IRS Pub 901 - US Tax Treaty Benefits

Userid: ________ DTD TIP04 Leadpct: 0% Pt.
size: 8 ❏ Draft ❏ Ok to Print

PAGER/SGML Fileid: D:\Users\h2ycb\documents\epicfiles\08P901.sgm (Init. & date)
Page 1 of 52 of Publication 901 12:36 - 23-APR-2008
The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.
Publication 901
(Rev. April 2008) Contents
Cat. No. 46849F What’s New . . . . . . . . . . . . . . . . . . . . . 1
Department
of the Reminders . . . . . . . . . . . . . . . . . . . . . . 2
Treasury
Internal
U.S. Tax Introduction . . . . . . . . . . . . . . . . . . . . .
Application of Treaties . . . . . . . . . . . . .
2
2
Revenue
Service
Treaties Tax Exemptions Provided by
Treaties . . . . . . . . . . . . . . . . ..... 2
Personal Services Income . . . . ..... 3
Professors, Teachers, and
Researchers . . . . . . . . . . . . . . . 15
Students and Apprentices . . . . . . . . . 19
Wages and Pensions Paid by a
Foreign Government . . . . . . . . . . 28
Explanation of Tables . . . . . . . . . . . . . . 33
Table 1 - Tax Rates on Income
Other Than Personal Service
Income . . . . . . . . . . . . . . . . . . . 34
Table 2 - Exempt Personal
Services Income . . . . . . . . . . . . 38
Table 3 - List of Tax Treaties . . . . . . . 50
How To Get Tax Help . . . . . . . . . . . . . . 51
What’s New
New tax treaties and protocols. The United
States has exchanged instruments of ratification
for a new income tax treaty with Belgium and
new protocols for the income tax treaties with
Denmark, Finland, and Germany. The provi-
sions of these treaties and protocols are in-
cluded in the appropriate areas of this
publication. The effective dates are as follows:
Belgium. The provisions relating to with-
holding tax at source are effective for amounts
paid or credited on or after February 1, 2008. For
other taxes, the treaty is effective for tax periods
beginning on or after January 1, 2008. A person
entitled to benefits under the previous treaty can
elect to have that treaty apply in its entirety for a
twelve-month period following the date the new
treaty would otherwise apply.
Denmark. The provisions relating to with-
paid or credited on or after February 1, 2008. For
other taxes, the protocol is effective for tax peri-
ods beginning on or after January 1, 2008.
Finland. The provisions relating to withhold-
ing tax at source are effective for amounts paid
or credited on or after February 1, 2008. How-
ever, the provisions for dividends exempt under
Article 10(3) as amended by this protocol are
effective January 1, 2007. For other taxes, the
protocol is effective for tax years beginning on or
after January 1, 2008.
Germany. The provisions relating to with-
paid or credited on or after January 1, 2007. For
other taxes, the treaty is effective for tax years
beginning on or after January 1, 2008. A person
entitled to benefits under the treaty before modi-
Get forms and other information fication by this protocol can elect to have the
unmodified treaty apply in its entirety for a
faster and easier by: twelve-month period following the date the pro-
tocol would otherwise apply.
Internet • www.irs.gov
We respond to many letters by telephone.

Reminders Therefore, it would be helpful if you would in- Application of Treaties
clude your daytime phone number, including the
Disclosure of a treaty-based position that area code, in your correspondence. The United States has income tax treaties with a
reduces your tax. If you take the position that You can email us at *taxforms@irs.gov. (The number of foreign countries. Under these trea-
any U.S. tax is overruled or otherwise reduced asterisk must be included in the address.) ties, residents (not necessarily citizens) of for-
by a U.S. treaty (a treaty-based position), you Please put “Publications Comment” on the sub- eign countries are taxed at a reduced rate, or are
generally must disclose that position on your ject line. Although we cannot respond individu- exempt from U.S. income taxes on certain items
affected return. See Application of Treaties, ally to each email, we do appreciate your of income they receive from sources within the
later. feedback and will consider your comments as United States. These reduced rates and exemp-
we revise our tax products. tions vary among countries and specific items of
U.S. – U.S.S.R. income tax treaty. The
Ordering forms and publications. Visit income.
U.S. – U.S.S.R. income tax treaty remains in ef-
www.irs.gov/formspubs to download forms and If the treaty does not cover a particular kind
fect for the following members of the Common-
publications, call 1-800-829-3676, or write to the of income, or if there is no treaty between your
wealth of Independent States: Armenia,
address shown in the How To Get Tax Help country and the United States, you must pay tax
Azerbaijan, Belarus, Georgia, Kyrgyzstan,
section under Mail. on the income in the same way and at the same
Moldova, Tajikistan, Turkmenistan, and Uzbeki-
rates shown in the instructions for Form
stan. That treaty will remain in effect until new Obtaining copies of treaties. You can get 1040NR. Also see Publication 519.
treaties with these individual countries are nego- complete information about treaty provisions Many of the individual states of the United
tiated and ratified. Provisions of the from the taxing authority in the country from States tax the income of their residents. There-
U.S. – U.S.S.R. income tax treaty are discussed which you receive income or from the treaty fore, you should consult the tax authorities of the
in this publication under Commonwealth of Inde- itself. state in which you live to find out if that state
pendent States. You can obtain the text of most of the treaties taxes the income of individuals and, if so,
at www.irs.gov/businesses/international. You whether the tax applies to any of your income.
U.S. – China income tax treaty. The can also obtain the text of most of the treaties at
U.S. – China income tax treaty does not apply to Tax treaties reduce the U.S. taxes of re-
the following address: sidents of foreign countries. With certain excep-
Hong Kong.
Department of the Treasury tions, they do not reduce the U.S. taxes of U.S.
U.S. – United Kingdom income tax treaty. Office of Public Correspondence citizens or residents. U.S. citizens and residents
Generally, the treaty is effective for tax periods 1500 Pennsylvania Ave. NW — Rm. 3419 are subject to U.S. income tax on their world-
beginning on or after January 1, 2004. However, Washington, D.C. 20220 wide income.
an individual who was otherwise entitled to Treaty provisions generally are reciprocal
treaty benefits under Article 21 (students and If you have specific questions about a treaty, (apply to both treaty countries); therefore, a U.S.
trainees) of the former treaty can continue to you can get this information from most Internal citizen or resident who receives income from a
apply that provision. Revenue Service offices or from: treaty country may refer to the tables in this
publication to see if a tax treaty might affect the
U.S. – Japan income tax treaty. Generally, Internal Revenue Service tax to be paid to that foreign country. Foreign
the treaty is effective for tax periods beginning International Returns Section taxing authorities sometimes require certifica-
on or after January 1, 2005. However, an individ- P.O. Box 920 tion from the U.S. Government that an applicant
ual who was entitled to treaty benefits under Bensalem, PA 19020-8518 filed an income tax return as a U.S. citizen or
Article 19 (teachers and researchers) or Article resident, as part of the proof of entitlement to the
20 (students and trainees) of the former treaty Tax questions. If you have a tax question, treaty benefits. For more information, see Publi-
as of March 30, 2004, can continue to apply check the information available on www.irs.gov cation 686.
those provisions. or call 1-800-829-1040.
Disclosure of a treaty-based position that
reduces your tax. If you take the position that
Useful Items any U.S. tax is overruled or otherwise reduced
You may want to see:
by a U.S. treaty (a treaty-based position), you
Introduction generally must disclose that position on Form
Publication
This publication will tell you whether a tax treaty 8833 and attach it to your return. If you are not
between the United States and a particular ❏ 519 U.S. Tax Guide for Aliens required to file a return because of your
country offers a reduced rate of, or possibly a treaty-based position, you must file a return any-
❏ 597 Information on the United
complete exemption from, U.S. income tax for way to report your position. The filing of Form
States – Canada Income Tax Treaty
residents of that particular country. 8833 does not apply to a reduced rate of with-
Tables in the back of this publication show ❏ 686 Certification for Reduced Tax Rates holding tax on noneffectively connected income,
the countries that have income tax treaties with in Tax Treaty Countries such as dividends, interest, rents or royalties, or
the United States, the tax rates on different kinds to a reduced rate of tax on pay received for
Form (and Instructions) services performed as an employee, including
of income, and the kinds of income that are
pensions, annuities, and social security. For
exempt from tax. ❏ 8833 Treaty-Based Return Position
more information, see Publication 519 and the
You should use this publication only for Disclosure Under Section 6114 or
Form 8833 instructions.
7701(b)
! quick reference. It is not a complete
See How To Get Tax Help near the end of
If you fail to file Form 8833, you may have to
CAUTION
guide to all provisions of every income pay a $1,000 penalty. Corporations are subject
tax treaty. this publication for information about getting
to a $10,000 penalty for each failure.
these publications and forms.
Comments and suggestions. We welcome

your comments about this publication and your
suggestions for future editions. Tax Exemptions
You can write to us at the following address:
Provided by Treaties
Internal Revenue Service In addition to the tables in the back of this publi-
Individual Forms and Publications Branch cation, this publication contains discussions of
SE:W:CAR:MP:T:I the exemptions from tax and certain other ef-
1111 Constitution Ave. NW, IR-6526 fects of the tax treaties on the following types of
Washington, DC 20224 income.
Page 2 Publication 901 (April 2008)

• Pay for certain personal services per- • The pay is paid by, or on behalf of, an If they have a fixed base available in the United
formed in the United States. employer or company that is not a resident States, they are taxed on the income attributable
of the United States, and to the fixed base.
• Pay of a professor, teacher, or researcher
who teaches or performs research in the • The pay is not deductible in determining Income that residents of Bangladesh receive
United States for a limited time. the taxable income of the trade or busi- for services performed in the United States as
ness of the employer (or company) in the employees (dependent personal services) is ex-
• Amounts received for maintenance and United States. empt from U.S. income tax if the residents meet
studies by a foreign student or apprentice
the following requirements.
who is here for study or experience. These exemptions do not apply to public en-
• Wages, salaries, and pensions paid by a tertainers (such as theater, motion picture, ra- • They are in the United States for no more
dio, or television entertainers, musicians, and than 183 days in any 12-month period be-
foreign government.
athletes) from Australia who earn more than ginning or ending in the tax year.
$10,000 in gross receipts, including reimbursed • Their income is paid by, or on behalf of, an
Personal Services Income expenses, from their entertainment activities in employer who is not a U.S. resident.
the United States during the tax year.
Pay for certain personal services performed in • Their income is not borne by a permanent
the United States is exempt from U.S. income establishment or a fixed base that the em-
tax if you are a resident of one of the countries Austria ployer has in the United States.
discussed below, if you are in the United States
for a limited number of days, and if you meet Income that residents of Austria receive for per- These exemptions do not apply to pubic en-
certain other conditions. For this purpose, the sonal services as independent contractors or tertainers (such as theater, motion picture, ra-
word “day” means a day during any part of which self-employed individuals (independent per- dio, or television entertainers, musicians, and
you are physically present in the United States. sonal services) in the United States is exempt athletes) from Bangladesh who earn more than
from U.S. income tax if they do not have a fixed $10,000 in gross receipts, including reimbursed
Terms defined. Several terms appear in base regularly available to them in the United expenses, from their entertainment activities in
many of the discussions that follow. The exact States for performing the services. If they have a the United States during the tax year. Regard-
meanings of the terms are determined by the fixed base available in the United States, they less of these limits, income of Bangladesh enter-
particular tax treaty under discussion; thus, the are taxed on the income attributable to the fixed tainers is exempt from U.S. income tax if their
meanings vary among treaties. The definitions base. visit to the United States is wholly or mainly
that follow are, therefore, general definitions that Income that residents of Austria receive for supported by public funds of Bangladesh, its
may not give the exact meaning intended by a services performed in the United States as em- political subdivisions, or local authorities.
particular treaty. ployees (dependent personal services) is ex- Income received from employment as a
empt from U.S. income tax if the residents meet
The terms fixed base and permanent estab- member of the regular complement of a ship or
the following requirements.
lishment generally mean a fixed place of busi- an aircraft operated by a Bangladesh enterprise
ness, such as a place of management, a branch, • They are in the United States for no more in international traffic is exempt from U.S. tax. If
an office, a factory, a warehouse, or a mining than 183 days in any 12-month period be- the ship or aircraft is operated by a U.S. enter-
site, through which an enterprise carries on its ginning or ending in the tax year. prise, the income is subject to U.S. tax.
business. • Their income is paid by, or on behalf of, an If the resident of Bangladesh is a share-
The term borne by generally means having employer who is not a U.S. resident. holder in a U.S. corporation, these exemptions
ultimate financial accounting responsibility for or do not apply to director’s fees received as a
providing the monetary resources for an expen- • Their income is not borne by a permanent member of the board of directors of the U.S.
diture or payment, even if another entity in an- establishment or a fixed base that the em- corporation. The amount received by the share-
other location actually made the expenditure or ployer has in the United States. holder that is more than the amount paid to a
payment. director that is not a shareholder is subject to
These exemptions do not apply to public en- U.S. tax at the rate of 15%.
tertainers (such as theater, motion picture, ra-
Australia dio, or television entertainers, musicians, and
athletes) from Austria who earn more than Barbados
Income that residents of Australia receive for $20,000 in gross receipts, including reimbursed
performing personal services as independent expenses, from their entertainment activities in Income that residents of Barbados receive for
contractors or self-employed individuals (inde- the United States during the tax year. performing personal services as independent
pendent personal services) in the United States Income received by a resident of Austria for contractors or self-employed individuals (inde-
during the tax year is exempt from U.S. income services performed as an employee and mem- pendent personal services) in the United States
tax if the residents: ber of the regular complement of a ship or air- during the tax year is exempt from U.S. income
craft operated in international traffic is exempt tax if the residents:
• Are in the United States for no more than from U.S. income tax.
183 days during the tax year, and • Are in the United States for no more than
89 days during the tax year,
• Do not have a fixed base regularly avail-
able to them in the United States for the Bangladesh • Earn net income for independent services
purpose of performing the services. provided to U.S. residents that is not more
Income that residents of Bangladesh receive for than $5,000 (there is no dollar limit if the
If they have a fixed base available in the United performing personal services as independent contractors are not U.S. residents), and
States, they are taxed on the income attributable contractors or self-employed individuals (inde-
to the fixed base. pendent personal services) in the United States • Do not have a regular base available in
during the tax year is exempt from U.S. income the United States for performing the serv-
Pay that residents of Australia receive for la-
tax if the residents: ices.
bor or personal services performed in the United
States as employees (dependent personal serv- • Are in the United States for no more than If they have a regular base available in the
ices), including services as a director of a com- 183 days in any 12-month period begin- United States but otherwise meet the conditions
pany, is exempt from U.S. income tax if: ning or ending in the tax year, or for exemption, they are taxed only on the income
attributable to the regular base.
• The residents are in the United States for • Do not have a fixed base regularly avail-
no more than 183 days during the tax able to them in the United States for the Income that residents of Barbados receive for
year, purpose of performing the services. personal services performed in the United
Publication 901 (April 2008) Page 3

States as employees (dependent personal serv- The exemption does not apply to public en- the services. If they have a fixed base available
ices) is exempt from U.S. tax if the residents tertainers (such as theater, motion picture, ra- in the United States, they are taxed on the in-
meet four requirements. dio, or television artists, musicians, or athletes) come attributable to the fixed base.
from Belgium who earn more than $20,000 in Income that residents of Canada receive for
• They are in the United States for no more gross receipts, including reimbursed expenses,
than 183 days during the calendar year. personal services performed as employees (de-
from their entertainment activities in the United pendent personal services) in the United States
• The income earned in the calendar year in States during the tax year. is exempt from U.S. tax if it is not more than
the United States is not more than $5,000. Income received by a resident of Belgium for $10,000 for the year. If the income is more than
services performed as an employee and mem- $10,000 for the year, it is exempt only if:
• Their income is paid by or for an employer ber of the regular complement of a ship or air-
who is not a U.S. resident. craft operated in international traffic is exempt • The residents are present in the United
• The income is not borne by a permanent from U.S. income tax. States for no more than 183 days during
the calendar year, and
establishment or regular base of the em-
ployer in the United States. Former treaty. Income that residents of • The income is not borne by a U.S. resi-
Belgium receive for performing personal serv- dent employer or by a permanent estab-
Income of a Barbadian resident from employ- ic es as i n d e p e n d e n t c o n t r a c t o r s o r lishment or fixed base of an employer in
ment as a member of the regular complement of self-employed individuals (independent per- the United States.
a ship or aircraft operated in international traffic sonal services) in the United States during the
is exempt from U.S. tax. tax year is exempt from U.S. income tax if the These exemptions do not apply to public en-
residents: tertainers (such as theater, motion picture, ra-
These exemptions do not apply to Barbadian
resident public entertainers (such as theater, • Are present in the United States less than dio, or television artists, musicians, or athletes)
motion picture, radio, or television artists, musi- 183 days during the tax year, and from Canada who derive more than $15,000 in
gross receipts, including reimbursed expenses,
cians, or athletes) who receive gross receipts of • Do not maintain a fixed base in the United from their entertainment activities in the United
more than $250 per day or $4,000 in the tax States for a period or periods that total
year, not including reimbursed expenses, from States during the calendar year. However, the
more than 182 days during the tax year.
their entertainment activities in the United exemptions do apply, regardless of this $15,000
States. However, the exemptions do apply re- If they do not meet condition (2), they are taxed limit, to athletes participating in team sports in
gardless of these limits on gross receipts if the on the income attributed to the fixed base. leagues with regularly scheduled games in both
entertainer’s visit to the United States is sub- Canada and the United States.
The exemption for independent personal
stantially supported by Barbadian public funds services does not apply to individuals who are Pay received by a resident of Canada for
or if the entertainer’s services are provided to a public entertainers (theater, motion picture, or employment regularly done in more than one
nonprofit organization. television artists, musicians, or athletes), if they country on a ship, aircraft, motor vehicle, or train
are in the United States for more than 90 days operated by a Canadian resident is exempt from
during the tax year or if their pay for services as U.S. tax.
Belgium public entertainers is more than $3,000.
Income that residents of Belgium receive for
labor or personal services performed in the China, People’s Republic of
Note. See the effective dates of the new United States as employees (dependent per-
treaty under What’s New at the beginning of this Income that residents of the People’s Republic
sonal services), including services as an officer of China receive for personal services as inde-
publication. of a corporation, is exempt from U.S. income tax pendent contractors or self-employed individu-
if the residents meet three requirements.
New treaty. Income that residents of Belgium als (independent personal services) that they
receive for personal services as independent • They are present in the United States less perform during the tax year in the United States
contractors or self-employed individuals are than 183 days during the tax year. is exempt from U.S. income tax if the residents:
subject to the provisions of Article 7 (Business • They are employees of a resident of • Are present in the United States for no
Profits) of the treaty. Under that provision, busi- Belgium or of a permanent establishment more than 183 days in the calendar year,
ness profits are exempt from U.S. income tax in Belgium. and
unless they have a permanent establishment in
• Their income is not borne by a permanent • Do not have a fixed base regularly avail-
the United States. If they have a permanent
establishment that the employer has in the able in the United States for performing
establishment available in the United States,
United States. the services.
they are taxed on the income attributable to the
permanent establishment. If they have a fixed base available in the United
Income for services performed by an individ-
Income that residents of Belgium receive for States, they are taxable on the income attributa-
ual as an employee aboard a ship or an aircraft
services performed in the United States as em- ble to the fixed base.
registered in Belgium and operated by a resi-
ployees (dependent personal services) is ex- dent of Belgium in international traffic is exempt Pay received by residents of the People’s
empt from U.S. income tax if the residents meet from U.S. tax if the individual is a member of the Republic of China for services performed as
the following requirements. regular complement of the ship or aircraft. employees (dependent personal services) in the
• They are in the United States for no more These exemptions do not apply to fees re- United States is exempt from U.S. tax if:
ceived by a resident of Belgium for services
than 183 days in any 12-month period be-
performed as a director of a U.S. corporation if
• The residents are present in the United
ginning or ending in the tax year. States for no more than 183 days in the
the fees are treated as a distribution of profits
calendar year,
• Their income is paid by, or on behalf of, an and cannot be taken as a deduction by the
employer who is not a U.S. resident. corporation. • The pay is paid by or for an employer who
is not a U.S. resident, and
• Their income is not borne by a permanent
establishment that the employer has in the
Canada • The pay is not borne by a permanent es-
United States. tablishment or fixed base that the em-
Income that residents of Canada receive for ployer has in the United States.
The exemption does not apply to directors’ personal services as independent contractors or
fees and similar payments received by a resi- self-employed individuals (independent per- These exemptions do not apply to directors’
dent of Belgium for services performed in the sonal services) that they perform during the tax fees for service on the board of directors of a
United States as a member of the board of year in the United States is exempt from U.S. tax U.S. corporation.
directors of a company that is a resident of the if they do not have a fixed base regularly avail- These exemptions generally do not apply to
United States. able to them in the United States for performing income received as a public entertainer (such as

