitled “U.S. Moves to End Tax Treaty With Hungary”, the U.S. Department of the Treasury (the “Treasury”) explained that its action was based on long-standing concerns with Hungary’s tax system and the treaty itself, and a lack of satisfactory action by Hungary to remedy these concerns in coordination with other EU member countries that are seeking to implement the OECD Pillar Two global minimum tax proposal. The treaty’s termination will apply to U.S.-source dividends,…
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What is an RRSP and How is it Taxed Under the United States- Canada Income Tax Treaty

What is an RRSP and How is it Taxed Under the United States- Canada Income Tax Treaty

Tax Treaty
By Anthony DiosdiThe Canadian diaspora in the United States comprises approximately 3.1 million individuals who were either born in Canada or reported Canadian ancestry. Many of these individuals have Canadian registered retirement accounts or (“RRSPs”). An RRSP is a retirement savings and investing vehicle for employees and self-employed individuals in Canada. Under Canadian tax law, money that is placed into an RRSP grows tax-free until it is withdrawn from the account. An RRSP is similar to a U.S. 401(k) plan. There are a number of retirement plans available to Canadian residents to save for retirement. These plans provide tax deferral benefits and are intended to promote savings for retirements. Some common Canadian retirement plans are RRSPs, registered retirement income funds (“RRIFs”), tax-free savings accounts (“TFSAs”), registered education savings plans (“RDSPs”),…
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What is Superannuation and How it Could be Taxed Under the United States- Australia Income Tax Treaty

What is Superannuation and How it Could be Taxed Under the United States- Australia Income Tax Treaty

Tax Treaty
There are currently more than 100,000 Australian-born people living in the United States. Many of these individuals have an Australian Superannuation account. A superannuation is an Australian pension program created by a company to benefit its employees. Funds deposited in a superannuation account will grow through appreciation and contributions until retirement or withdrawal. As with many foreign pension plans, the U.S. federal taxation of superannuation accounts is a gray area. The most common type of superannuation is the Self-Managed Superannuation Funds. This article will focus on Self-Managed Superannuation Funds. This is because Self-Managed Superannuation Funds are the most common type of superannuation. Many tax professionals consider a superannuation fund to be a foreign grantor trust for U.S. tax purposes. If a superannuation fund can be classified as a grantor trust,…
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