The provisions of the Uruguay Agreement are similar to those of the Agreement with Brazil. The Uruguay Agreement exempts citizens of a contracting country posted by a company to that contracting country to work five years or less in the other country under contract from the payment of social security taxes to the other country. People who have worked in both countries but do not meet the minimum eligibility requirements for both systems may be entitled to a benefit based on the combined coverage credits of the two countries.12 BOB ROTHERY: Yes. Well, without going into details, yes, this agreement has a special regime for people who have worked temporarily in a third country. The United States has signed SAAS with Slovenia and Iceland. Both agreements were transmitted to Congress in May 2018.13 Without congressional objection, both agreements are considered approved by Congress after 60 days of session, but will not enter into force until the first month after 90 days, after each country that is a party to the agreement has informed the other party of the approval of the agreement. Recently, it was announced that the Social Security Totalization Agreement (SSTA) between the United States and Brazil will definitively enter into force on October 1, 2018. It is estimated that about 1.3 million Brazilians and 35,000 Americans will benefit from this agreement. BOB ROTHERY: Therefore, if a person can be subject to social security tax, both in the country of origin and in the host country, it is the agreement that determines which country is responsible for taxation. In general, this is therefore the country where the person works. For example, a U.S. person working in Brazil is usually exempt from the FICA and is only subject to Brazilian social security tax.

This Agreement may in future be amended by supplementary agreements which, after notification of the conclusion of the necessary domestic legal procedures of each State Party, shall be considered as an integral part of this Agreement from their entry into force. Such agreements may take effect retroactively if they so provide. Reducing the Potential Double Taxation of Social Security BOB ROTHERY: Well, thank you, and I`m glad to be with you today, John. The aggregation agreement is therefore like a mini-contract that prevents a double social security tax and it also coordinates the provision of certain social security benefits. The agreement with Brazil was therefore already signed in June 2015, and it is the 27th of the United States. We asked our international social security expert, Bob Rothery, in San Diego, to comment on the details of the deal. Welcome, Bob. First of all, Bob, remember, what is a totalization agreement? It`s good to know. Well, thank you for helping us better understand the important features of this historic agreement between the two countries.