a theater, motion picture, radio, or television Czech Republic Income that residents of Denmark receive for
artist, musician, or athlete). However, income of services performed in the United States as em-
athletes or public entertainers from China partic- Income that residents of the Czech Republic ployees (dependent personal services) is ex-
ipating in a cultural exchange program agreed receive for performing personal services as in- empt from U.S. income tax if the residents meet
upon by the U.S. and Chinese governments is dependent contractors or self-employed individ- the following requirements.
exempt from U.S. tax. uals (independent personal services) in the
United States is exempt from U.S. income tax if • They are in the United States for no more
the residents: than 183 days in any 12-month period be-
Commonwealth of ginning or ending in the tax year.
• Are present in the United States for no
Independent States
more than 183 days in any 12-month pe- • Their income is paid by, or on behalf of, an
riod, and employer who is not a U.S. resident.
Income that residents of a C.I.S. member re-
ceive for performing personal services in the • Do not have a fixed base regularly avail- • Their income is not borne by a permanent
United States is exempt from U.S. income tax if able to them in the United States for per- establishment or a fixed base that the em-
those residents are in the United States for no ployer has in the United States.
forming the services.
more than 183 days during the tax year.
Pay received by an employee who is a mem- If they have a fixed base available, they are These exemptions do not apply to directors’
ber of the regular complement of a ship or air- taxed only on income attributable to the fixed fees and similar payments received by a resi-
craft operated in international traffic by a C.I.S. base. dent of Denmark as a member of the board of
member or a resident of a C.I.S. member is directors of a company that is a resident of the
Income that residents of the Czech Republic
exempt from U.S. tax. United States.
receive for employment in the United States
(dependent personal services) is exempt from These exemptions do not apply to public
U.S. income tax if the following three require- entertainers (such as theater, motion picture,
Cyprus radio, or television artists, musicians, and ath-
ments are met.
Income that residents of Cyprus receive for per- letes) from Denmark who earn more than
• The resident is present in the United $20,000 in gross receipts, including reimbursed
forming personal services as independent con- States for no more than 183 days in any
tract ors o r se lf-em ploy ed indiv iduals expenses, from their entertainment activities in
12-month period. the United States during the tax year.
(independent personal services) in the United
States during the tax year is exempt from U.S. • The income is paid by, or on behalf of, an Income received by a resident of Denmark
income tax if the residents: employer who is not a U.S. resident. for services performed as an employee and
member of the regular complement of a ship or
• Are present in the United States for less • The income is not borne by a permanent aircraft operated in international traffic is exempt
than 183 days in the tax year, and establishment or a fixed base that the em-
from U.S. income tax.
ployer has in the United States.
• Do not have a fixed base regularly avail-
able to them in the United States for per-
These exemptions do not apply to income Egypt
residents of the Czech Republic receive as pub-
If they have a fixed base available in the United lic entertainers (such as theater, motion picture, Income that residents of Egypt receive for per-
States, they are taxable on the income attributa- radio, or television artists, or musicians) or forming personal services as independent con-
ble to the fixed base. sportsmen if their gross receipts, including reim- tractors or as self-employed individuals
Pay received by residents of Cyprus from bursed expenses, are more than $20,000 during (independent personal services) in the United
services performed as employees (dependent the tax year. Regardless of these limits, income States during the tax year is exempt from U.S.
personal services), including services as an of- of Czech entertainers and sportsmen is exempt income tax if they are in the United States for no
ficer of a corporation, is exempt from U.S. in- from U.S. income tax if their visit to the United more than 89 days during the tax year.
come tax if: States is substantially supported by public funds Income that residents of Egypt receive for
of the Czech Republic, its political subdivisions, labor or personal services performed in the
• The residents are in the United States for or local authorities, or the visit is made pursuant United States as employees (dependent per-
less than 183 days during the tax year, to a specific arrangement between the United sonal services), including income for services
• The pay is paid by or for an employer who States and the Czech Republic. performed by an officer of a corporation or com-
is not a U.S. resident, and These exemptions do not apply to directors’ pany, is exempt from U.S. income tax if the
• The pay is not borne by a permanent es- fees and similar payments received by a resi- residents meet four requirements.
dent of the Czech Republic as a member of the
tablishment, fixed base, or trade or busi- • They are in the United States for no more
ness that the employer has in the United board of directors of a company that is a resident than 89 days during the tax year.
States. of the United States.
Income from employment as a member of • They are employees of a resident of, or a
Pay received by a Cyprus resident for per- the regular complement of a ship or aircraft permanent establishment in, Egypt.
forming personal services as an employee and operated by a Czech enterprise in international • Their income is not borne by a permanent
member of the regular complement of a ship or traffic is exempt from U.S. income tax. If the ship establishment that the employer has in the
aircraft operated in international traffic by a resi- or aircraft is operated by a U.S. enterprise, the United States.
dent of Cyprus is exempt from U.S. tax. income is subject to U.S. tax.
These exemptions do not apply to Cyprus • Their income is subject to Egyptian tax.
resident public entertainers (theater, motion pic-
ture, radio, or television artists, musicians, or Denmark This exemption does not apply to pay re-
athletes) who receive gross receipts of more ceived by a resident of Egypt who is an em-
than $500 per day or $5,000 for the tax year, not Income that residents of Denmark receive for ployee and member of the regular complement
including reimbursed expenses, from their en- personal services as independent contractors or of a ship or an aircraft operated in international
tertainment activities in the United States. self-employed individuals (independent per- traffic by a resident of the United States.
Directors’ fees received by residents of Cy- sonal services) in the United States is exempt These exemptions do not apply to Egyptian
prus for service on the board of directors of a from U.S. income tax if they do not have a fixed resident public entertainers (theater, motion pic-
U.S. corporation are exempt from U.S. income base regularly available to them in the United ture, radio, or television artists, musicians, or
tax to the extent of a reasonable fixed amount States for performing the services. If they have a athletes), who earn income for services as pub-
payable to all directors for each day of attend- fixed base available in the United States, they lic entertainers if the gross amount of the income
ance at directors’ meetings held in the United are taxed on the income attributable to the fixed is more than $400 for each day they are in the
States. base. United States performing the services.

Estonia • They are in the United States for no more Germany

than 183 days during any 12-month pe-
Income that residents of Estonia receive for per- riod.
forming personal services as independent con- Note. See the effective dates of the protocol
tract ors o r se lf-em ploy ed indiv iduals • Their income is paid by, or on behalf of, an under What’s New at the beginning of this publi-
(independent personal services) in the United employer who is not a resident of the cation.
States is exempt from U.S. income tax if the United States.
Treaty as modified. Income that residents of
residents: • Their income is not borne by a permanent Germany receive for personal services as inde-
• Are in the United States for no more than establishment, fixed base, or trade or busi- pendent contractors or self-employed individu-
183 days in any 12-month period begin- ness that the employer has in the United als are subject to the provisions of Article 7
ning or ending in the tax year, and States. (Business Profits) of the treaty. Under that provi-
sion, business profits are exempt from U.S. in-
• Do not have a fixed base regularly avail- The exemption does not apply to pay received come tax unless they have a permanent
by a resident of Finland who is an employee and establishment in the United States. If they have
member of the regular complement of a ship or a permanent establishment available in the
If they have a fixed base available, they are aircraft operated in international traffic by a resi- United States, they are taxed on the income
taxed on the income attributable to the fixed dent of the United States. attributable to the permanent establishment.
base. These exemptions do not apply to income Income that residents of Germany receive
residents of Finland receive as public entertain- for labor or personal services performed in the
Income that residents of Estonia receive for
ers or sportsmen if the gross income, including United States as employees (dependent per-
services performed in the United States as em-
reimbursed expenses, is more than $20,000 for sonal services) is exempt from U.S. tax if the
ployees (dependent personal services) is ex-
their personal activities in the United States dur- residents meet three requirements.
empt from U.S. income tax if the following
requirements are met. ing the calendar year. • They are in the United States for no more
than 183 days during the calendar year.
• The resident is in the United States for no
more than 183 days in any 12-month pe- France • The income is paid by, or on behalf of, an
riod beginning or ending in the tax year. employer who is not a resident of the
Income that residents of France receive for per- United States.
• The income is paid by, or on behalf of, an
forming personal services as independent con-
employer who is not a U.S. resident. • The income is not borne by a permanent
t r ac t or s o r s e l f - e m p l o y e d i n d i v i d u a l s
• The income is not borne by a permanent (independent personal services) in the United United States.
establishment or a fixed base that the em- States is exempt from U.S. income tax if they do
ployer has in the United States. not have a fixed base regularly available to them Pay received by a resident of Germany for
in the United States for performing the services. services performed as an employee and mem-
These exemptions do not apply to directors’ If they have a fixed base available in the United ber of the regular complement of a ship or air-
fees and similar payments received by a resi- States, they are taxed on the income attributable craft operated in international traffic is exempt
dent of Estonia as a member of the board of to the fixed base. from U.S. tax.
directors or similar body of a company that is a Income that residents of France receive for The exemption does not apply to directors’
U.S. resident. labor or personal services performed in the fees and other similar payments received by a
Pay received for employment as a member United States as employees (dependent per- resident of Germany for services performed in
of the regular complement of a ship or an aircraft
sonal services) is exempt from U.S. income tax if the United States as a member of the board of
operated in international traffic by a United
the residents meet three requirements. directors of a company resident in the United
States enterprise is subject to U.S. tax.
States.
These exemptions do not apply to income • They are in the United States for no more
The exemption does not apply to income
residents of Estonia receive as public entertain- than 183 days in any 12-month period.
residents of Germany receive as public enter-
ers (such as theater, motion picture, radio, or
• Their income is paid by, or on behalf of, an tainers (such as theater, motion picture, radio, or
television artists, or musicians) or sportsmen if
employer who is not a resident of the television artists, or musicians) or athletes if
their gross receipts, including reimbursed ex-
United States. their gross receipts, including reimbursed ex-
penses, are more than $20,000 for their per-
penses, are more than $20,000 during the cal-
sonal activities in the United States during the • Their income is not borne by a permanent endar year. Regardless of these limits, income
tax year. Regardless of these limits, income of establishment or a fixed base that the em-
of German entertainers or athletes is exempt
Estonian entertainers or athletes is exempt from ployer has in the United States.
from U.S. tax if their visit to the United States is
U.S. income tax if their visit to the United States
substantially supported by public funds of Ger-
is wholly or mainly supported by public funds of Income for services performed by a resident
many, its political subdivisions, or local authori-
Estonia, its political subdivisions, or local author- of France as an employee and member of the
ties.
ities. regular complement of a ship or an aircraft oper-
ated in international traffic is exempt from tax in Unmodified treaty. Generally, the previous
the United States. discussion, other than the first paragraph, ap-
Finland These exemptions do not apply to public plies to the unmodified treaty. Under that treaty,
entertainers (such as theater, motion picture, the first paragraph would be as follows.
Income that residents of Finland receive for per- Income that residents of Germany receive
forming personal services as independent con- radio, or television artists, or musicians), or
sportsmen from France who earn more than for personal services as independent contrac-
tract ors o r se lf-em ploy ed indiv iduals tors or self-employed individuals (independent
(independent personal services) in the United $10,000 in gross receipts, including reimbursed
expenses, from their entertainment activities in personal services) in the United States is ex-
States is exempt from U.S. income tax if they do empt from U.S. income tax if the income is not
not have a fixed base regularly available to them the United States during the tax year. Regard-
less of these limits, income of French entertain- attributable to a fixed base regularly available in
in the United States for performing the services. the United States.
If they have a fixed base available in the United ers or sportsmen is exempt from U.S. tax if their
States, they are taxed on the income attributable visit is principally supported by public funds of
to the fixed base. France.
Greece
Income that residents of Finland receive for These exemptions do not apply to directors’
labor or personal services performed in the fees and similar payments received by a resi- Income that residents of Greece receive for la-
United States as employees (dependent per- dent of France as a member of the board of bor or personal services (including practicing
sonal services) is exempt from U.S. income tax if directors of a company that is a resident of the liberal and artistic professions) is exempt from
the residents meet three requirements. United States. U.S. income tax if they are in the United States

for no more than 183 days during the tax year pay for services as public entertainers is more (such as theater, motion picture, radio, or televi-
and the pay is not more than $10,000. The pay, than $100 per day. sion artists, or musicians) or athletes if their net
regardless of amount, is exempt from U.S. in- Income that residents of Iceland receive for income is more than $1,500 during the tax year
come tax if it is for labor or personal services labor or personal services performed in the for their entertainment activities in the United
performed as employees of, or under contract United States as employees (dependent per- States. Regardless of this limit, the income of
with, a resident of Greece or a Greek corpora- sonal services) is exempt from U.S. income tax if Indian entertainers and athletes is exempt from
tion or other entity of Greece, and if the residents the employees meet three requirements: U.S. tax if their visit to the United States is wholly
are in the United States for no more than 183 or substantially supported from the public funds
days during the tax year. • They are in the United States for no more of the Indian Government, its political subdivi-
than 182 days during the tax year. sions, or local authorities.
• They are employees of a resident of Ice-
Hungary land or of a permanent establishment of a
resident of a state other than Iceland if the Indonesia
Income that residents of Hungary receive for
permanent establishment is located in Ice- Income that residents of Indonesia receive for
performing personal services as independent
land. performing personal services as individual con-
contractors or self-employed individuals (inde-
pendent personal services) in the United States • Their income is not borne by a permanent tractors or self-employed individuals (indepen-
during the tax year is exempt from U.S. tax if the establishment that the employer has in the dent personal services) in the United States
residents: United States. during the tax year is exempt from U.S. income
tax if the residents:
• Are in the United States for no more than
183 days during the tax year, and
Income for services performed by an em- • Are present in the United States for no
ployee aboard a ship or an aircraft operated by a more than 119 days during any consecu-
• Do not have a fixed base regularly avail- resident of Iceland in international traffic or in tive 12-month period, and
able in the United States. fishing on the high seas is exempt from U.S. tax
if the individual is a member of the regular com- • Do not have a fixed base regularly avail-
If they have a fixed base available in the United able to them in the United States for per-
States, they are taxed on the income attributable plement of the ship or aircraft.
to the fixed base.
Income that residents of Hungary receive for India If they have a fixed base available, they are
labor or personal services performed in the taxed only on the income attributable to the fixed
United States as employees (dependent per- Income that residents of India receive for per- base.
sonal services) is exempt from U.S. income tax if forming personal services in the United States Income that residents of Indonesia receive
the residents meet three requirements. during the tax year as independent contractors for personal services performed in the United
or self-employed individuals (independent per- States as employees (dependent personal serv-
• They are in the United States for no more sonal services) is exempt from U.S. income tax if ices) is exempt from U.S. income tax if the re-
than 183 days during the tax year. the residents: sidents meet three requirements.
• Their income is paid by or on behalf of an • Are present in the United States for no • They are present in the United States no
employer who is not a resident of the more than 119 days during any consecu-
more than 89 days during the tax year,
United States. tive 12-month period.
and
• Their income is not borne by a permanent • Do not have a fixed base regularly avail- • The income is paid by, or on behalf of, an
establishment or a fixed base that the em- employer who is not a resident of the
ployer has in the United States. United States.
Pay received by an employee who is a mem- • The income is not borne or reimbursed by
If they have a fixed base available, they are a permanent establishment the employer
ber of the regular complement of a ship or air-
taxed only on income attributable to the fixed has in the United States.
craft operated by a Hungarian enterprise in
base.
international traffic is exempt from U.S. tax. If the
ship or aircraft is operated by a U.S. enterprise, Income that residents of India receive for Pay received by an individual for services
the pay is subject to U.S. tax. personal services performed in the United performed as an employee aboard a ship or
States as employees (dependent personal serv- aircraft operated by an Indonesian resident in
ices) is exempt from U.S. income tax if the re- international traffic is exempt from U.S. tax if the
Iceland sidents meet three requirements. individual is a member of the regular comple-
Income that residents of Iceland receive for per-

• They are present in the United States for ment of the ship or aircraft.
no more than 183 days during the tax These exemptions do not apply to income
forming personal services as independent con- residents of Indonesia receive as public enter-
year.
tract ors o r se lf-em ploy ed indiv iduals tainers (such as theater, motion picture, radio, or
(independent personal services) in the United • The income is paid by, or on behalf of, an television artists, or musicians) or athletes if
States during the tax year is exempt from U.S. employer who is not a resident of the their gross receipts, including reimbursed ex-
income tax if the residents: United States. penses, are more than $2,000 during any con-
• Are present in the United States for no • The income is not borne by a permanent secutive 12-month period. Regardless of these
more than 182 days during the tax year, establishment, fixed base, or trade or busi- limits, income of Indonesian entertainers and
and ness the employer has in the United athletes is exempt from U.S. tax if their visit to
States. the United States is substantially supported or
• Do not maintain a fixed base in the United sponsored by the Indonesian Government and
States for a period or periods totaling the Indonesian competent authority certifies that
The exemption does not apply to pay received
more than 182 days during the tax year. the entertainers or athletes qualify for this ex-
by a resident of India for services performed as
If they do not meet condition (2), they are taxed an employee aboard a ship or aircraft operated emption.
on the income that is attributable to the fixed in international traffic by a U.S. enterprise.
base. These exemptions do not apply to directors’
Ireland
This exemption does not apply to residents of fees and similar payments received by an Indian
Iceland who are public entertainers (theater, resident as a member of the board of directors of Income that residents of Ireland receive for per-
motion picture, or television artists, musicians, a company that is a U.S. resident. sonal services as independent contractors or
or athletes) if they are in the United States for These exemptions do not apply to income self-employed individuals (independent per-
more than 90 days during the tax year or their residents of India receive as public entertainers sonal services) in the United States is exempt

from U.S. income tax if they do not have a fixed These exemptions do not apply to income • Earn net income for those services that is
base regularly available to them in the United that residents of Israel receive as public enter- not more than $5,000 during the tax year if
States for performing the services. If they have a tainers (such as theater, motion picture, radio, or the income is from a U.S. contractor.
fixed base available in the United States, they television artists, musicians, or athletes), if the
If they have a fixed base available in the United
are taxed on the income attributable to the fixed gross amount of the income is more than $400 States, they are taxed only on the income that is
base. for each day they are in the United States per- attributable to the fixed base. There is no dollar
Income that residents of Ireland receive for forming the services. limit for condition (3) if the contractor is from a
services performed in the United States as em- country other than the United States.
ployees (dependent personal services) is ex-
empt from U.S. income tax if the residents meet Italy Income that residents of Jamaica receive for
the following requirements. personal services performed in the United
Income that residents of Italy receive for per- States as employees (dependent personal serv-
• They are in the United States for no more forming personal services in the United States ices) is exempt from U.S. income tax if the re-
than 183 days in any 12-month period be- during the tax year as independent contractors sidents meet four requirements.
ginning or ending in the tax year. or self-employed individuals (independent per-
• They are in the United States for no more
• Their income is paid by, or on behalf of, an sonal services) is exempt from U.S. income tax if
than 183 days during the tax year.
employer who is not a U.S. resident. the residents:
• Are present in the United States for no • Their income is paid by or for an employer
• Their income is not borne by a permanent who is not a resident of the United States.
establishment or a fixed base that the em- more than 183 days in the tax year, and
ployer has in the United States. • Do not have a fixed base regularly avail- • Their income is not borne by a permanent
establishment or a fixed base that the em-
These exemptions do not apply to directors’ ployer has in the United States.
fees and similar payments received by a resi- • Their net income received for the services
dent of Ireland as a member of the board of If they have a fixed base available, they are
is not more than $5,000 during the tax
directors of a company that is a resident of the taxed only on the income attributable to the fixed
year.
United States. However, amounts received for base.
attending meetings in Ireland are not subject to Income that residents of Italy receive for per- Pay received from employment as a member
U.S. income tax. sonal services performed in the United States as of the regular complement of a ship or an aircraft
Income received by a resident of Ireland for employees (dependent personal services) is ex- operated in international traffic by a Jamaican
services performed as an employee and mem- empt from U.S. income tax if: enterprise is exempt from U.S. tax. If the ship or
ber of the regular complement of a ship or air- aircraft is operated by a U.S. enterprise, the pay
craft operated in international traffic is exempt • The residents are present in the United is subject to U.S. tax.
from U.S. income tax. States for not more than 183 days during
These exemptions do not apply to income
the tax year,
These exemptions do not apply to public that residents of Jamaica receive for performing
entertainers (such as theater, motion picture, • The income is paid by or for an employer services in the United States as entertainers,
radio, or television entertainers, musicians, and who is not a U.S. resident, and such as theater, motion picture, radio, or televi-
athletes) from Ireland who earn more than sion artists, musicians, or athletes, if the gross
$20,000 in gross receipts, including reimbursed
• The income is not borne by a permanent receipts (excluding reimbursements for ex-
establishment or fixed base that the em-
expenses, from their entertainment activities in penses) from the services are more than $400 a
the United States during the tax year. day or $5,000 for the tax year.
Directors’ fees received by residents of Ja-
Pay received by a resident of Italy from em-
maica for services performed in the United
Israel ployment regularly exercised aboard a ship or
States as members of boards of directors of U.S.
aircraft operated by an Italian enterprise in inter-
corporations are exempt from U.S. tax if the fees
Income that residents of Israel receive for per- national traffic is exempt from U.S. tax.
(excluding reimbursed expenses) are not more
forming personal services as independent con- These exemptions do not apply to directors’ than $400 per day for each day the directors are
tractors or as self-employed individuals fees and similar payments received by an Italian present in the United States to perform the serv-
(independent personal services) in the United resident as a member of the board of directors of ices.
States during the tax year is exempt from U.S. a company that is a U.S. resident.
income tax if they are in the United States for no These exemptions do not apply to income
more than 182 days during the tax year. residents of Italy receive as public entertainers Japan
Income that residents of Israel receive for (such as theater, motion picture, radio, or televi-
labor or personal services performed in the sion artists, musicians, or athletes) if they are Income that residents of Japan receive for per-
United States as employees (dependent per- present in the United States for more than 90 sonal services as independent contractors or
sonal services), including income for services days during the tax year or their gross receipts, self-employed individuals is subject to the provi-
performed by an officer of a corporation or com- including reimbursed expenses, are more than sions of Article 7 (business profits) of the treaty.
pany, is exempt from U.S. income tax if the $12,000 during the tax year for their entertain- Under that provision, business profits are ex-
residents meet four requirements. ment activities in the United States. empt from U.S. income tax unless they have a
permanent establishment in the United States. If
• They are in the United States for no more they have a permanent establishment available
than 182 days during the tax year. in the United States, they are taxed on the in-
Jamaica
• They are employees of a resident of, or a come attributable to the permanent establish-
permanent establishment in, Israel. Income that residents of Jamaica receive for the ment.
performance of personal services as indepen- Income that residents of Japan receive for
• Their income is not borne by a permanent dent contractors or self-employed individuals services performed in the United States as em-
(independent personal services) in the United ployees (dependent personal services) is ex-
United States.
States during the tax year is exempt from U.S. empt from U.S. income tax if the residents meet
• Their income is subject to Israeli tax. income tax if the residents: the following requirements.
• Are in the United States for no more than • They are in the United States for no more
89 days during the tax year, than 183 days in any 12-month period be-
by an employee for labor or personal services
ginning or ending in the tax year.
performed as a member of the regular comple- • Do not have a fixed base regularly avail-
ment of a ship or an aircraft operated in interna- able to them in the United States for per- • Their income is paid by, or on behalf of, an
tional traffic by a U.S. resident. forming their services, and employer who is not a U.S. resident.

