This is a Technical Explanation of the Convention between the Government of the United States and the Government of the Republic of Hungary for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income, signed on February 4, 2010 (the "Convention"). Negotiations took into account the U.S. Treasury Department's current tax treaty policy, and the Treasury Department's Model Income Tax Convention. Negotiations also took into account the Model Tax Convention on Income and on Capital, published by the Organisation for Economic Cooperation and Development (the "OECD Model"), and recent tax treaties concluded by both countries.1 The Technical Explanation is an official guide to the Convention and an accompanying Exchange of Notes. It reflects the policies behind particular provisions in the Convention and Exchange of Notes, as well as understandings reached during the negotiations with respect to the application and interpretation of the Convention and Exchange of Notes. References in the Technical Explanation to "he" or "his" should be read to mean "he or she" or "his and her."