• Their income is not borne by a permanent • Are in the United States for no more than complement of a ship or an aircraft operated in
establishment that the employer has in the 182 days during the tax year, international traffic by a U.S. enterprise.
United States.
• Earn income for those services that is not The exemptions do not apply to directors’
more than $3,000 during the tax year, and fees and similar payments received by a resi-
The exemption does not apply to directors’ dent of Latvia as a member of the board of
fees and similar payments received by a resi- • Do not maintain a fixed base in the United directors or similar body of a company that is a
dent of Japan for services performed as a mem- States for more than 182 days during the U.S. resident.
ber of the board of directors of a company that is tax year. The exemptions do not apply to income re-
a resident of the United States. sidents of Latvia receive as public entertainers
If they maintain a fixed base in the United States
The exemption does not apply to a resident for more than 182 days, they are taxed on the (such as theater, motion picture, radio, or televi-
of Japan who performs services as an employee income attributable to the fixed base. sion artists, or musicians) or sportsmen if their
aboard a ship or an aircraft operated in interna- gross receipts, including reimbursed expenses,
tional traffic by a U.S. resident. Income that residents of Korea receive for are more than $20,000 for their personal activi-
These exemptions do not apply to public labor or personal services performed in the ties in the United States during the tax year.
entertainers (such as theater, motion picture, United States as employees (dependent per- Regardless of these limits, income of Latvian
radio, or television artists, musicians, or ath- sonal services), including pay for services per- entertainers or athletes is exempt from U.S. in-
letes) from Japan who earn more than $10,000 formed as an officer of a corporation, is exempt come tax if their visit to the United States is
in gross receipts, including reimbursed ex- from U.S. tax if the residents meet four require- wholly or mainly supported by public funds of
penses, from their entertainment activities in the ments. Latvia, its political subdivisions, or local authori-
United States during the tax year. • They are in the United States for no more ties.
than 182 days during the tax year.
Kazakhstan • They are employees of a resident of Korea Lithuania

or of a permanent establishment main-
Income that residents of Kazakhstan receive for tained in Korea. Income that residents of Lithuania receive for
performing personal services as independent performing personal services as independent
• Their compensation is not borne by a per- contractors or self-employed individuals (inde-
manent establishment that the employer pendent personal services) in the United States
pendent personal services) in the United States
has in the United States. is exempt from U.S. income tax if the residents:
is exempt from U.S. income tax if:
• Their income for those services is not • Are in the United States for no more than
• The residents are in the United States for more than $3,000.
no more than 183 days in any consecutive 183 days in any 12-month period begin-
12-month period, and ning or ending in the tax year, and
Pay received by employees who are mem-
• The income is not attributable to a fixed bers of the regular complement of a ship or • Do not have a fixed base regularly avail-
base in the United States which is regu- aircraft operated by a resident of Korea in inter- able to them in the United States for per-
larly available to the residents. national traffic is exempt. forming the services.
If the residents have a fixed base available, they If they have a fixed base available, they are
are taxed only on the income attributable to the taxed only on the income attributable to the fixed
Latvia base.
fixed base.
Income that residents of Kazakhstan receive Income that residents of Latvia receive for per- Income that residents of Lithuania receive for
for employment in the United States (dependent forming personal services as independent con- services performed in the United States as em-
personal services) is exempt from U.S. income t r ac t or s o r s e l f - e m p l o y e d i n d i v i d u a l s ployees (dependent personal services) is ex-
tax if the following three requirements are met. (independent personal services) in the United empt from U.S. income tax if the following
States is exempt from U.S. income tax if the requirements are met.
• The resident is in the United States for no residents:
more than 183 days in any 12-month pe- • The resident is in the United States for no
riod. • Are in the United States for no more than more than 183 days in any 12-month pe-
183 days in any 12-month period begin- riod beginning or ending in the tax year.
employer who is not a resident of the
ning or ending in the tax year, and • The income is paid by, or on behalf of, an
United States. • Do not have a fixed base regularly avail- employer who is not a U.S. resident.
• The income is not borne by a permanent

able to them in the United States for per- • The income is not borne by a permanent
forming the services. establishment or a fixed base that the em-
If they have a fixed base available, they are ployer has in the United States.
taxed only on the income attributable to the fixed
base. The exemption does not apply to pay received
Income derived by a resident of Kazakhstan
for employment as a member of the regular
from employment as a member of the regular Income that residents of Latvia receive for complement of a ship or an aircraft operated in
complement of a ship or aircraft operated in services performed in the United States as em- international traffic by a U.S. enterprise.
international traffic is exempt from U.S. tax. ployees (dependent personal services) is ex-
These exemptions do not apply to directors’ The exemptions do not apply to directors’
empt from U.S. income tax if the following fees and similar payments received by a resi-
fees and similar payments received by a resi- requirements are met. dent of Lithuania as a member of the board of
dent of Kazakhstan as a member of the board of
directors or similar body of a company that is a • The resident is in the United States for no directors or similar body of a company that is a
more than 183 days in any 12-month pe- U.S. resident.
U.S. resident.
riod beginning or ending in the tax year. The exemptions do not apply to income re-
sidents of Lithuania receive as public entertain-
Korea, Republic of ers (such as theater, motion picture, radio, or
employer who is not a U.S. resident.
television artists, or musicians) or sportsmen if
Income that residents of the Republic of Korea • The income is not borne by a permanent their gross receipts, including reimbursed ex-
receive for performing personal services as in- establishment or a fixed base that the em- penses, are more than $20,000 for their per-
dependent contractors or self-employed individ- ployer has in the United States. sonal activities in the United States during the
uals (independent personal services) in the tax year. Regardless of these limits, income of
United States during the tax year is exempt from The exemption does not apply to pay received Lithuanian entertainers or athletes is exempt
U.S. tax if the residents: for employment as a member of the regular from U.S. income tax if their visit to the United

States is wholly or mainly supported by public • The resident is present in the United a corporation does not qualify for this exemp-
funds of Lithuania, its political subdivisions, or States for no more than 183 days in a tion.
local authorities. 12-month period. Income received by an individual for per-
forming labor or personal services as an em-
• The income is paid by, or on behalf of, an ployee aboard a ship or an aircraft operated in
Luxembourg international traffic by a Moroccan resident is
United States. exempt from U.S. income tax if the individual is a
Income that residents of Luxembourg receive for • The income is not borne by a permanent member of the regular complement of the ship or
personal services as independent contractors or establishment or fixed base that the em- aircraft.
self-employed individuals (independent per- ployer has in the United States. These exemptions do not apply to income
sonal services) in the United States is exempt received for services performed in the United
from U.S. income tax if they do not have a fixed These exemptions do not apply to director’s States by professional entertainers, including
base regularly available to them in the United fees and similar payments received by a resi- theater, film, radio, and television performers,
States for performing the services. If they have a dent of Mexico for services performed outside musicians, and athletes, unless the services are
fixed base available in the United States, they Mexico as a director or overseer of a company performed by, or for the account of, a Moroccan
are taxed on the income attributable to the fixed that is a U.S. resident. nonprofit organization.
base. These exemptions do not apply to income
Income that residents of Luxembourg re- residents of Mexico receive as public entertain-
Netherlands
ceive for services performed in the United
States as employees (dependent personal serv- television artists, or musicians) or athletes if the Income that residents of the Netherlands re-
ices) is exempt from U.S. income tax if the re- income, including reimbursed expenses, is ceive for performing personal services as inde-
sidents meet the following requirements. more than $3,000 during the tax year for their pendent contractors or self-employed
entertainment activities in the United States. individuals (independent personal services) in
• They are in the United States for no more This includes income from activities performed the United States is exempt from U.S. income
than 183 days in any 12-month period be- in the United States relating to the entertainer or tax if the income is not attributable to a fixed
ginning or ending in the tax year. athlete’s reputation, such as endorsements of base in the United States that is regularly avail-
• Their income is paid by, or on behalf of, an commercial products. Regardless of this limit, able for performing the services.
employer who is not a U.S. resident. the income of Mexican entertainers and athletes Income that residents of the Netherlands re-
is exempt from U.S. tax if their visit to the United ceive for employment in the United States (de-
• Their income is not borne by a permanent States is substantially supported by public funds pendent personal services) is exempt from U.S.
establishment or a fixed base that the em- of Mexico, its political subdivisions, or local au- income tax if the following three requirements
ployer has in the United States. thorities. are met.
The exemption does not apply to pay received • The resident is in the United States for no
for employment exercised continuously or more than 183 days during the tax year.
Morocco
predominantly aboard a ship or aircraft operated • The income is paid by, or on behalf of, an
in international traffic by a U.S. enterprise. Income that residents of Morocco receive for employer who is not a U.S. resident.
The exemptions do not apply to directors’
contractors or as self-employed persons (inde- • The income is not borne by a permanent
fees and similar payments received by a resi- establishment or fixed base the employer
dent of Luxembourg for services performed in has in the United States.
during the tax year is exempt from U.S. income
the United States as a member of the board of
directors of a company that is a resident of the Income received by a Netherlands resident for
United States. • Are in the United States for no more than employment as a member of the regular com-
The exemptions do not apply to public enter- 182 days during the tax year, plement of a ship or aircraft operated in interna-
tional traffic is exempt from U.S. tax.
tainers (such as theater, motion picture, radio, or • Do not maintain a fixed base in the United
television artists, musicians, or athletes) from These exemptions do not apply to directors’
States for more than 89 days during the
Luxembourg who earn more than $10,000 in fees and other similar payments received by a
tax year, and
resident of the Netherlands for services per-
gross receipts, including reimbursed expenses,
• Earn total income for those services that is formed outside the Netherlands as a member of
from their entertainment activities in the United
not more than $5,000. the board of directors of a company that is a
States during the tax year.
resident of the United States.
If they have a fixed base in the United States for
more than 89 days, they are taxed only on the
residents of the Netherlands receive as public
Mexico income attributable to the fixed base.
entertainers (such as theater, motion picture,
Income that residents of Mexico receive for per- Income that residents of Morocco receive for radio, or television artists, or musicians) or ath-
forming personal services as independent con- labor or personal services performed in the letes if the gross income, including reimbursed
tract ors o r se lf-em ploy ed indiv iduals United States as employees (dependent per- expenses, is more than $10,000.
(independent personal services) in the United sonal services) is exempt from U.S. income tax if
States is exempt from U.S. income tax if the the residents meet three requirements.
New Zealand
residents: • They are in the United States for less than
• Are in the United States for no more than 183 days during the tax year. Income that residents of New Zealand receive
183 days in a 12-month period, and • They are employees of a resident of Mo- for performing personal services as indepen-
rocco or of a permanent establishment of dent contractors or self-employed individuals
• Do not have a fixed base that they regu- (independent personal services) in the United
larly use for performing the services. a resident of a country other than Morocco
if the permanent establishment is located States in any tax year is exempt from U.S. in-
If they have a fixed base available, they are come tax if the residents:
in Morocco.
taxed only on income attributable to the fixed
• Their income is not borne by a permanent • Are present in the United States for no
base. more than 183 days during any consecu-
Income that residents of Mexico receive for tive 12-month period, and
United States.
employment in the United States (dependent • Do not have a fixed base regularly avail-
personal services) is exempt from U.S. tax if the Compensation received for services per- able to them in the United States for per-
following three requirements are met. formed by a member of the board of directors of forming the services.

If they have a fixed base available in the United • Their income is not borne by a permanent income is more than $100 a day or $3,000 for
States, they are taxed on the income attributable establishment that the employer has in the the tax year. Regardless of these limits, income
to the fixed base. United States. of Philippine entertainers is exempt from U.S.
Income that residents of New Zealand receive tax if their visit to the United States is substan-
The exemption does not apply to a resident of tially supported or sponsored by the Philippine
for labor or personal services performed in the Norway who performs services as an employee
United States as employees (dependent per- Government and the entertainers are certified
aboard a ship or an aircraft operated by a United
sonal services) is exempt from U.S. income tax if as qualified for this exemption by the Philippine
States resident in international traffic or in fish-
the residents meet these requirements. ing on the high seas if the resident of Norway is a competent authority.
• They are present in the United States for member of the regular complement of the ship or
no more than 183 days in any consecutive aircraft.
Poland
12-month period.
Income that residents of Poland receive for per-
• Their income is paid by or on behalf of an Pakistan forming personal services as independent con-
employer that is not a resident of the
Residents of Pakistan who perform personal t r a c t o r s o r s e l f - e m p l o y e d i n d i vi d u a l s
United States.
services (including professional services) for or (independent personal services) in the United
• Their income is not borne by a permanent on behalf of a resident of Pakistan while in the States is exempt from U.S. income tax if they are
establishment or fixed base of the em- United States for no more than 183 days during in the United States for no more than 182 days
ployer in the United States. the tax year are exempt from U.S. income tax on during the tax year.
the income from the services if they are subject
Pay received by a New Zealand resident as Income that residents of Poland receive for
to Pakistani tax.
an employee and member of the regular com- labor or personal services performed as employ-
plement of a ship or aircraft operated in interna- ees (dependent personal services), including
tional traffic is exempt from U.S. tax. Philippines services performed by an officer of a corporation
The exemption from U.S. tax on income from or company, in the United States during the tax
Income that residents of the Philippines receive year is exempt from U.S. income tax if the re-
both independent and dependent personal serv-
for performing personal services as indepen- sidents meet three requirements.
ices does not apply to public entertainers (art-
dent contractors or as self-employed individuals
ists, athletes, etc.) from New Zealand who earn
(independent personal services) in the United • They are in the United States for no more
more than $10,000 in gross receipts, including States during the tax year is exempt from U.S. than 182 days during the tax year.
reimbursed expenses, from their entertainment
activities in the United States during the tax
income tax if the residents: • Their income is paid by or on behalf of an
year. • Are in the United States for no more than employer who is not a U.S. resident.
89 days during the tax year, • Their income is not borne by a permanent
• Earn gross income for those services that establishment that the employer has in the
Norway is not more than $10,000 for the tax year if United States.
the income is from U.S. contractors, and
Income that residents of Norway receive for per-
forming personal services as independent con- • Do not have a fixed base regularly avail-
able to them in the United States for per- bers of the regular complement of a ship or
tract ors o r se lf-em ploy ed indiv iduals
(independent personal services) in the United forming their services. aircraft operated by a resident of Poland in inter-
States during the tax year is exempt from U.S. national traffic is exempt from U.S. tax.
If they have a fixed base available in the United
income tax if the residents: States, they are taxed only on the income attrib-
• Are present in the United States for no utable to the fixed base. There is no dollar limit Portugal
more than 182 days during the tax year, for condition (2) if the contractor is a resident of a
and country other than the United States. Income that residents of Portugal receive for
• Do not maintain a fixed base in the United Income that residents of the Philippines re-
States for more than 182 days during the ceive for personal services performed in the
United States as employees (dependent per- pendent personal services) in the United States
tax year.
sonal services) is exempt from U.S. income tax if is exempt from U.S. income tax if the residents:
If they do not meet requirement (2), they are the residents meet three requirements. • Are in the United States for no more than
taxed only on the income attributable to the fixed
base. • They are in the United States for no more 182 days in any 12-month period, and
than 89 days during the tax year. • Do not have a fixed base regularly avail-
This exemption does not apply to residents of
Norway who are public entertainers (theater,
• They are employees of a resident of the able to them in the United States for per-
Philippines or of a permanent establish- forming the activities.
motion picture, or television artists, musicians,
ment maintained in the Philippines.
or athletes) if they are in the United States for If they have a fixed base available, they are
more than 90 days during the tax year or their • Their income is not borne by a permanent taxed only on the income attributable to the fixed
pay for services as public entertainers is more establishment that the employer has in the base.
than $10,000 during the tax year. United States.
Income that residents of Portugal receive for
Income that residents of Norway receive for employment in the United States (dependent
labor or personal services performed in the Pay received by an employee of a resident of
the Philippines for personal services performed personal services) is exempt from U.S. income
United States as employees (dependent per-
as a member of the regular complement of a tax if the following three requirements are met.
sonal services) is exempt from U.S. income tax if
the residents meet three requirements.
ship or an aircraft operated in international traffic • The resident is in the United States for no
by a resident of the Philippines is exempt from more than 183 days in any 12-month pe-
• They are in the United States less than U.S. tax.
riod.
183 days during the tax year.
These exemptions do not apply to income • The income is paid by, or on behalf of, an
• They are employees of a resident of Nor- residents of the Philippines receive for perform- employer who is not a U.S. resident.
way or of a permanent establishment of a ing services (both independent and dependent
resident of a state other than Norway if the personal services) in the United States as enter- • The income is not borne by a permanent
permanent establishment is situated in tainers, such as theater, motion picture, radio, or establishment or fixed base that the em-
Norway. television artists, musicians, or athletes, if the ployer has in the United States.

Income received by a resident of Portugal for Russia If they have a fixed base available, they are
employment as a member of the regular com- taxed only on income attributable to the fixed
plement of a ship or aircraft operated in interna- Income that residents of Russia receive for per- base.
tional traffic is exempt from U.S. tax. forming personal services as independent con-
t r ac t or s o r s e l f - e m p l o y e d i n d i v i d u a l s Income that residents of the Slovak Republic
(independent personal services) in the United receive for employment in the United States
residents of Portugal receive as public entertain-
States is exempt from U.S. income tax if: (dependent personal services) is exempt from
U.S. income tax if the following three require-
television artists, or musicians) or athletes if that • The residents are in the United States for ments are met.
income, including reimbursed expenses, is no more than 183 days during the calen-
more than $10,000. The income of Portuguese
dar year, or
• The resident is present in the United
entertainers and athletes is exempt from U.S. States for no more than 183 days in any
tax if their visit to the United States is substan- • The income is not attributable to a fixed 12-month period.
tially supported by public funds of Portugal or its base in the United States which is regu-
larly available to the residents.
political or administrative subdivisions.
These exemptions do not apply to directors’
If the residents have a fixed base available, they
fees and similar payments received by a resi-
are taxed only on the income attributable to the
dent of Portugal for services performed outside establishment or a fixed base that the em-
fixed base.
of Portugal as a member of the board of direc- ployer has in the United States.
tors of a company that is a resident of the United Income that residents of Russia receive for
States. employment in the United States (dependent These exemptions do not apply to income
personal services) is exempt from U.S. income residents of the Slovak Republic receive as pub-
tax if the following three requirements are met. lic entertainers (such as theater, motion picture,
Romania radio, or television artists, or musicians) or
• The resident is in the United States for no sportsmen if their gross receipts, including reim-
Income that residents of Romania receive for more than 183 days during the calendar bursed expenses, are more than $20,000 during
performing personal services as independent year. the tax year. Regardless of these limits, income
contractors or self-employed individuals (inde- • The income is paid by, or on behalf of, an of Slovak entertainers and sportsmen is exempt
pendent personal services) in the United States employer who is not a resident of the from U.S. income tax if their visit to the United
during the tax year is exempt from U.S. income States is substantially supported by public funds
United States.
tax if the residents: of the Slovak Republic, its political subdivisions,
• Are present in the United States for no establishment or a fixed base that the em-
or local authorities, or the visit is made pursuant
more than 182 days during the tax year, to a specific arrangement between the United
ployer has in the United States. States and the Slovak Republic.
and
However, income from employment directly These exemptions do not apply to directors’
• Do not maintain a permanent establish- connected with a place of business that is not a fees and similar payments received by a resi-
ment in the United States with which the dent of the Slovak Republic for services per-
permanent establishment is exempt if the resi-
income is effectively connected. formed in the United States as a member of the
dent is present in the United States not longer
than 12 consecutive months. For this purpose, a board of directors of a company that is a resident
Income that residents of Romania receive for of the United States.
labor or personal services performed as employ- place of business means a construction site,
assembly or installation project, or drilling opera- Income from employment as a member of
ees (dependent personal services), including the regular complement of a ship or aircraft
services performed by an officer of a corporation tion.
operated by a Slovak enterprise in international
or company, in the United States during the tax Income derived by a resident of Russia from traffic is exempt from U.S. income tax. If the ship
year is exempt from U.S. income tax if the re- employment as a member of the regular com- or aircraft is operated by a U.S. enterprise, the
sidents meet these requirements. plement of a ship or aircraft operated in interna- income is subject to U.S. income tax.
• They are in the United States for no more tional traffic is exempt from U.S. tax.
than 182 days during the tax year. Income from technical services directly con-
nected with the application of a right or property Slovenia
• They are employees of a resident of giving rise to a royalty is exempt if those services
Romania or of a permanent establishment Income that residents of Slovenia receive for
are provided as part of a contract granting the
maintained in Romania by a resident of personal services as independent contractors or
use of the right or property.
the United States. self-employed individuals (independent per-
These exemptions do not apply to directors’ sonal services) in the United States is exempt
• Their income is not borne by a permanent fees and similar payments received by a resi- from U.S. income tax if they do not have a fixed
establishment that the employer has in the dent of Russia as a member of the board of base regularly available to them in the United
United States. directors or similar body of a company that is a States for performing the services. If they have a
resident of the United States. fixed base available in the United States, they
These exemptions do not apply to entertain-
are taxed on the income attributable to the fixed
ers, such as theater, motion picture, radio, or
base.
television artists, musicians, or athletes, who are Slovak Republic Income that residents of Slovenia receive for
present in the United States for more than 90
Income that residents of the Slovak Republic services performed in the United States as em-
days during the tax year (90 days or more if the
receive for performing personal services as in- ployees (dependent personal services) is ex-
entertainers are employees) or who earn gross
dependent contractors or self-employed individ- empt from U.S. income tax if the residents meet
income as entertainers in the United States of
uals (independent personal services) in the the following requirements.
more than $3,000 during the tax year ($3,000 or
more if they are employees). However, the ex- United States is exempt from U.S. income tax if • They are in the United States for no more
emptions do apply, without regard to the 90 day, the residents: than 183 days in any 12-month period be-
$3,000 requirement, if the entertainers are pres- ginning or ending in the tax year.
• Are present in the United States for no
ent in the United States by specific arrange-
ments between the United States and Romania.
more than 183 days in any 12-month pe- • Their income is paid by, or on behalf of, an
riod, and employer who is not a U.S. resident.
bers of the regular complement of a ship or • Do not have a fixed base regularly avail- • Their income is not borne by a permanent
aircraft operated by a resident of Romania in able to them in the United States for per- establishment or a fixed base that the em-
international traffic is exempt from U.S. tax. forming the activities. ployer has in the United States.

These exemptions do not apply to directors’ funds of South Africa, its political subdivisions, • They are in the United States for no more
fees and similar payments received by a resi- or local authorities. than 183 days in any 12-month period.
dent of Slovenia for services performed in the Income received by a resident of South Af- • Their income is paid by, or on behalf of, an
United States as a member of the board of rica for services performed as an employee and employer who is not a U.S. resident.
directors of a company that is a resident of the member of the complement of a ship or aircraft
United States. operated in international traffic is exempt from • Their income is not borne by a permanent
Income received by a Slovenian resident for U.S. income tax. establishment or a fixed base that the em-
employment as a member of the regular com- ployer has in the United States.
plement of a ship or aircraft operated in interna-
Spain Income received from employment as a mem-
tional traffic is exempt from U.S. tax.
ber of the regular complement of a ship or an
These exemptions do not apply to income aircraft operated in international traffic by a Sri
Income that residents of Spain receive as inde-
residents of Slovenia receive as public enter- pendent contractors or self-employed individu- Lanka enterprise is exempt from U.S. tax. If the
tainers (such as theater, motion picture, radio, or als (independent personal services) in the ship or aircraft is operated by a U.S. enterprise,
television artists, or musicians) or athletes if United States is exempt from U.S. income tax if the income is subject to U.S. tax.
their gross receipts, including reimbursed ex- the residents do not have a fixed base available These exemptions do not apply to public
penses, are more than $15,000 during the tax to them in the United States for performing the entertainers (such as theater, motion picture,
year. Regardless of these limits, income of Slo- services. If they have a fixed base, they are radio, or television entertainers, musicians, and
venian entertainers or athletes is exempt from taxed only on the income attributable to the fixed athletes) from Sri Lanka who earn more than
U.S. tax if their visit to the United States is wholly base. $6,000 in gross receipts, including reimbursed
or mainly paid by public funds of either the expenses, from their entertainment activities in
Income that residents of Spain receive for
United States or Slovenia or their political subdi- the United States during the tax year. Regard-
personal services performed in the United
visions, or local authorities. States as employees (dependent personal serv- less of these limits, income of Sri Lanka enter-
ices) is exempt from U.S. income tax if: tainers is exempt from U.S. income tax if their
visit to the United States is directly or indirectly
South Africa • The residents are present in the United supported wholly or substantially by public funds
States no more than 183 days in any of Sri Lanka or the United States, their political
Income that residents of South Africa receive for 12-month period, subdivisions, or local authorities.
contractors or self-employed individuals (inde- • The income is paid by, or on behalf of, an These exemptions do not apply to directors’
employer who is not a U.S. resident, and fees and other compensation received by a resi-
is exempt from U.S. income tax if the residents: • The income is not borne by a permanent dent of Sri Lanka for services performed in the
establishment or fixed base the employer United States as a member of the board of
• Are in the United States for no more than directors of a company resident in the United
has in the United States.
183 days in any 12-month period begin- States.
ning or ending in the tax year, and
• Do not have a fixed base regularly avail- by employees who are members of a regular
able to them in the United States for per- complement of a ship or aircraft operated in Sweden
forming the services. international traffic by a U.S. enterprise. Income that residents of Sweden receive for
If they have a fixed base available, they are These exemptions do not apply to public performing personal services as independent
taxed only on income attributable to the fixed entertainers (such as theater, motion picture, contractors or self-employed individuals (inde-
base. radio, or television artists, or musicians) or ath- pendent personal services) in the United States
letes from Spain who earn more than $10,000 in during the tax year is exempt from U.S. income
Income that residents of South Africa receive income, including reimbursed expenses, from tax if they do not have a fixed base regularly
for services performed in the United States as their entertainment activities in the United States available to them in the United States for per-
employees (dependent personal services) is ex- during the tax year. Regardless of these limits, forming the services. If they have a fixed base
empt from U.S. income tax if the following re- Spanish entertainers and athletes are exempt available in the United States, they are taxed on
quirements are met. from U.S. tax if their visit to the United States is the income attributable to the fixed base.
• The resident is in the United States for no substantially supported by public funds of Spain, Income that residents of Sweden receive for
a political subdivision, or local authority. labor or personal services performed in the
more than 183 days in any 12-month pe-
riod beginning or ending in the tax year. United States as employees (dependent per-
sonal services) is exempt from U.S. income tax if
• The income is paid by, or on behalf of, an Sri Lanka the residents meet three requirements.
Income that residents of Sri Lanka receive for • They are in the United States for no more
• The income is not borne by a permanent performing personal services as independent than 183 days during any consecutive
establishment or a fixed base that the em- contractors or self-employed individuals (inde- 12-month period.
ployer has in the United States. pendent personal services) in the United States
during the tax year is exempt from U.S. income
• Their income is paid by, or on behalf of, an
These exemptions do not apply to directors’ employer who is not a resident of the
fees and similar payments received by a resi- United States.
• Are in the United States for no more than
dent of South Africa for services performed in
183 days in any 12-month period, or
• Their income is not borne by a permanent
the United States as a member of the board of establishment or a fixed base that the em-
directors of a company resident in the United • Do not have a fixed base regularly avail- ployer has in the United States.
States. able to them in the United States for the
These exemptions do not apply to income purpose of performing the services. Income received by a resident of Sweden for
residents of South Africa receive as public enter- employment as a member of the regular com-
tainers (such as theater, motion picture, radio, or If they have a fixed base available in the plement of a ship or aircraft operated in interna-
television artists, or musicians) or athletes if United States, they are taxed on the income tional traffic is exempt from U.S. tax.
their gross receipts, including reimbursed ex- attributable to the fixed base. These exemptions do not apply to income
penses, are more than $7,500 during the tax Income that residents of Sri Lanka receive residents of Sweden receive as public entertain-
year. Regardless of these limits, income of for services performed in the United States as ers (such as theater, motion picture, radio, or
South African entertainers or athletes is exempt employees (dependent personal services) is ex- television artists, or musicians) or athletes if the
from U.S. income tax if their visit to the United empt from U.S. income tax if the residents meet gross income, including reimbursed expenses,
States is wholly or mainly supported by public the following requirements. is more than $6,000 for any 12-month period.

These exemptions do not apply to directors’ by a U.S. resident or borne by a permanent Tunisia
fees received by a resident of Sweden for serv- establishment or fixed base in the United States.
ices performed outside of Sweden as a member Income that residents of Tunisia receive for per-
Income that residents of Thailand receive for
of the board of directors of a company that is a forming personal services as independent con-
services performed in the United States as em- t r a c t o r s o r s e l f - e m p l o y e d i n d i vi d u a l s
resident of the United States.
ployees (dependent personal services) is ex- (independent personal services) in the United
empt from U.S. income tax if the following States are exempt from U.S. income tax if:
Switzerland requirements are met.
• The resident is in the United States for no than 183 days during the tax year,
Income that residents of Switzerland receive for
more than 183 days in any 12-month pe-
personal services as independent contractors or
riod beginning or ending in the tax year. • They do not have a fixed base regularly
self-employed individuals (independent per- available in the United States for perform-
sonal services) that they perform during the tax • The income is paid by, or on behalf of, an ing the services, and
year in the United States is exempt from U.S. employer who is not a U.S. resident.
income tax if they do not have a fixed base • The gross income for the tax year from
regularly available to them in the United States • The income is not borne by a permanent U.S. residents for services performed in
for performing the services. If they have a fixed establishment or a fixed base that the em- the United States is no more than $7,500.
base available in the United States, they are ployer has in the United States.
taxed on the income attributable to the fixed If they do not meet condition (2), they are
base. These exemptions do not apply to directors’ taxed on the income that is attributable to the
Income that residents of Switzerland receive fees and similar payments received by a resi- fixed base.
for services performed in the United States as dent of Thailand for services performed outside Income that residents of Tunisia receive for
employees (dependent personal services) is ex- of Thailand as a member of the board of direc- personal services performed in the United
empt from U.S. income tax if the residents meet tors of a company that is a resident of the United States as employees (dependent personal serv-
the following requirements. States. ices) is exempt from U.S. income tax if:
• They are in the United States for no more These exemptions do not apply to income • The residents are in the U.S. for no more
than 183 days in any 12-month period be- residents of Thailand receive for performing than 183 days during the tax year,
ginning or ending in the tax year. services in the United States as entertainers
• Their income is paid by, or on behalf of, an
• Their income is paid by, or on behalf of, an (such as theater, motion picture, radio, or televi-
employer who is not a U.S. resident. sion artists, or musicians) and athletes, if the United States, and
income is more than $100 a day or $3,000 for
• Their income is not borne by a permanent the tax year. Regardless of these limits, income • Their income is not borne by a permanent
establishment or a fixed base that the em- establishment or fixed base the employer
of Thai entertainers is exempt from U.S. tax if
ployer has in the United States. has in the United States.
their visit to the United States is substantially
These exemptions do not apply to directors’ supported by public funds of Thailand or its
fees and similar payments received by a resi- political subdivisions or local authorities.
bers of the regular complement of a ship or
dent of Switzerland as a member of the board of The exemption does not apply to pay re- aircraft operated by an enterprise in interna-
directors of a company that is a resident of the ceived by employees who are members of the tional traffic is exempt from U.S. tax if the place
United States. regular complement of a ship or aircraft oper- of management of the enterprise is in Tunisia.
These exemptions do not apply to public ated in international traffic by a U.S. enterprise. However, if the enterprise is created under the
entertainers (such as theater, motion picture, laws of the United States (or a U.S. state), the
radio, or television entertainers, musicians, and pay is subject to U.S. tax.
athletes) from Switzerland who earn more than Trinidad and Tobago These exemptions do not apply to income
$10,000 in gross receipts, including reimbursed
residents of Tunisia receive as public entertain-
expenses, from their entertainment activities in Income (including reimbursed travel expenses)
the United States during the tax year. that residents of Trinidad and Tobago receive
television artists, and musicians) or athletes if
Income received by a resident of Switzerland during the tax year for personal services per-
their gross receipts, including reimbursed ex-
for services performed as an employee and formed in the United States is exempt from U.S. penses, are more than $7,500 during the tax
member of the regular complement of a ship or income tax if the individuals are in the United year.
aircraft operated in international traffic is exempt States for no more than 183 days during the tax
from U.S. income tax. These exemptions do not apply to fees re-
year and either: ceived by a resident of Tunisia for services per-
• The residents are employees of a resident formed as a director of a U.S. corporation if the
Thailand of a country other than the United States fees are treated as a distribution of profits and
or are employees of a permanent estab- cannot be taken as a deduction by the corpora-
Income that residents of Thailand receive for lishment of a U.S. resident outside the tion.
performing personal services as independent United States and the income is not de-
contractors or as self-employed individuals (in-
ducted in figuring the profits of a perma-
dependent personal services) in the United
nent establishment in the United States, or
Turkey
States during the tax year is exempt from U.S.
income tax if the residents: • The income is not more than $3,000 (ex- Income that residents of Turkey receive for per-
cluding reimbursed travel expenses). forming personal services as independent con-
• Are in the United States for no more than t r a c t o r s o r s e l f - e m p l o y e d i n d i vi d u a l s
89 days during the tax year, and (independent personal services) in the United
These exemptions do not apply to the profes-
• Do not have a fixed base regularly avail- sional earnings of public entertainers such as States is exempt from U.S. income tax if the
able to them in the United States for per- actors, musicians, and professional athletes or residents:
forming their services. to any person providing their services if the pay • Are in the United States for purposes of
If they have a fixed base available in the United is more than $100 per day (excluding reim- performing the services or activities for no
States, they are taxed only on the income attrib- bursed travel expenses). more than 183 days in any 12-month pe-
utable to the fixed base. Pay received by members of the regular riod, and
This exemption does not apply if a resident of complement of a ship or aircraft operated in • Do not have a fixed base regularly avail-
Thailand earns more than $10,000 for indepen- international traffic by a resident of Trinidad and able to them in the United States for per-
dent personal services and that income is paid Tobago is exempt from U.S. tax. forming the services.

If they have a fixed base available, they are of a company that is a resident of the United States for performing the services. If they have a
taxed only on income attributable to the fixed States. fixed base available, they are taxed on the in-
base. These exemptions generally do not apply to come attributable to the fixed base.
income received as a public entertainer (such as Income that residents of Venezuela receive
Income that residents of Turkey receive for
a theater, motion picture, radio, or television for services performed in the United States as
services performed in the United States as em-
artist, musician, or athlete). However, income of employees (dependent personal services) is ex-
ployees (dependent personal services) is ex- Ukrainian entertainers and sportsmen is exempt empt from U.S. income tax if the residents meet
empt from U.S. income tax if the following from U.S. income tax if their visit to the United the following requirements.
requirements are met. States is substantially supported by public funds
• The resident is in the United States for no of Ukraine, its political subdivisions, or local au-
than 183 days in any 12-month period be-
more than 183 days in any 12-month pe- thorities, or the visit is made pursuant to a spe-
ginning or ending in the tax year.
riod. cific arrangement between the United States
and Ukraine. • Their income is paid by, or on behalf of, an
• The income is paid by, or on behalf of, an Income derived by a resident of Ukraine from employer who is not a U.S. resident.
employer who is not a U.S. resident. employment as a member of the regular com-
• The income is not borne by a permanent plement of a ship or aircraft operated in interna-
establishment or a fixed base that the em- tional traffic is exempt from U.S. tax.
These exemptions do not apply to directors’
This exemption does not apply to a resident of United Kingdom fees and similar payments received by a resi-
Turkey who performs services as a member of dent of Venezuela for services performed in the
Income that residents of the United Kingdom
the regular complement of a ship or an aircraft receive for personal services as independent United States as a member of the board of
operated by a U.S. resident in international traf- contractors or self-employed individuals are directors of a company resident in the United
fic. subject to the provisions of Article 7 (Business States.
These exemptions do not apply to directors’ Profits) of the treaty. Under that provision, busi- Pay received by a resident of Venezuela for
fees and similar payments received by a resi- ness profits are exempt from U.S. income tax services performed as an employee of a ship or
dent of Turkey for services provided in the unless they have a permanent establishment in an aircraft operated in international traffic is ex-
United States as a member of the board of the United States. If they have a permanent empt from U.S. income tax.
directors of a company that is a resident of the establishment available in the United States, These exemptions do not apply to income
United States. they are taxed on the income attributable to the residents of Venezuela receive as public enter-
These exemptions do not apply to income permanent establishment. tainers (such as theater, motion picture, radio, or
residents of Turkey receive as public entertain- Income that residents of the United Kingdom television artists, or musicians) or sportsmen if
ers (such as theater, motion picture, radio, or receive for services performed in the United their gross income, including reimbursed ex-
television artists, or musicians) or athletes if States as employees (dependent personal serv- penses, is more than $6,000 for their personal
their gross receipts are more than $3,000 during ices) is exempt from U.S. income tax if the re- activities in the United States during the tax
sidents meet the following requirements. year. Regardless of these limits, income of Ven-
the tax year for their entertainment activities in
ezuelan entertainers or athletes is exempt from
the United States. If their visit to the United • They are in the United States for no more U.S. income tax if their visit to the United States
States is substantially supported by a Turkish than 183 days in any 12-month period be- is wholly or mainly supported by public funds of
non-profit organization or from the public funds ginning or ending in the tax year. Venezuela, its political subdivisions, or local au-
of Turkey, its political subdivisions, or local au-
thorities, the income is taxed as independent
• Their income is paid by, or on behalf of, an thorities.
personal services or dependent personal serv-
ices. • Their income is not borne by a permanent Professors, Teachers,
establishment that the employer has in the and Researchers
United States.
Ukraine Pay of professors and teachers who are re-
These exemptions do not apply to directors’ sidents of the following countries is generally
Income that residents of Ukraine receive for fees and similar payments received by a resi- exempt from U.S. income tax for 2 or 3 years if
performing personal services as independent dent of the United Kingdom for services per- they temporarily visit the United States to teach
contractors or self-employed individuals (inde- formed in the United States as a member of the or do research. The exemption applies to pay
pendent personal services) in the United States board of directors of a company resident in the earned by the visiting professor or teacher dur-
is exempt from U.S. income tax if the income is United States. ing the applicable period. For most of the follow-
not attributable to a fixed base in the United These exemptions do not apply to public ing countries, the applicable period begins on
States that is regularly available for performing entertainers (such as theater, motion picture, the date of arrival in the United States for the
the services. radio, or television artists, musicians, or ath- purpose of teaching or engaging in research.
Income that residents of Ukraine receive for letes) from the United Kingdom who earn more Furthermore, for most of the following countries,
employment in the United States (dependent than $20,000 in gross receipts, including reim- the exemption applies even if the stay in the
personal services) is exempt from U.S. income bursed expenses, from their entertainment ac- United States extends beyond the applicable
tivities in the United States during the tax year. period.
tax if the following three requirements are met.
Income received by a resident of the United The exemption generally applies to pay re-
• The resident is in the United States for no Kingdom for services performed as an em- ceived during a second teaching assignment if
more than 183 days during the tax year. both are completed within the specified time,
ployee and member of the regular complement
• The income is paid by, or on behalf of, an of a ship or aircraft operated in international even if the second assignment was not arranged
employer who is not a resident of the traffic is exempt from U.S. income tax. until after arrival in the United States on the first
assignment. For each of the countries listed, the
United States.
conditions are stated under which the pay of a
• The income is not borne by a permanent Venezuela professor or teacher from that country is exempt
establishment or a fixed base that the em- from U.S. income tax.
ployer has in the United States. Income that residents of Venezuela receive for If you do not meet the requirements for ex-
personal services as independent contractors or emption as a teacher or if you are a resident of a
These exemptions do not apply to directors’ self-employed individuals (independent per- treaty country that does not have a special provi-
fees and similar payments received by a resi- sonal services) in the United States is exempt sion for teachers, you may qualify under a per-
dent of Ukraine for services performed outside from U.S. income tax if they do not have a fixed sonal services income provision discussed
of Ukraine as a member of the board of directors base regularly available to them in the United earlier.

Bangladesh Commonwealth of This exemption does not apply to income

Independent States (C.I.S.) from research carried on mainly for the private
An individual is exempt from U.S. income tax on benefit of any person rather than in the public
income from teaching or research for not more An individual who is a resident of a C.I.S. mem- interest.
than 2 years from the date of arrival for such ber on the date of arrival in the United States
purposes if he or she: and who is temporarily in the United States at
the invitation of the U.S. Government or an edu- France
• Is a resident of Bangladesh immediately cational or scientific research institution in the
before visiting the United States, and United States primarily to teach, engage in re- An individual who is a resident of France on the
• Is in the United States to teach or engage search, or participate in scientific, technical, or date of arrival in the United States and who is
in research at a university, college, or professional conferences is exempt from U.S. temporarily in the United States at the invitation
other recognized educational institution. income tax on income for teaching, research, or of the U.S. Government, a university, or other
participation in these conferences for a maxi- recognized educational or research institution in
This exemption does not apply to income from mum period of 2 years. the United States primarily to teach or engage in
research carried on mainly for the private benefit This exemption does not apply to income research, or both, at a university or other educa-
of any person rather than in the public interest. from research carried on mainly for the benefit of tional or research institution is exempt from U.S.
a private person, including a commercial enter- income tax on income from teaching or research
prise of the United States or a foreign trade for a maximum of 2 years from the date of arrival
Belgium organization of a C.I.S. member. in the United States.
The exemption does, however, apply if the An individual may claim this benefit only
research is conducted through an intergovern-
once. Also, this benefit and the benefits de-
Note. See the effective dates of the new mental agreement on cooperation.
scribed later under Students and Apprentices
treaty under What’s New at the beginning of this This exemption also applies to journalists
can be claimed for no more than 5 years.
publication. and correspondents who are temporarily in the
United States for periods not longer than 2 years This exemption does not apply to income
and who receive their compensation from from research carried on mainly for the private
New treaty. An individual who is a resident of benefit of any person rather than in the public
abroad. It is not necessary that the journalists or
Belgium at the beginning of the visit to the correspondents be invited by the U.S. Govern- interest.
United States and who is temporarily in the ment or other appropriate institution, nor does it
United States to teach or carry on research at a matter that they are employed by a private per-
school, college, university or other educational son, including commercial enterprises and for- Germany
or research institution is exempt from U.S. in- eign trade organizations.
come tax for a period not exceeding 2 years
Note. See the effective dates of the protocol
from the date of arrival in the United States on
under What’s New at the beginning of this publi-
income received for teaching or carrying on re- Czech Republic
cation.
search.
An individual is exempt from U.S. income tax on
This exemption does not apply to income income for teaching or research for up to 2 years
from research carried on mainly for the private Treaty as modified. A professor or teacher
if he or she: who is a resident of Germany and who is tempo-
benefit of any person rather than in the public
interest. • Is a resident of the Czech Republic imme- rarily in the United States to engage in advanced
diately before visiting the United States, study or research or teaching at an accredited
and educational institution or institution engaged in
Former treaty. An individual who is a resident research for the public benefit is exempt from
• Is in the United States primarily to teach or
of Belgium on the date of arrival in the United U.S. tax on income received for such study,
conduct research at a university, college,
States and who is temporarily in the United research, or teaching for a maximum of 2 years
school, or other accredited educational or
States at the invitation of the U.S. Government, from the date of arrival in the United States.
research institution.
a university, or other recognized educational The exemption does not apply to income
institution in the United States primarily to teach A Czech resident is entitled to these benefits from research carried on mainly for the private
or engage in research, or both, at a university or only once. However, the exemption does not benefit of any person rather than in the public
other accredited educational institution is ex- apply if: interest. The exemption does not apply if, during
empt from U.S. income tax on income for the the preceding period, the benefit described in
• The resident claimed during the immediate
teaching or research for a maximum of 2 years paragraph (2), (3), or (4) of Article 20 of the
preceding period the benefits described
from the date of arrival in the United States. treaty, pertaining to students, was claimed.
later under Students and Apprentices, or
This exemption does not apply to income
from research carried on mainly for the private
• The income is from research undertaken
Unmodified treaty. A professor or teacher
primarily for the private benefit of a spe-
benefit of any person rather than in the public who is a resident of Germany and who is in the
cific person or persons.
interest. United States for not more than 2 years to en-
gage in advanced study or research or teaching
Egypt at an accredited educational institution or institu-
China, People’s Republic of tion engaged in research for the public benefit is
An individual who is a resident of Egypt on the exempt from U.S. tax on income received for
An individual who is a resident of the People’s date of arrival in the United States and who is such study, research, or teaching. If the individ-
Republic of China and who is temporarily in the temporarily in the United States primarily to
ual’s visit to the United States exceeds 2 years,
United States primarily to teach, lecture, or con- teach or engage in research, or both, at a univer-
the exemption is lost for the entire visit unless
duct research at a university or other accredited sity or other recognized educational institution is
the competent authorities of Germany and the
educational institution or scientific research in- exempt from U.S. income tax on income from
United States agree otherwise.
stitution is exempt from U.S. income tax on in- the teaching or research for a maximum of 2
years from the date of arrival in the United The exemption does not apply to income
come for the teaching, lecturing, or research for
States. The individual must have been invited to from research carried on mainly for the private
a total of not more than 3 years. benefit of any person rather than in the public
the United States for a period not expected to be
This exemption does not apply to income longer than 2 years by the U.S. Government or a interest. The exemption does not apply if, during
from research carried on mainly for the private state or local government, or by a university or the preceding period, the benefit described in
benefit of any person rather than in the public other recognized educational institution in the paragraph (2), (3), or (4) of Article 20 of the
interest. United States. treaty, pertaining to students, was claimed.

Greece Indonesia This exemption does not apply to income

A professor or teacher who is a resident of An individual is exempt from U.S. tax on income benefit of any person rather than in the public
Greece and who is temporarily in the United for teaching or research for a maximum of 2 interest.
States to teach at a university, college, or other years from the date of arrival in the United
educational institution for a maximum of 3 years States if he or she:
is exempt from U.S. income tax on the income • Is a resident of Indonesia immediately Japan
received for teaching during that period. before visiting the United States, and An individual who is a resident of Japan and who
• Is in the United States at the invitation of a is temporarily in the United States primarily to
university, school, or other recognized ed- teach or engage in research at a university,
Hungary college, or other recognized educational institu-
ucational institution to teach or engage in
An individual who is a resident of Hungary on the research, or both, at that educational insti- tion is exempt from U.S. income tax on income
date of arrival in the United States and who is tution. for the teaching or research for a maximum of 2
years from the date of arrival in the United
temporarily in the United States primarily to
A resident of Indonesia is entitled to this ex- States.
teach or engage in research, or both, at a univer-
emption only once. But this exemption does not The exemption does not apply to income
sity or other recognized educational institution is from research carried on mainly for the private
apply to income from research carried on mainly
exempt from U.S. income tax on income for the benefit of any person rather than in the public
for the private benefit of any person.
teaching or research for a maximum of 2 years interest.
from the date of arrival in the United States. The
individual must have been invited to the United Israel Former treaty. An individual entitled to the
States for a period not expected to be longer teacher and researcher benefits under the for-
than 2 years by the U.S. Government or a state An individual who is a resident of Israel on the mer treaty may continue to claim those benefits
or local government, or by a university or other date of arrival in the United States and who is for as long as the individual would have been
recognized educational institution in the United temporarily in the United States primarily to entitled to them under the treaty.
teach or engage in research, or both, at a univer-
States.
sity or other recognized educational institution is
The exemption does not apply to income exempt from U.S. income tax on income from Korea, Republic of
from research carried on mainly for the private the teaching or research for a maximum of 2
benefit of any person rather than in the public years from the date of arrival in the United An individual who is a resident of the Republic of
interest. States. The individual must have been invited to Korea on the date of arrival in the United States
the United States for a period not expected to be and who is temporarily in the United States pri-
longer than 2 years by the U.S. Government or a marily to teach or engage in research, or both, at
Iceland state or local government, or by a university or a university or other recognized educational in-
other recognized educational institution in the stitution is exempt from U.S. income tax on in-
An individual who is a resident of Iceland on the come for the teaching or research for a
United States.
date of arrival in the United States and who is maximum of 2 years from the date of arrival in
temporarily in the United States at the invitation the United States. The individual must have
of the U.S. Government, a university, or other been invited to the United States for a period not
recognized educational institution in the United expected to be longer than 2 years by the U.S.
interest. The exemption does not apply if, during
States primarily to teach or engage in research, Government or a state or local government, or
the immediately preceding period, the benefits by a university or other recognized educational
or both, at a university or other educational insti- described in Article 24(1) of the treaty, pertain- institution in the United States.
tution is exempt from U.S. income tax on income ing to students, were claimed. The exemption does not apply to income
for the teaching or research for a maximum of 2 from research carried on mainly for the private
years from the date of arrival in the United benefit of any person rather than in the public
States. Italy interest.
This exemption does not apply to income A professor or teacher who is a resident of Italy
from research carried on mainly for the private on the date of arrival in the United States and
benefit of any person rather than in the public who temporarily visits the United States to teach Luxembourg
interest. or conduct research at a university, college, A resident of Luxembourg who is temporarily in
school, or other educational institution, or at a the United States at the invitation of a U.S.
medical facility primarily funded from govern- university, college, school, or other recognized
India ment sources, is exempt from U.S. income tax educational institution only to teach or engage in
for up to 2 years on pay from this teaching or research, or both, at that educational institution
An individual is exempt from U.S. tax on income research. is exempt from U.S. income tax on income for
received for teaching or research if he or she: This exemption does not apply to income the teaching or research for not more than 2
• Is a resident of India immediately before from research carried on mainly for the private years from the date of arrival in the United
visiting the United States, and benefit of any person rather than in the public States.
interest. If the individual’s visit to the United States is
• Is in the United States to teach or engage longer than 2 years, the exemption is lost for the
in research at an accredited university or entire visit unless the competent authorities of
other recognized educational institution in Jamaica Luxembourg and the United States agree other-
the United States for a period not longer wise.
than 2 years. An individual who is a resident of Jamaica on the This exemption does not apply to pay for
date of arrival in the United States and who research carried on for the benefit of any person
If the individual’s visit to the United States temporarily visits the United States to teach or other than the educational institution that ex-
exceeds 2 years, the exemption is lost for the engage in research at a university, college, or tended the invitation.
other recognized educational institution is ex-
entire visit.
empt from U.S. income tax on the income re-
This exemption does not apply to income ceived for the teaching or research for not more Netherlands
from research carried on mainly for the private than 2 years from the date of arrival in the United
benefit of any person rather than in the public States. A resident of Jamaica is entitled to this An individual is exempt from U.S. income tax on
interest. exemption only once. income received for teaching or research for a

maximum of 2 years from the date of arrival if he described in Article 22(1) of the treaty, pertain- • Is in the United States primarily to teach or
or she: ing to students, were claimed. conduct research at a university, college,
school, or other accredited educational or
• Is a resident of the Netherlands immedi- research institution.
ately before visiting the United States, and Poland
• Is in the United States to teach or engage A Slovak resident is entitled to these benefits
in research at a university, college, or An individual who is a resident of Poland on the only once. However, the exemption does not
other recognized educational institution for date of arrival in the United States and who is apply if:
temporarily in the United States at the invitation
not more than 2 years.
of the U.S. Government, a university, or other • The resident claimed during the immediate
recognized educational institution in the United preceding period the benefits described
If the individual’s visit to the United States is later under Students and Apprentices, or
longer than 2 years, the exemption is lost for the States primarily to teach or engage in research,
entire visit unless the competent authorities of or both, at a university or other recognized edu- • The income is from research undertaken
the Netherlands and the United States agree cational institution is exempt from U.S. income primarily for the private benefit of a spe-
otherwise. tax on income for the teaching or research for a cific person or persons.
The exemption does not apply to income maximum of 2 years from the date of arrival in
the United States.
from research carried on primarily for the private Slovenia
benefit of any person rather than in the public This exemption does not apply to income
interest. Nor does the exemption apply if the from research carried on mainly for the private An individual who is a resident of Slovenia on
resident claimed during the immediate preced- benefit of any person rather than in the public the date of arrival in the United States and who
ing period the benefits described later under interest. temporarily visits the United States to teach or
Students and Apprentices. engage in research at a recognized educational
or research institution is exempt from U.S. in-
Portugal come tax on the income received for the teach-
Norway ing or research for not more than 2 years from
An individual who is a resident of Portugal on the the date of arrival in the United States. This
An individual who is a resident of Norway on the date of arrival in the United States and who is benefit can be claimed for no more than 5 years.
date of arrival in the United States and who is temporarily in the United States at the invitation The exemption does not apply to income
temporarily in the United States at the invitation of the U.S. Government, a university, other ac- from research carried on mainly for the private
of the U.S. Government, a university, or other credited educational institution, or recognized benefit of any person rather than in the public
recognized educational institution in the United research institution in the United States, or interest.
States primarily to teach or engage in research, under an official cultural exchange program,
or both, at a university or other recognized edu- only to teach or engage in research, or both, at a
cational institution is exempt from U.S. income university or educational institution is exempt Thailand
tax on income for the teaching or research for a from U.S. income tax on income from teaching
or research for a maximum of 2 years from the An individual who is a resident of Thailand on
maximum period of 2 years from the date of
date of arrival in the United States. An individual the date of arrival in the United States and who
arrival in the United States.
is entitled to these benefits only once. However, is in the United States for not longer than 2 years
This exemption does not apply to income primarily to teach or engage in research at a
these benefits, and the benefits described later
from research carried on mainly for the private university, college, school, or other recognized
under Students and Apprentices cannot be
benefit of any person rather than in the public educational institution is exempt from U.S. in-
claimed either simultaneously or consecutively.
interest. come tax on income for the teaching or re-
search. The exemption from tax applies only if
the visit does not exceed 2 years from the date
Pakistan benefit of any person rather than in the public
the individual first visits the United States for the
interest.
purpose of engaging in teaching or research.
A professor or teacher who is a resident of
Pakistan and who temporarily visits the United This exemption does not apply to income
States to teach at a university, college, school, Romania from research carried on mainly for the private
or other educational institution for not longer
An individual who is a resident of Romania on interest. This exemption does not apply if, during
than 2 years is exempt from U.S. income tax on
the date of arrival in the United States and who the immediately preceding period, the benefits
the income received for teaching for that period.
is temporarily in the United States at the invita- described in treaty Article 22(1), pertaining to
tion of the U.S. Government, a university, or students, were claimed.
Philippines other recognized educational institution in the
United States primarily to teach or engage in
An individual who is a resident of the Philippines research, or both, at a university or other recog- Trinidad and Tobago
on the date of arrival in the United States and nized educational institution is exempt from U.S.
An individual who is a resident of Trinidad and
who is temporarily in the United States primarily income tax on income for the teaching or re-
Tobago on the date of arrival in the United
to teach or engage in research, or both, at a search for a maximum of 2 years from the date
States and who is temporarily in the United
university or other recognized educational insti- of arrival in the United States. States at the invitation of the U.S. Government,
tution is exempt from U.S. income tax on income This exemption does not apply to income a university, or other accredited educational in-
from the teaching or research for not more than from research carried on mainly for the private stitution in the United States primarily to teach or
2 years from the date of arrival in the United benefit of any person rather than in the public engage in research, or both, at a university or
States. The individual must have been invited to interest. other accredited educational institution is ex-
the United States for a period not expected to be empt from U.S. income tax on the income re-
longer than 2 years by the U.S. Government or a ceived for the teaching or research for a
state or local government, or by a university or Slovak Republic maximum of 2 years from the date of arrival in
other recognized educational institution in the the United States.
United States. An individual is exempt from U.S. income tax on
income for teaching or research for up to 2 years
This exemption does not apply to income from research carried on mainly for the private
if he or she:
from research carried on mainly for the private benefit of any person rather than in the public
benefit of any person rather than in the public • Is a resident of the Slovak Republic imme- interest. Nor does the exemption apply to in-
interest. The exemption does not apply if, during diately before visiting the United States, come if an agreement exists between the Gov-
the immediately preceding period, the benefits and ernments of Trinidad and Tobago and the

United States for providing the services of these Associate Program and Visiting Scientist Pro- Nevertheless, an individual who qualifies for
individuals. gram are not exempt from U.S. tax as a grant, this exemption may instead choose to be treated
allowance, or award. as a resident alien of the United States for all
U.S. income tax purposes. Once made, this
Turkey choice applies for the entire period that the indi-
Australia vidual remains qualified for exemption and may
An individual who was a resident of Turkey im- not be revoked without the permission of the
mediately before visiting the United States who A resident of Australia or an individual who was U.S. competent authority.
is in the United States for not longer than 2 years a resident of Australia immediately before visit-
for the purpose of teaching or engaging in scien- ing the United States who is temporarily here for
tific research is exempt from U.S. income tax on full-time education is exempt from U.S. income Belgium
payments received from outside the United tax on payments received from outside the
States for teaching or research. United States for the individual’s maintenance or
education. Note. See the effective dates of the new
treaty under What’s New at the beginning of this
United Kingdom publication.
Austria
A professor or teacher who is a resident of the
United Kingdom on the date of arrival in the A student, apprentice, or business trainee who New treaty. A student or business trainee who
United States and who is in the United States for is a resident of Austria immediately before visit- is a resident of Belgium immediately before visit-
not longer than 2 years primarily to teach or ing the United States and is in the United States ing the United States and is in the United States
engage in research at a university, college, or for the purpose of full-time education at a recog- for the purpose of full-time education or training
other recognized educational institution is ex- nized educational institution or full-time training is exempt from U.S. income tax on the following
empt from U.S. income tax on income for the is exempt from U.S. income tax on amounts amounts.
teaching or research. If the individual’s 2-year received from sources outside the United States • Payments received from abroad for main-
period is exceeded, the exemption is lost for the for the individual’s maintenance, education, or tenance, education, or training.
entire visit, including the 2-year period. training.
• Income from personal services of up to
The exemption does not apply to income Apprentices and business trainees are enti- $9,000 for each tax year.
from research carried on mainly for the private tled to the benefit of this exemption for a maxi-
benefit of any person rather than in the public mum period of 3 years. A business trainee is entitled to the benefit of
interest. this exemption for a maximum period of 2 years.
For this purpose, a business trainee is an
Bangladesh individual who is temporarily in the United
Venezuela States:
An individual who is a resident of Bangladesh
An individual who is a resident of Venezuela on immediately before visiting the United States • To secure training to practice a profession
the date of arrival in the United States and who and who is temporarily present in the United or professional specialty, or
temporarily visits the United States to teach or States for the primary purpose of:
• As an employee of, or under contract with,
engage in research at a recognized educational
1. Studying at a university, college, school, or a resident of Belgium, for the primary pur-
or research institution is exempt from U.S. in-
other recognized educational institution in pose of acquiring technical, professional,
come tax on the income received for the teach-
the United States, or business experience from a person
ing or research for not more than 2 years from
other than that resident of Belgium or
the date of arrival in the United States. This 2. Securing training as a business or techni- other than a person related to that resi-
benefit can be claimed for no more than 5 years. cal apprentice, or dent.
The exemption does not apply to income 3. Studying or doing research as a recipient
from research carried on mainly for the private of a grant, allowance, or award from a gov- Former treaty. An individual who is a resident
benefit of any person rather than in the public ernmental, religious, charitable, or educa- of Belgium on the date of arrival in the United
interest. tional organization States and who is temporarily in the United
is exempt from U.S. tax on the following States primarily to study at a university or other
Students and Apprentices amounts. recognized educational institution in the United
States, obtain professional training, or study or
Residents of the following countries who are in • The payments from abroad for the pur- do research as a recipient of a grant, allowance,
the United States to study or acquire technical pose of maintenance, education, or train- or award from a governmental, religious, chari-
experience are exempt from U.S. income tax, ing. table, scientific, literary, or educational organi-
under certain conditions, on amounts received
from abroad for their maintenance and studies.
• The grant, allowance, or award. zation is exempt from U.S. income tax on the
following amounts.
• The income from personal services per-
This exemption does not apply to the salary
formed in the United States of up to • Gifts from abroad for maintenance, educa-
paid by a foreign corporation to one of its execu- tion, study, research, or training.
$8,000 for the tax year.
tives, a citizen and resident of a foreign country
who is temporarily in the United States to study a • The grant, allowance, or award.
For an individual described in (2), the exemp-
particular industry for an employer. That amount
tion from tax applies for not more than 2 years • Income from personal services performed
is a continuation of salary and is not received to in the United States of up to $2,000 for
from the date the individual first arrived in the
study or acquire experience. each tax year.
United States.
For each country listed there is a statement
An individual is entitled to the benefit of this
of the conditions under which the exemption
Barbados exemption for a maximum of 5 years.
applies to students and apprentices from that
An individual who is a resident of Belgium on
country.
A student or business apprentice who is a resi- the date of arrival in the United States and who
Amounts received from the National Insti- dent of Barbados on the date of arrival in the is in the United States as an employee of, or
tutes of Health (NIH) under provisions of the United States and is here for full-time education under contract with, a resident of Belgium is
Visiting Fellows Program are generally treated or training is exempt from U.S. income tax on exempt from U.S. income tax for a period of 12
as a grant, allowance, or award for purposes of payments received from outside the United consecutive months on up to $5,000 received
whether an exemption is provided by treaty. States for the individual’s maintenance, educa- for personal services if the individual is in the
Amounts received from NIH under the Visiting tion, or training. United States primarily to:

• Acquire technical, professional, or busi- under contract with, a resident of a C.I.S. mem- Czech Republic
ness experience from a person other than ber is exempt from U.S. income tax on the
that resident of Belgium or other than a amounts received from that resident. Also ex- An individual who is a resident of the Czech
person related to that resident, or empt is an amount received from U.S. sources, Republic at the beginning of his or her visit to the
United States and who is temporarily present in
• Study at an educational institution. of not more than $10,000, that is necessary to
the United States is exempt from U.S. income
provide for ordinary living expenses. The ex-
tax on certain amounts for a period of up to 5
An individual who is a resident of Belgium on emption contained in this paragraph is limited to
years. To be entitled to the exemption, the indi-
the date of arrival in the United States and who 1 year. vidual must be in the United States for the pri-
is temporarily present in the United States for An individual who is a resident of a C.I.S. mary purpose of:
not longer than 1 year as a participant in a member and who is temporarily present in the
program sponsored by the U.S. Government • Studying at a university or other accred-
United States under an exchange program pro-
primarily to train, research, or study is exempt ited educational institution in the United
vided for by an agreement between govern- States,
from U.S. income tax on income received for
ments on cooperation in various fields of
personal services for the training, research, or
science and technology is exempt from U.S. • Obtaining training required to qualify him
study in the amount of $10,000. or her to practice a profession or profes-
income tax on all income received in connection
with the exchange program for a period not sional specialty, or
Canada longer than 1 year. • Studying or doing research as a recipient

of a grant, allowance, or award from a
A full-time student, trainee, or business appren- governmental, religious, charitable, scien-
tice who is or was a Canadian resident immedi- Cyprus tific, literary, or educational organization.
ately before visiting the United States is exempt
An individual who is a resident of Cyprus on the If the individual meets any of these require-
from U.S. income tax on amounts received from
date of arrival in the United States and who is ments, the following amounts are exempt from
sources outside the United States for mainte-
temporarily here primarily to study at a university U.S. tax.
nance, education, or training.
Also see Publication 597, Information on the or other recognized educational institution in the • The payments from abroad, other than
United States – Canada Income Tax Treaty. United States, obtain professional training, or compensation for personal services, for
study or do research as a recipient of a grant, the purpose of maintenance, education,
allowance, or award from a governmental, relig- study, research, or training.
China, People’s Republic of ious, charitable, scientific, literary, or educa- • The grant, allowance, or award.
tional organization is exempt from U.S. income
A student, business apprentice, or trainee who tax on the following amounts. • The income from personal services per-
is a resident of the People’s Republic of China formed in the United States of up to
on the date of arrival in the United States and • Gifts from abroad for maintenance, educa- $5,000 for the tax year.
who is present in the United States solely to tion, or training.
obtain training, education, or special technical • The grant, allowance, or award. An individual who is a Czech resident at the
experience is exempt from U.S. income tax on beginning of the visit to the United States and
the following amounts. • Income from personal services performed who is temporarily present in the United States
in the United States of up to $2,000 for as an employee of, or under contract with, a
• Payments received from abroad for main- each tax year. Czech resident is exempt from U.S. income tax
tenance, education, study, research, or
for a period of 12 consecutive months on up to
training. An individual is entitled to this exemption for $8,000 received for personal services if the indi-
• Grants or awards from a government, sci- up to 5 tax years and for an additional period as vidual is in the United States primarily to:
entific, educational, or other tax-exempt is necessary to complete, as a full-time student,
• Acquire technical, professional, or busi-
organization. educational requirements for a postgraduate or ness experience from a person other than
• Income from personal services performed professional degree from a recognized educa- the Czech resident, or
in the United States of up to $5,000 for tional institution.
• Study at a university or other accredited
each tax year. An individual who is a resident of Cyprus on educational institution in the United States.
the date of arrival in the United States and who
An individual is entitled to this exemption only is temporarily here as an employee of, or under An individual who is a Czech resident at the
for the time reasonably necessary to complete contract with, a resident of Cyprus is exempt time he or she becomes temporarily present in
the education or training. from U.S. income tax for not more than 1 year on the United States and who is temporarily pres-
income from personal services for a maximum ent in the United States for a period not longer
of $7,500 if the individual is in the United States than 1 year as a participant in a program spon-
Commonwealth of primarily to either: sored by the U.S. Government for the primary
Independent States (C.I.S.) purpose of training, research, or study is exempt
• Acquire technical, professional, or busi- from U.S. income tax on up to $10,000 of in-
An individual who is a resident of a C.I.S. mem- ness experience from a person other than
ber and who is temporarily in the United States come from personal services for that training,
a resident of Cyprus or other than a per- research, or study.
primarily to study at an educational or scientific son related to that resident, or These exemptions do not apply to income
research institution or to obtain training for quali-
fication in a profession or specialty is exempt • Study at a university or other recognized from research undertaken primarily for the pri-
educational institution. vate benefit of a specific person or persons.
from U.S. income tax on amounts received as
stipends, scholarships, or other substitute al-
lowances necessary to provide ordinary living An individual who is a resident of Cyprus on
the date of arrival in the United States and who Denmark
expenses. An individual is entitled to the benefit
of this exemption for a maximum of 5 years and is temporarily here for a period of not more than A student, apprentice, or business trainee who
for less than $10,000 in each tax year. 1 year as a participant in a program sponsored is a resident of Denmark immediately before
An individual who is a resident of a C.I.S. by the U.S. Government primarily to train, re- visiting the United States and is in the United
member and who is temporarily in the United search, or study is exempt from U.S. income tax States for the purpose of full-time education at
States primarily to acquire technical, profes- on income for personal services for the training, an accredited educational institution, or full-time
sional, or commercial experience or perform research, or study. This exemption is limited to training, is exempt from U.S. income tax on
technical services and who is an employee of, or $10,000. amounts received from sources outside the

United States for the individual’s maintenance, governmental, religious, charitable, scientific, lit- An individual is entitled to this benefit and the
education, or training. erary, or educational organization is exempt benefit described earlier under Professors,
Apprentices and business trainees are enti- from U.S. income tax on the following amounts. Teachers, and Researchers for a maximum of 5
tax years.
tled to the benefit of this exemption for a maxi- • Payments from abroad, other than com-
mum period of 3 years. pensation for personal services, for main- This exemption does not apply to income
The exemption does not apply to income tenance, education, study, research, or from research carried on mainly for the private
from research undertaken primarily for the pri- training. benefit of any person rather than in the public
vate benefit of a specific person or persons. interest.
• The grant, allowance, or award. An individual who is a resident of France on
• Income from personal services performed the date of arrival in the United States and who
Egypt in the United States of up to $5,000 for is in the United States as an employee of, or
each tax year. under contract with, a resident of France is ex-
An individual who is a resident of Egypt on the empt from U.S. income tax for a period of 12
date of arrival in the United States and who is An individual is entitled to the benefit of this consecutive months on up to $8,000 received
temporarily in the United States primarily to exemption for a maximum of 5 years. for personal services if the individual is in the
study at a university or other recognized educa- United States primarily to:
An individual who is a resident of Estonia on
tional institution in the United States, obtain pro-
fessional training, or study or do research as a
the date of arrival in the United States and who • Acquire technical, professional, or busi-
is in the United States as an employee of, or ness experience from a person other than
recipient of a grant, allowance, or award from a under contract with, a resident of Estonia is that resident of France, or
governmental, religious, charitable, scientific, lit- exempt from U.S. income tax for a period of 12
erary, or educational organization is exempt consecutive months on up to $8,000 received • Study at an educational institution.
from U.S. income tax on the following amounts. for personal services if the individual is in the
• Gifts from abroad for maintenance, educa- United States primarily to: Germany
tion, study, research, or training. • Acquire technical, professional, or busi-
• The grant, allowance, or award. ness experience from a person other than Note. See the effective dates of the protocol
that resident of Estonia, or under What’s New at the beginning of this publi-
• Income from personal services performed
in the United States of up to $3,000 each • Study at an educational institution. cation. The only change under the protocol that
applies to students and business apprentices
tax year.
An individual who is a resident of Estonia on increases the compensation for dependent per-
the date of arrival in the United States and who sonal services that is exempt from U.S. tax from
is temporarily present in the United States for $5,000 to $9,000.
exemption for a maximum of 5 tax years and for
not longer than 1 year as a participant in a A student or business apprentice (including
any additional period of time needed to com-
program sponsored by the U.S. Government Volontaere and Praktikanten) who is or was im-
plete, as a full-time student, educational require-
primarily to train, research, or study is exempt mediately before visiting the United States a
ments as a candidate for a postgraduate or
from U.S. income tax on income received for resident of Germany and who is present in the
professional degree from a recognized educa-
personal services for the training, research, or United States for full-time education or training
tional institution. study in the amount of $10,000. is exempt from U.S. income tax on amounts
An individual who is a resident of Egypt on from sources outside the United States for main-
These provisions do not apply to income
the date of arrival in the United States and who tenance, education, or training.
is temporarily in the United States as an em-
benefit of any person rather than in the public An individual who is or was immediately
ployee of, or under contract with, a resident of
interest. before visiting the United States a resident of
Egypt is exempt from U.S. income tax for a
Germany is exempt from U.S. tax on amounts
period of 12 consecutive months on up to $7,500 received as a grant, allowance, or award from a
received for personal services if the individual is Finland nonprofit religious, charitable, scientific, literary,
in the United States primarily to: or educational organization.
• Acquire technical, professional, or busi- A full-time student, trainee, or business appren-
Individuals described in the previous two
tice who is a resident of Finland immediately
ness experience from a person other than paragraphs are also exempt from U.S. tax on
before visiting the United States is exempt from
that resident of Egypt or other than a per- compensation for dependent personal services
U.S. income tax on amounts received from
son related to that resident, or of up to $9,000 per year if:
sources outside the United States for mainte-
• Study at a university or other educational nance, education, or training. • They are present in the United States for
institution. not more than 4 years, and
France • The services are performed for the pur-

An individual who is a resident of Egypt on the
pose of supplementing funds available
date of arrival in the United States and who is
An individual who is a resident of France on the otherwise for maintenance, education, or
temporarily in the United States for no more than training.
1 year as a participant in a program sponsored date of arrival in the United States and who is
by the U.S. Government primarily to train, re- If the individual’s visit exceeds 4 years, the
study at a university or other recognized educa-
search, or study is exempt from U.S. income tax exemption is lost for the entire visit unless the
on income received for personal services for the competent authorities of Germany and the
fessional training, or study, or do research as a
training, research, or study for a maximum of United States agree otherwise.
recipient of a grant, allowance, or award from a
$10,000.
not-for-profit governmental, religious, charitable, An individual who is a resident of Germany
scientific, artistic, cultural, or educational organi- and who is employed by a German enterprise or
zation is exempt from U.S. income tax on the by a nonprofit religious, charitable, scientific,
Estonia following amounts. literary, or educational organization is exempt
from U.S. tax on compensation paid by the em-
An individual who is a resident of Estonia on the • Gifts from abroad for maintenance, educa- ployer from outside the United States if:
date of arrival in the United States and who is tion, study, research, or training.
• The grant, allowance, or award. • The individual is temporarily in the United
study at a university or other accredited educa- States for not more than 1 year to acquire
tional institution in the United States, obtain pro- • Income from personal services performed technical, professional, or business experi-
fessional training, or study or do research as a in the United States of up to $5,000 each ence from any person other than his or her
recipient of a grant, allowance, or award from a tax year. employer, and

• The compensation is not more than program sponsored by the U.S. Government Ireland
$10,000. primarily to train, research, or study is exempt
from U.S. income tax on income received for A student, apprentice, or business trainee who
If the compensation is more than $10,000, none is a resident of Ireland immediately before visit-
of the income is exempt. personal services for the training, research, or
ing the United States and is in the United States
study for a maximum of $10,000.
for the purpose of full-time education at a recog-
Greece nized educational institution or full-time training
is exempt from U.S. income tax on amounts
A student or business apprentice who is a resi- India
received from sources outside the United States
dent of Greece and is temporarily in the United
An individual who is a resident of India immedi- for the individual’s maintenance, education, or
States only to study or acquire business experi-
ately before visiting the United States and who is training.
ence is exempt from U.S. income tax on
amounts received from sources outside the temporarily in the United States primarily for Apprentices and business trainees are enti-
United States for maintenance or studies. studying or training is exempt from U.S. income tled to the benefit of this exemption for a maxi-
tax on payments from abroad for maintenance, mum period of 1 year.
study, or training. The exemption does not apply
Hungary to payments borne by a permanent establish-
ment in the United States or paid by a U.S. Israel
An individual who is a resident of Hungary im-
citizen or resident, the U.S. Government, or any
mediately before arrival in the United States and An individual who is a resident of Israel on the
is here for full-time education or training is ex- of its agencies, instrumentalities, political subdi-
empt from U.S. income tax on payments re- visions, or local authorities.
ceived from outside the United States for the Under the treaty, if the payments are not study at a university or other recognized educa-
individual’s maintenance, education, or training. exempt under the rule described above, an indi- tional institution in the United States, obtain pro-
The full-time student or trainee may instead vidual described in the previous paragraph may fessional training, or study or do research as a
choose to be treated as a resident alien of the be eligible to deduct exemptions for his or her recipient of a grant, allowance, or award from a
United States for U.S. income tax purposes. spouse and dependents and the standard de- governmental, religious, charitable, scientific, lit-
Once made, the choice applies for the entire duction. The individual must file Form 1040NR erary, or educational organization is exempt
period that the individual remains qualified for or Form 1040NR-EZ to claim these amounts. from U.S. income tax on the following amounts.
exemption as a full-time student or trainee and For information on how to claim these amounts, • Gifts from abroad for maintenance, educa-
may not be changed unless permission is ob- see chapter 5 in Publication 519. tion, study, research, or training.
tained from the U.S. competent authority.
The individual is entitled to these benefits • The grant, allowance, or award.
only for a period of time considered reasonable
or customarily required to complete studying or • Income from personal services performed
Iceland in the United States of up to $3,000 each
training.
tax year.
An individual who is a resident of Iceland on the
temporarily in the United States primarily to Indonesia
exemption for a maximum of 5 tax years.
tional institution in the United States, obtain pro- An individual who is a resident of Indonesia
An individual who is a resident of Israel on
fessional training, or study or do research as a immediately before visiting the United States
recipient of a grant, allowance, or award from a and who is temporarily in the United States is is temporarily in the United States as an em-
governmental, religious, charitable, scientific, lit- exempt from U.S. income tax on certain ployee of, or under contract with, a resident of
erary, or educational organization is exempt amounts for a period of up to 5 years. To be Israel is exempt from U.S. income tax for a
from U.S. income tax on the following amounts. entitled to the exemption, the individual must be period of 12 consecutive months on up to $7,500
• Gifts from abroad for maintenance, educa- temporarily in the United States for full-time received for personal services if the individual is
tion, study, research, or training. study at a U.S. university, school, or other recog- in the United States primarily to:
nized educational institution, or for full-time
• The grant, allowance, or award. • Acquire technical, professional, or busi-
study, research, or training as a recipient of a
ness experience from a person other than
• Income from personal services performed grant, allowance, or award from either the U.S. that resident of Israel or other than a per-
in the United States of up to $2,000 each or Indonesian Government, a scientific, educa- son related to that resident, or
tax year. tional, religious, or charitable organization, or
under a technical assistance program entered • Study at a university or other educational
An individual is entitled to the benefit of this into by either the U.S. or Indonesian Govern- institution.
exemption for a maximum of 5 years. ment. If the individual meets any of these re-
An individual who is a resident of Israel on the
An individual who is a resident of Iceland on quirements, the following amounts are exempt
the date of arrival in the United States and who from tax. temporarily in the United States for no more than
is temporarily in the United States as an em- • All payments from abroad for mainte- 1 year as a participant in a program sponsored
ployee of, or under contract with, a resident of by the U.S. Government primarily to train, re-
nance, education, study, research, or
Iceland is exempt from U.S. income tax for a search, or study is exempt from U.S. income tax
training.
period of 12 consecutive months on up to $5,000 on income received for personal services for the
received for personal services if the individual is • The grant, allowance, or award. training, research, or study for a maximum of
in the United States primarily to:
• Income from personal services performed $10,000.
• Acquire technical, professional, or busi- in the United States of up to $2,000 each
ness experience from a person other than tax year.
that resident of Iceland or other than a Italy
person related to that person, or An individual who is a resident of Indonesia A student or business apprentice (trainee) who
• Study at an educational institution. immediately before visiting the United States is a resident of Italy on the date of arrival in the
and is temporarily in the United States only as a United States and who is temporarily in the
An individual who is a resident of Iceland on business or technical apprentice is exempt from United States only for education or training is
the date of arrival in the United States and who U.S. income tax for a period of 12 consecutive exempt from U.S. income tax on amounts re-
is temporarily present in the United States for months on up to $7,500 received for personal ceived from outside the United States for main-
not longer than 1 year as a participant in a services. tenance, education, and training.

Jamaica The individual is entitled to this exemption • The grant, allowance, or award.
only for a period of time necessary to complete
A student who is a resident of Jamaica on the the study, training, or research, but the exemp-
• Income from personal services performed
date of arrival in the United States and is here for in the United States of up to $5,000 for
tion for training or research may not extend for a
full-time education or training is exempt from each tax year.
period exceeding 5 years.
U.S. income tax on payments received from
These exemptions do not apply to income An individual is entitled to the benefit of this
outside the United States for the student’s main-
from research if it is undertaken primarily for the exemption for a maximum of 5 years.
tenance, education, or training.
private benefit of a specific person or persons. An individual who is a resident of Latvia on
An individual who is a resident of Jamaica on
the date of arrival in the United States and who the date of arrival in the United States and who
is temporarily in the United States as an em- is in the United States as an employee of, or
Korea, Republic of under contract with, a resident of Latvia is ex-
ployee of, or under contract with, a resident of
Jamaica is exempt from U.S. income tax for a An individual who is a resident of the Republic of empt from U.S. income tax for a period of 12
period of 12 consecutive months on up to $7,500 Korea on the date of arrival in the United States consecutive months on up to $8,000 received
of net income from personal services if the indi- and who is temporarily in the United States pri- for personal services if the individual is in the
vidual is in the United States primarily to: marily to study at a university or other recog- United States primarily to:
• Acquire technical, professional, or busi- nized educational institution in the United • Acquire technical, professional, or busi-
ness experience from a person other than States, obtain professional training, or study or ness experience from a person other than
that resident of Jamaica or other than a do research as a recipient of a grant, allowance, that resident of Latvia, or
person related to that resident, or or award from a governmental, religious, chari-
table, scientific, literary, or educational organi- • Study at an educational institution.
• Study at a university or other recognized zation is exempt from U.S. income tax on the
educational institution. following amounts. An individual who is a resident of Latvia on the
An individual who qualifies for one of the ex- • Amounts from abroad for maintenance, temporarily present in the United States for not
emptions discussed above may instead choose education, study, research, or training. longer than 1 year as a participant in a program
to be treated as a resident alien of the United • The grant, allowance, or award. sponsored by the U.S. Government primarily to
States for all U.S. income tax purposes. Once train, research, or study is exempt from U.S.
made, the choice applies for the entire period • Income from personal services performed income tax on income received for personal
that the individual remains qualified for exemp- in the United States of up to $2,000 each
services for the training, research, or study in the
tion and may not be revoked unless permission tax year.
amount of $10,000.
is obtained from the U.S. competent authority. These provisions do not apply to income
exemption for a maximum of 5 years. from research carried on mainly for the private
Japan An individual who is a resident of Korea on interest.
A student or business apprentice who is a resi- is temporarily in the United States as an em-
dent of Japan immediately before visiting the ployee of, or under contract with, a resident of
United States and is in the United States for the Lithuania
Korea is exempt from U.S. income tax for 1 year
purpose of education or training is exempt from on up to $5,000 received for personal services if An individual who is a resident of Lithuania on
U.S. income tax on amounts received from the individual is in the United States primarily to: the date of arrival in the United States and who
abroad for the individual’s maintenance, educa-
• Acquire technical, professional, or busi- is temporarily in the United States primarily to
tion, or training.
ness experience from a person other than study at a university or other accredited educa-
Business apprentices are entitled to the ben- tional institution in the United States, obtain pro-
efit of this exemption for a maximum period of 1 that resident of Korea or other than a per-
son related to that resident, or fessional training, or study or do research as a
year.
• Study at an educational institution. governmental, religious, charitable, scientific, lit-
Former treaty. An individual entitled to the erary, or educational organization is exempt
student and trainee benefits under the former An individual who is a resident of Korea on the from U.S. income tax on the following amounts.
treaty may continue to claim those benefits for date of arrival in the United States and who is
as long as the individual would have been enti- temporarily present in the United States for not • Payments from abroad, other than com-
tled to those benefits under that treaty. longer than 1 year as a participant in a program pensation for personal services, for main-
sponsored by the U.S. Government primarily to tenance, education, study, research, or
train, research, or study is exempt from U.S. training.
Kazakhstan income tax on income received for personal • The grant, allowance, or award.
services for the training, research, or study for a
An individual who is a resident of Kazakhstan at maximum of $10,000. • Income from personal services performed
the beginning of his or her visit to the United in the United States of up to $5,000 for
States is exempt from U.S. tax on payments each tax year.
from abroad for maintenance, education, study, Latvia
research, or training and on any grant, allow- An individual is entitled to the benefit of this
ance, or other similar payments. To be entitled An individual who is a resident of Latvia on the exemption for a maximum of 5 years.
to the exemption, the individual must be tempo- date of arrival in the United States and who is An individual who is a resident of Lithuania
rarily present in the United States primarily to: temporarily in the United States primarily to on the date of arrival in the United States and
study at a university or other accredited educa-
• Study at a university or other accredited tional institution in the United States, obtain pro-
who is in the United States as an employee of, or
educational institution, under contract with, a resident of Lithuania is
fessional training, or study or do research as a exempt from U.S. income tax for a period of 12
• Obtain training required to qualify him or recipient of a grant, allowance, or award from a
consecutive months on up to $8,000 received
her to practice a profession or professional governmental, religious, charitable, scientific, lit-
for personal services if the individual is in the
specialty, or, erary, or educational organization is exempt
United States primarily to:
from U.S. income tax on the following amounts.
• Study or do research as a recipient of a • Acquire technical, professional, or busi-
grant, allowance, or other similar pay- • Payments from abroad, other than com- ness experience from a person other than
ments from a governmental, religious, pensation for personal services, for main-
that resident of Lithuania, or
charitable, scientific, literary, or educa- tenance, education, study, research, or
tional organization. training. • Study at an educational institution.

An individual who is a resident of Lithuania on primarily for full-time study at a recognized uni- An individual who is a resident of Norway on
the date of arrival in the United States and who versity, college, or school or securing training as the date of arrival in the United States and who
is temporarily present in the United States for a business apprentice is exempt from U.S. in- is in the United States as an employee of, or
not longer than 1 year as a participant in a come tax on the following amounts. under contract with, a resident of Norway is
program sponsored by the U.S. Government exempt from U.S. income tax for a period of 12
• Payments from abroad for maintenance,
primarily to train, research, or study is exempt consecutive months on up to $5,000 received
education, or training.
from U.S. income tax on income received for for personal services if the individual is in the
personal services for the training, research, or • Income from personal services performed United States primarily to:
study in the amount of $10,000. in the United States of up to $2,000 each
tax year. • Acquire technical, professional, or busi-
These provisions do not apply to income ness experience from a person other than
from research carried on mainly for the private that resident of Norway or other than a
benefit of any person rather than in the public The individual is entitled to this exemption
only for a period of time considered reasonable person related to that resident of Norway,
interest. or
or customarily required to complete studying or
training. • Study at an educational institution.
Luxembourg An individual who immediately before visiting
the United States is a resident of the Nether- Also exempt is a resident of Norway who is
A student, apprentice, or business trainee who lands and is temporarily present in the United present in the United States for not longer than 1
is a resident of Luxembourg immediately before States for a period not exceeding 3 years for the year as a participant in a program sponsored by
visiting the United States and is in the United purpose of study, research, or training solely as the Government of the United States primarily to
States for the purpose of full-time education at a a recipient of a grant, allowance, or award from a train, research, or study. The individual is ex-
recognized educational institution or full-time scientific, educational, religious, or charitable or- empt from tax on income from personal services
training is exempt from U.S. income tax on ganization or under a technical assistance pro- performed in the United States and received for
amounts received for the individual’s mainte- gram entered into by either the Netherlands or the training, research, or study, for a maximum
nance, education, or training. the United States, or its political subdivisions or of $10,000.
Apprentices and business trainees are enti- local authorities is exempt from U.S. income tax
tled to the benefit of this exemption for a maxi- on the following amounts.
mum period of 2 years. Pakistan
• The amount of the grant, allowance, or
If the individual’s visit to the United States is
award. Residents of Pakistan temporarily in the United
longer than 2 years, the exemption is lost for the
entire visit unless the competent authorities of • Income of up to $2,000 for personal serv- States are exempt from U.S. income tax on
Luxembourg and the United States agree other- ices performed in the United States for certain income they may receive. To be entitled
wise. any tax year if the services are connected to this exemption, they must be in the United
with, or incidental to, the study, research, States only as students at a recognized univer-
or training. sity, college, or school, or as recipients of grants,
Mexico allowances, or awards from religious, charitable,
An individual is not entitled to these exemp- scientific, or educational organizations of Paki-
A student or business apprentice who is a resi- tions if, during the immediately preceding pe- stan primarily to study or research. The income
dent of Mexico immediately before visiting the riod, the individual claimed the exemption exempt in these cases is any payment from
United States and is in the United States solely discussed earlier under Professors, Teachers, abroad for maintenance, education, or training,
for the purpose of education or training is ex- and Researchers. and any pay for personal services of not more
empt from U.S. tax on amounts received from than $5,000 for any tax year.
sources outside the United States for the individ- Other residents of Pakistan who are tempo-
ual’s maintenance, education, or training. New Zealand rarily in the United States for no more than 1
year are exempt from U.S. income tax on pay of
A resident of New Zealand or an individual who not more than $6,000 received for that period,
Morocco was a resident of New Zealand immediately including pay from the enterprise or organization
before visiting the United States who is in the of which they are employees or with which they
An individual who is a resident of Morocco on United States for full-time education is exempt are under contract. To qualify for this exemption,
the date of arrival in the United States and who from U.S. income tax on amounts received from they must be employees of, or under contract
is temporarily in the United States primarily to abroad for maintenance or education. with, a Pakistani enterprise or religious, charita-
ble, scientific, or educational organization and
be in the United States only to acquire technical,
fessional training, or study or do research as a Norway professional, or business experience from a per-
recipient of a grant, allowance, or award from a son other than that enterprise or organization.
governmental, religious, charitable, scientific, lit- An individual who is a resident of Norway on the
date of arrival in the United States and who is Also exempt from U.S. income tax on certain
erary, or educational organization is exempt
temporarily in the United States primarily to income are residents of Pakistan temporarily in
study at a university or other recognized educa- the United States under an arrangement with
• Gifts from abroad for maintenance, educational institution in the United States, obtain pro- the U.S. Government, or any of its agencies or
tion, study, research, or training. fessional training, or study or do research as a instrumentalities, only for study, training, or ori-
entation. They are exempt from tax on income of
• The grant, allowance, or award. recipient of a grant, allowance, or award from a
governmental, religious, charitable, scientific, lit- not more than $10,000 for services directly re-
• Income from personal services performed erary, or educational organization is exempt lated to their training, study, or orientation, in-
in the United States of up to $2,000 each from U.S. income tax on the following amounts. cluding income from their employer abroad.
tax year.
• Gifts from abroad for maintenance, educa-
An individual is entitled to the benefit of this tion, study, research, or training. Philippines
exemption for a maximum of 5 years. • The grant, allowance, or award. An individual who is a resident of the Philippines
• Income from personal services performed on the date of arrival in the United States and
Netherlands in the United States up to $2,000 each tax who is temporarily in the United States primarily
year. to study at a university or other recognized edu-
An individual who immediately before visiting cational institution in the United States, obtain
the United States is a resident of the Nether- An individual is entitled to the benefit of this professional training, or study or do research as
lands and who is present in the United States exemption for a maximum of 5 tax years. a recipient of a grant, allowance, or award from a

governmental, religious, charitable, scientific, lit- • Acquire technical, professional, or busi- • Income from personal services performed
erary, or educational organization is exempt ness experience from a person other than in the United States of up to $2,000 each
from U.S. income tax on the following amounts. that resident of Poland or other than a tax year.
person related to that resident, or
• Gifts from abroad for maintenance, educa- An individual is entitled to the benefit of this
tion, study, research, or training. • Study at an educational institution.
exemption for a maximum of 5 years.
• The grant, allowance, or award. An individual who is a resident of Poland on An individual who is a resident of Romania
• Income from personal services performed the date of arrival in the United States and who on the date of arrival in the United States and
in the United States of up to $3,000 each is temporarily in the United States for not longer who is temporarily in the United States as an
than 1 year as a participant in a program spon- employee of, or under contract with, a resident
tax year.
sored by the U.S. Government primarily to train, of Romania is exempt from U.S. income tax for 1
An individual is entitled to the benefit of this research, or study is exempt from U.S. income year on up to $5,000 received for personal serv-
exemption for a maximum of 5 years. tax on up to $10,000 of income received for ices if the individual is in the United States pri-
personal services for the training, research, or marily to:
An individual who is a resident of the Philip-
study. • Acquire technical, professional, or busi-
pines on the date of arrival in the United States
and who is temporarily in the United States as ness experience from a person other than
an employee of, or under contract with, a resi- that resident of Romania or other than a
Portugal person related to that resident, or
dent of the Philippines is exempt from U.S. in-
come tax for a period of 12 consecutive months An individual who is a resident of Portugal on the • Study at an educational institution.
on up to $7,500 received for personal services if date of arrival in the United States and who is
the individual is in the United States primarily to: temporarily in the United States primarily to An individual who is a resident of Romania on
study at a university or other accredited educa-
• Acquire technical, professional, or busi- the date of arrival in the United States and who
tional institution in the United States, obtain pro- is temporarily in the United States for not longer
fessional training, or study, or do research as a than 1 year as a participant in a program spon-
that resident of the Philippines or other
recipient of a grant, allowance, or award from a sored by the U.S. Government primarily to train,
than a person related to that resident, or governmental, religious, charitable, scientific, lit- research, or study is exempt from U.S. income
• Study at an educational institution. erary, or educational organization is exempt tax on up to $10,000 of income received for
from U.S. income tax on the following amounts. personal services for the training, research, or
An individual who is a resident of the Philip-
• Payments from abroad for maintenance, study.
pines on the date of arrival in the United States, education, study, research, or training.
and who is temporarily in the United States (for
no more than 1 year as a participant in a pro- • The grant, allowance, or award. Russia
gram sponsored by the U.S. Government) pri- • Income from personal services performed
marily to train, research, or study is exempt from in the United States of up to $5,000 each An individual who is a resident of Russia at the
U.S. income tax on income received for per- tax year. beginning of his or her visit to the United States
sonal services for the training, research, or is exempt from U.S. tax on payments from
study, up to a maximum of $10,000. An individual is entitled to the benefit of this abroad for maintenance, education, study, re-
exemption for a maximum of 5 tax years from search, or training and on any grant, allowance,
the date of arrival in the United States. The or other similar payments. To be entitled to the
Poland benefits provided here and the benefits de- exemption, the individual must be temporarily
scribed earlier under Professors, Teachers, and present in the United States primarily to:
An individual who is a resident of Poland on the
Researchers cannot be claimed simultaneously • Study at a university or other accredited
or consecutively. educational institution,
An individual who is a resident of Portugal on
the date of arrival in the United States and who • Obtain training required to qualify him or
tional institution in the United States, obtain pro- her to practice a profession or professional
is in the United States as an employee of, or
fessional training, or study or do research as a under contract with, a resident of Portugal is specialty, or
governmental, religious, charitable, scientific, lit-
exempt from U.S. income tax for a period of 12 • Study or do research as a recipient of a
consecutive months on up to $8,000 received grant, allowance, or other similar pay-
erary, or educational organization is exempt for personal services if the individual is in the ments from a governmental, religious,
from U.S. income tax on the following amounts. United States primarily to: charitable, scientific, literary, or educa-
• Gifts from abroad for maintenance, educa- • Acquire technical, professional, or busi- tional organization.
tion, study, research, or training. ness experience from a person other than
The individual is entitled to this exemption
• The grant, allowance, or award. that resident of Portugal, or
• Any other payments received from Poland, • Study at an educational institution. the study, training, or research, but the exemp-
except income from performing personal tion for training or research may not extend for a
services. Romania period exceeding 5 years.
• Income from personal services performed An individual who is a resident of Romania on
in the United States of up to $2,000 each from research if it is undertaken primarily for the
the date of arrival in the United States and who private benefit of a specific person or persons.
tax year.
is temporarily in the United States primarily to
exemption for a maximum of 5 years.
tional institution in the United States, obtain pro- Slovak Republic
fessional training, or study or do research as a
An individual who is a resident of Poland on recipient of a grant, allowance, or award from a An individual who is a resident of the Slovak
the date of arrival in the United States and who governmental, religious, charitable, scientific, lit- Republic at the beginning of his or her visit to the
is temporarily in the United States as an em- erary, or educational organization is exempt United States and who is temporarily present in
ployee of, or under contract with, a resident of from U.S. income tax on the following amounts. the United States is exempt from U.S. income
Poland is exempt from U.S. income tax for 1 tax on certain amounts for a period of up to 5
year on up to $5,000 received for personal serv- • Gifts from abroad for maintenance, educa- years. To be entitled to the exemption, the indi-
tion, study, research, or training.
ices if the individual is in the United States pri- vidual must be in the United States for the pri-
marily to: • The grant, allowance, or award. mary purpose of:

• Studying at a university or other accred- • Income from personal services performed temporarily in the United States as an employee
ited educational institution in the United in the United States of up to $5,000 for of, or under contract with, a resident of Spain is
States, each tax year. exempt from U.S. income tax for a period of 12
• Obtaining training required to qualify him An individual is entitled to the benefit of this consecutive months on up to $8,000 received
or her to practice a profession or profes- exemption for a maximum of 5 tax years and for for personal services if the individual is in the
sional specialty, or any additional period of time needed to com- United States primarily to:
• Studying or doing research as a recipient plete, as a full-time student, educational require- • Acquire technical, professional, or busi-
of a grant, allowance, or award from a ments as a candidate for a postgraduate or ness experience from a person other than
governmental, religious, charitable, scien- professional degree from a recognized educa- that Spanish resident, or
tional institution.
tific, literary, or educational organization. • Study at a university or other accredited
If the individual meets any of these require- An individual who is a resident of Slovenia on educational institution in the United States.
ments, the following amounts are exempt from the date of arrival in the United States and who
U.S. tax. is temporarily in the United States as an em- Both the $5,000 and $8,000 exemptions in-
ployee of, or under contract with, a resident of clude any amount excluded or exempted from
• The payments from abroad, other than Slovenia is exempt from U.S. income tax for a tax under U.S. tax law.
compensation for personal services, for period not exceeding 12 months on up to $8,000 These exemptions do not apply to income
the purpose of maintenance, education, received for personal services if the individual is
study, research, or training. from research carried on mainly for the private
in the United States primarily to: benefit of any person rather than in the public
• The grant, allowance, or award. • Acquire technical, professional, or busi- interest.
• The income from personal services per- ness experience from a person other than
formed in the United States of up to that resident of Slovenia, or
Sri Lanka
$5,000 for the tax year. • Study at a university or other recognized
educational institution. A student, apprentice, or business trainee, who
An individual who is a Slovak resident at the
is a resident of Sri Lanka resident immediately
beginning of the visit to the United States and These provisions do not apply to income from before visiting the United States and is in the
who is temporarily present in the United States research carried on mainly for the private benefit United States for the purpose of full-time educa-
as an employee of, or under contract with, a of any person rather than in the public interest. tion or training, is exempt from U.S. income tax
Slovak resident is exempt from U.S. income tax
on amounts received from sources outside the
for a period of 12 consecutive months on up to
$8,000 received from personal services if the United States for the individual’s maintenance,
South Africa education, or training.
individual is in the United States primarily to:
A student, apprentice, or business trainee who An individual who is a resident of Sri Lanka
• Acquire technical, professional, or busi- on the date of arrival in the United States and
is a resident of South Africa immediately before
ness experience from a person other than who is temporarily in the United States as an
visiting the United States and is in the United
the Slovak resident, or employee of, or under contract with, a resident
States for the purpose of full-time education or
• Study at a university or other accredited training is exempt from U.S. income tax on of Sri Lanka, or as a participant in a program
educational institution in the United States. amounts received from sources outside the sponsored by the United States or by any inter-
United States for the individual’s maintenance, national organization, is exempt from U.S. in-
An individual who is a Slovak resident at the education, or training. come tax for a period not exceeding 1 year on up
time he or she becomes temporarily present in Apprentices and business trainees are enti- to $6,000 received for personal services if the
the United States and who is temporarily pres- tled to the benefit of this exemption for a maxi- individual is in the United States primarily to:
ent in the United States for a period not longer
than 1 year as a participant in a program spon-
mum period of 1 year. • Acquire technical, professional, or busi-
sored by the U.S. government for the primary ness experience from a person other than
purpose of training, research, or study is exempt that resident of Sri Lanka or other than a
Spain person related to that resident, or
from U.S. income tax on up to $10,000 of in-
come from personal services for that training, An individual who is a resident of Spain at the • Study at a university or other recognized
research, or study. beginning of the visit to the United States and educational institution.
These exemptions do not apply to income who is temporarily in the United States primarily
from research undertaken primarily for the pri- to study at a U.S. university or other accredited
vate benefit of a specific person or persons. educational institution, to obtain training to be- Sweden
come qualified to practice a profession or pro-
A student, apprentice, or business trainee who
fessional specialty, or to study or do research as
Slovenia is a resident of Sweden immediately before visit-
a recipient of a grant, allowance, or award from a
ing the United States and is in the United States
An individual who is a resident of Slovenia at the for the purpose of full-time education or training
beginning of the visit to the United States and is exempt from U.S. tax on amounts received
who is temporarily in the United States primarily from sources outside the United States for the
to study at a U.S. university or other recognized • Payments from abroad (other than com- individual’s maintenance, education, and train-
educational institution, to obtain training to be- pensation for personal services) for main- ing.
come qualified to practice a profession or pro- tenance, education, study, research, or
fessional specialty, or to study or do research as training.
a recipient of a grant, allowance, or award from a
• The grant, allowance, or award. Switzerland
erary, or educational organization is exempt • Income from personal services performed A student, apprentice, or business trainee who
from U.S. income tax on the following amounts. in the United States of up to $5,000 for is a resident of Switzerland immediately before
each tax year. visiting the United States and is in the United
• Payments from abroad (other than com- States for the purpose of full-time education or
pensation for personal services) for main- An individual is entitled to the benefit of this training is exempt from U.S. income tax on
tenance, education, study, research, or exemption for a maximum of 5 years.
amounts received from sources outside the
training.
An individual who is a resident of Spain at the United States for the individual’s maintenance,
• The grant, allowance, or award. beginning of the visit to the United States and is education, or training.

Thailand • Gifts from abroad for maintenance, educa- Ukraine

tion, study, research, or training.
An individual who is a resident of Thailand at the An individual who is a resident of Ukraine at the
beginning of his or her visit to the United States • The grant, allowance, or award. beginning of his or her visit to the United States
and who is temporarily present in the United • Income from personal services performed is exempt from U.S. tax on payments from
States is exempt from U.S. income tax on cer- in the United States of up to $2,000 each abroad for maintenance, education, study, re-
tain amounts for a period of up to 5 years. To be tax year, or, if the individual is obtaining search, or training and on any grant, allowance,
entitled to the exemption, the individual must be or other similar payments. To be entitled to the
training required to qualify to practice a
in the United States for the primary purpose of: exemption, the individual must be temporarily
profession or a professional specialty, a
present in the United States primarily to:
• Studying at a university or other recog- maximum of $5,000 for any tax year.
nized educational institution in the United • Study at a university or other accredited
States, An individual is entitled to the benefit of this educational institution,
• Obtaining training required to qualify him exemption for a maximum period of 5 tax years. • Obtain training required to qualify him or
or her to practice a profession or profes- An individual who is a resident of Trinidad her to practice a profession or professional
sional specialty, or and Tobago on the date of arrival in the United specialty, or
• Studying or doing research as a recipient States and who is in the United States as an • Study or do research as a recipient of a
of a grant, allowance, or award from a employee of, or under contract with, a resident grant, allowance, or other similar pay-
governmental, religious, charitable, scien- or corporation of Trinidad and Tobago is exempt ments from a governmental, religious,
tific, literary, or educational organization. from U.S. income tax for 1 tax year on up to charitable, scientific, literary, or educa-
$5,000 received for personal services if the indi- tional organization.
If the individual meets any of these require-
vidual is in the United States primarily to:
ments, the following amounts are exempt from
The individual is entitled to this exemption
U.S. tax. • Study at an educational institution, or
• Gifts from abroad for the purpose of main- • Acquire technical, professional, or busi- the study, training, or research, but the exemp-
tenance, education, study, research, or ness experience from a person other than tion for training or research may not extend for a
training. that resident or corporation of Trinidad and period exceeding 5 years.
• The grant, allowance, or award. Tobago.
from research if it is undertaken primarily for the
• Income from personal services performed Also exempt is a resident of Trinidad and private benefit of a specific person or persons.
in the United States of up to $3,000 for the Tobago who is present in the United States for
tax year. not longer than 1 year as a participant in a
program sponsored by the U.S. Government United Kingdom
An individual who is a resident of Thailand at primarily to train, research, or study. The individ-
the beginning of the visit to the United States A student or business apprentice who is a resi-
ual is exempt from tax on income from personal dent of the United Kingdom immediately before
and who is temporarily present in the United
services performed in the United States and visiting the United States and is in the United
States as an employee of, or under contract
with, a resident of Thailand is exempt from U.S. received for the training, research, or study for States for the purpose of full-time education at a
income tax for a period of 12 consecutive up to a maximum of $10,000. recognized educational institution or full-time
months on up to $7,500 received from personal training is exempt from U.S. income tax on
services if the individual is in the United States amounts received from abroad for the individ-
primarily to: Tunisia ual’s maintenance, education, or training.
Business apprentices are entitled to the ben-
• Acquire technical, professional, or busi- An individual who is a resident of Tunisia imme- efit of this exemption for a maximum period of 1
ness experience from a person other than diately before visiting the United States and who year.
the Thai resident, or is in the United States for full-time study or
training is exempt from U.S. income tax on the Former treaty. An individual entitled to treaty
• Study at a university or other recognized benefits under Article 21 (students and trainees)
educational institution in the United States. following amounts.
of the former treaty may continue to claim those
• Payments from abroad for full-time study benefits for as long as the individual would have
An individual who is a resident of Thailand at or training. been entitled to them under that treaty.
the time he or she becomes temporarily present
in the United States and who is temporarily pres- • A grant, allowance, or award from a gov-
ent in the United States for a period not longer ernmental, religious, charitable, scientific,
literary, or educational organization to Venezuela
than 1 year as a participant in a program spon-
sored by the U.S. government for the primary study or engage in research. An individual who is a resident of Venezuela on
purpose of training, research, or study is exempt • Income from personal services performed the date of arrival in the United States and who
from U.S. income tax on up to $10,000 of in- is temporarily in the United States primarily to
in the United States of up to $4,000 in any
come from personal services for that training, study at a university or other recognized educa-
tax year.
research, or study. tional institution in the United States, obtain pro-
The individual is entitled to this exemption for fessional training, or study or do research as a
a maximum of 5 years. recipient of a grant, allowance, or award from a
Trinidad and Tobago governmental, religious, charitable, scientific, lit-
An individual who is a resident of Trinidad and
Turkey from U.S. income tax on the following amounts.
Tobago on the date of arrival in the United
States and who is temporarily in the United • Payments from abroad, other than com-
A student, apprentice, or business trainee who
States primarily to study at a university or other pensation for personal services, for main-
accredited educational institution in the United is a resident of Turkey immediately before visit- tenance, education, study, research, or
States, obtain professional training, or study or ing the United States and is in the United States training.
do research as a recipient of a grant, allowance, for the purpose of full-time education or training
or award from a governmental, religious, chari- is exempt from U.S. income tax on amounts • The grant, allowance, or award.
table, scientific, literary, or educational organi- received from sources outside the United States • Income from personal services performed
zation is exempt from U.S. income tax on the for the individual’s maintenance, education, or in the United States of up to $5,000 for
following amounts. training. each tax year.

An individual is generally entitled to the bene- with a trade or business carried on by Austria or with a business carried on by Belgium, its politi-
fit of this exemption for a maximum of 5 years its political subdivisions or local authorities. cal subdivisions, or local authorities.
from the date of arrival in the United States. This
exemption will also apply to any additional pe- Former treaty. Wages, salaries, similar in-
riod of time that a full-time student needs to Bangladesh come, and pensions and annuities paid by, or
complete the educational requirements as a from public funds of, Belgium, its political subdi-
candidate for a postgraduate or professional de- Income, other than a pension, paid by Ban-
visions, or its local authorities, to citizens of
gree from a recognized educational institution. gladesh, its political subdivisions, or local au-
Belgium (or to citizens of countries other than
An individual who is a resident of Venezuela thorities to an individual for services performed
the United States or Belgium who come to the
on the date of arrival in the United States and for the paying governmental body is exempt
United States and are employed by Belgium or
who is in the United States as an employee of, or from U.S. income tax. However, the exemption
its political subdivisions or local authorities) for
under contract with, a resident of Venezuela is does not apply if the services are performed in
performing governmental functions are exempt
exempt from U.S. income tax for a period of 12 the United States by a resident of the United
from U.S. tax.
months on up to $8,000 received for personal States who either:
However, these exemptions do not apply to
services if the individual is in the United States • Is a U.S. citizen, or payments for services performed in connection
primarily to:
• Did not become a U.S. resident only to with a trade or business carried on by Belgium or
• Acquire technical, professional, or busi- perform the services. its political subdivisions or local authorities.
that resident of Venezuela, or Pensions paid from the public funds of Ban-
gladesh, its political subdivisions, or local au- Canada
• Study at an educational institution.
thorities for services performed for Bangladesh, Wages, salaries, and similar income (other than
These provisions do not apply to income from its political subdivisions, or local authorities to an
pensions) paid by Canada or by a Canadian
research carried on mainly for the private benefit individual for services performed for the paying
political subdivision or local authority to a citizen
of any person rather than in the public interest. governmental body are exempt from U.S. in-
of Canada for performing governmental func-
come tax unless the recipient is both a resident
tions are exempt from U.S. income tax. This
and citizen of the United States.
Wages and Pensions This exemption does not apply to income or
exemption does not apply, however, to pay-
Paid by a Foreign ments for services performed in connection with
pensions for services performed in connection
a trade or business carried on by Canada or its
Government with a business carried on by Bangladesh, its
political subdivisions or local authorities.
political subdivisions, or local authorities.
Wages, salaries, pensions, and annuities paid Also see Publication 597, Information on the
by the governments of the following countries to United States – Canada Income Tax Treaty.
their residents who are present in the United Barbados
States as nonresident aliens generally are ex-
empt from U.S. income tax. The conditions Income, including a pension, paid from the pub- China, People’s Republic of
under which the income is exempt are stated for lic funds of Barbados, or its political subdivisions
or local authorities, to a citizen of Barbados for Income, other than a pension, paid by the Peo-
each of the countries listed.
performing governmental functions is exempt ple’s Republic of China or its political subdivi-
from U.S. income tax. sions or local authorities to an individual for
Exemption under U.S. tax law. Employees of
However, this exemption does not apply to services performed for the paying governmental
foreign countries who do not qualify under a tax
payments for services in connection with a busi- body is exempt from U.S. income tax. However,
treaty provision and employees of international
ness carried on by Barbados or its political sub- the exemption does not apply to payments for
organizations should see if they can qualify for
divisions or local authorities. services performed in the United States by a
exemption under U.S. tax law.
resident of the United States who either:
If you work for a foreign government in the
United States, your foreign government salary is • Is a U.S. citizen, or
exempt from U.S. tax if you perform services Belgium
similar to those performed by U.S. government
• Did not become a U.S. resident only to
perform the services.
employees in that foreign country and that for-
Note. See the effective dates of the new
eign government grants an equivalent exemp-
treaty under What’s New at the beginning of this Pensions paid by the People’s Republic of
tion. If you work for an international organization
publication. China for services performed for China are ex-
in the United States, your salary from that
empt from U.S. income tax unless the recipient
source is exempt from U.S. tax. See chapter 10
New treaty. Wages, salaries, and similar in- is both a citizen and a resident of the United
of Publication 519 for more information.
come, other than a pension, paid by Belgium, its States.
political subdivisions, or local authorities to an These exemptions do not apply to income or
individual for services performed for the paying pensions for services performed in connection
Australia governmental body is exempt from U.S. income with a business carried on by the People’s Re-
Salaries, wages, and similar income, including tax. However, the exemption does not apply if public of China or its subdivisions or local au-
pensions, paid by Australia, its political subdivi- the services are performed in the United States thorities.
sions, agencies, or authorities to its citizens by a resident of the United States who either:
(other than U.S. citizens) for performing govern- • Is a U.S. national, or
mental functions as an employee of any of the Commonwealth of
above entities are exempt from U.S. income tax. • Did not become a U.S. resident only to Independent States (C.I.S.)
Wages, salaries, and similar income paid by the
Austria Pensions paid by, or out of funds created by, C.I.S. or a member of the C.I.S. to its citizens for
Belgium, its political subdivisions, or local au- personal services performed as an employee of
Wages, salaries, similar income, and pensions thorities for services performed for Belgium, its a governmental agency or institution of the
and annuities paid from public funds of Austria, political subdivisions, or local authorities to an C.I.S. or a member of the C.I.S. (excluding local
its political subdivisions, or its local authorities, individual for services performed for the paying government employees) in the discharge of gov-
to citizens of Austria for performing governmen- governmental body are exempt from U.S. in- ernmental functions are exempt from U.S. in-
tal functions as an employee are exempt from come tax unless the recipient is both a resident come tax. For this purpose, persons engaged in
U.S. tax. and national of the United States. commercial activities are not considered en-
However, this exemption does not apply to However, these exemptions do not apply to gaged in the discharge of governmental func-
payments for services performed in connection payments for services performed in connection tions.

Cyprus Estonia Treaty as modified. Wages, salaries, and

similar income, other than a pension, paid by
Wages, salaries, and similar income, including Income, other than a pension, paid by or from Germany, its political subdivisions, local authori-
pensions, annuities, and similar benefits, paid public funds of Estonia, its political subdivisions, ties, or instrumentalities to an individual for serv-
from public funds of Cyprus to a citizen of Cy- or local authorities to an individual for services ices performed for the paying governmental
prus for labor or personal services performed as performed as an employee for the paying gov- body is exempt from U.S. income tax. However,
an employee of Cyprus in the discharge of governmental body in the discharge of governmen- the exemption does not apply if the services are
ernmental functions are exempt from U.S. in- tal functions is exempt from U.S. income tax. performed in the United States by a resident of
However, the exemption does not apply if the the United States who either:
come tax.
services are performed in the United States by a • Is a U.S. national, or
Czech Republic • Did not become a U.S. resident only to
• Is a U.S. citizen, or perform the services.
Income, including a pension, paid from the pub- • Did not become a U.S. resident only to
lic funds of the Czech Republic, its political sub- perform the services. Pensions paid by, or out of funds created by,
divisions, or local authorities to a Czech citizen Germany, its political subdivisions, local authori-
Pensions paid by or from the public funds of ties, or instrumentalities for services performed
for services performed in the discharge of gov-
Estonia, its political subdivisions, or local author- for the paying governmental body are exempt
ernmental functions is exempt from U.S. income from U.S. income tax unless the recipient is both
tax. This exemption does not apply to income ities for services performed for Estonia are ex-
empt from U.S. income tax unless the recipient a resident and a national of the United States.
paid for services performed in connection with a This exemption does not apply to income or
is both a resident and citizen of the United
business carried on by the Czech Republic, its pensions for services performed in connection
States.
political subdivisions, or local authorities. with a business carried on by Germany, its politi-
cal subdivisions, local authorities, or instrumen-
Finland talities.
Denmark
Income, other than a pension, paid by Finland, Unmodified treaty. Wages, salaries, and sim-
Income, other than a pension, paid from public ilar income and pensions paid by Germany, its
its political subdivisions, statutory bodies, or lo-
funds of Denmark, its political subdivisions, or Laender, or municipalities, or their public pen-
cal authorities to an individual for services per-
local authorities to an individual for services per- sion funds are exempt from U.S. income tax if
formed for the paying governmental body is
formed for the paying governmental body in the paid to individuals other than U.S. citizens and
exempt from U.S. income tax. However, the
discharge of governmental functions is exempt other than individuals admitted to the United
exemption does not apply to payments for serv-
from U.S. income tax. However, the exemption States for permanent residence.
ices performed in the United States by a U.S.
does not apply if the services are performed in resident who either:
the United States by a resident of the United
States who either:
• Is a U.S. citizen, or Greece
• Is a U.S. national, or • Did not become a U.S. resident only to Wages, salaries, and similar income and pen-
perform the services. sions paid by Greece or its subdivisions to indi-
• Did not become a U.S. resident only to viduals living in the United States for services
perform the services. Pensions paid by Finland for services per- rendered to Greece or its subdivisions are ex-
formed for Finland are exempt from U.S. income empt from U.S. income tax. This exemption
Pensions paid from the public funds of Den- tax unless the recipient is a resident and citizen does not apply to citizens of the United States or
mark, its political subdivisions, or local authori- of the United States. alien residents of the United States.
ties for services performed for Denmark are These exemptions do not apply to income or
exempt from U.S. income tax unless the recipi- pensions for services performed in connection
ent is a resident and a national of the United with a trade or business carried on by Finland or Hungary
States. its political subdivisions, statutory bodies, or lo- Income (other than a pension) paid by the Re-
These exemptions do not apply to income or cal authorities. public of Hungary or its political subdivisions for
pensions for services performed in connection labor or personal services performed for the
with a trade or business carried on by Denmark, paying governmental body is exempt from U.S.
France tax. However, the exemption does not apply to
its political subdivisions, or local authorities.
Income, including pensions, paid by the French payments for services performed in the United
Government or a local authority thereof to an States by a resident of the United States who
Egypt either:
individual in the United States for services per-
Wages, salaries, and similar income, including
formed for France (or for a local authority of • Is a U.S. citizen, or
France) in the discharge of governmental func-
pensions, annuities, and similar benefits, paid • Did not become a resident of the United
tions is exempt from U.S. tax. This exemption
from public funds of the Arab Republic of Egypt States only to perform the services.
does not apply to a person who is both a resi-
to a citizen of Egypt (or to a citizen of another dent and citizen of the United States and not a
country who comes to the United States specifi- Pensions paid by Hungary for services per-
French national. formed for Hungary are exempt from U.S. in-
cally to work for the Government of Egypt) for This exemption does not apply to any income tax unless the recipient is both a citizen
labor or personal services performed as an em- come or pensions paid because of services (or and a resident of the United States.
ployee of the national Government of Egypt, or past services) performed in connection with a These exemptions do not apply to income or
any of its agencies, in the discharge of govern- business carried on by the French Government pensions for services performed in connection
mental functions are exempt from U.S. income (or a local authority thereof). with a trade or business carried on by Hungary
tax. or its subdivisions.
This exemption does not apply to U.S. citi-
zens or to alien residents of the United States. Germany
The exemption also does not apply to payments
Iceland
for services performed in connection with a Note. See the effective dates of the protocol Wages, salaries, and similar income, including
trade or business carried on by Egypt or any of under What’s New at the beginning of this publi- pensions and similar benefits, paid by or from
its agencies. cation. public funds of the Republic of Iceland, a political

subdivision, or a local authority to a citizen of with a business carried on by Ireland or its subdi- governmental body is exempt from U.S. income
Iceland (other than a U.S. citizen or one admit- visions or local authorities. tax. However, the exemption does not apply if
ted to the United States for permanent resi- the services are performed in the United States
dence) for labor or personal services performed by a resident of the United States who either:
for Iceland or its political subdivisions or local Israel
authorities in the discharge of governmental
• Is a U.S. citizen, or
functions are exempt from U.S. tax. Wages, salaries, and similar income, including • Did not become a U.S. resident only to
pensions and similar benefits, paid from public perform the services.
funds by the national government of Israel or its
India agencies, for services performed in the dis- Pensions paid by, or out of funds to which
charge of governmental functions, are exempt contributions are made by, Japan, its political
Income, other than a pension, paid by India, its from U.S. income tax. This exemption does not subdivisions, or local authorities for services
political subdivisions, or local authorities to an apply to citizens of the United States or alien performed for Japan are exempt from U.S. in-
individual for services performed for the paying residents of the United States.
come tax unless the recipient is a resident and
governmental body is exempt from U.S. income
citizen of the United States.
tax. However, the exemption does not apply if
the services are performed in the United States Italy These exemptions do not apply to income or
by a U.S. resident who either: pensions for services performed in connection
Income, other than a pension, paid by Italy or by with a business carried on by Japan, its political
• Is a U.S. citizen, or an Italian political or administrative subdivision subdivisions, or local authorities.
• Did not become a U.S. resident only to or local authority to an individual for services
perform the services. performed for the paying governmental body is
exempt from U.S. income tax. However, the Kazakhstan
Pensions paid by India for services performed exemption does not apply to payments for serv-
ices performed in the United States by a resident Income, other than a pension, paid by Kazakh-
for India are exempt from U.S. tax unless the
of the United States who either: stan, or its subdivisions or local authorities to an
individual is both a resident and citizen of the
individual for government services is exempt
United States. • Is a U.S. citizen, or from U.S. tax. However, the exemption does not
These exemptions do not apply to income or
pensions for services performed in connection • Did not become a U.S. resident only to apply if the services are performed in the United
perform the services. States by a U.S. resident who either:
with a business carried on by India, its subdivi-
sions, or local authorities. The spouse and dependent children of an indi- • Is a U.S. citizen, or
vidual, however, are not subject to the second • Did not become a U.S. resident solely for
restriction if that individual is receiving exempt the purpose of performing the services.
Indonesia income for governmental services performed for
Italy and that individual does not come under These exemptions do not apply to income for
Income, other than a pension, paid by Indone- services performed in connection with a busi-
either of the restrictions.
sia, its political subdivisions, or local authorities ness.
to an individual for services performed for the Pensions paid by Italy for services performed
paying governmental body is exempt from U.S. for Italy are exempt from U.S. income tax unless Pensions paid by Kazakhstan, or its subdivi-
income tax. However, the exemption does not the recipient is both a citizen and a resident of sions or local authorities for services performed
apply if the services are performed in the United the United States. for Kazakhstan is exempt from U.S. tax unless
States by a U.S. resident who either: These exemptions do not apply to income or the individual is both a resident and citizen of the
pensions for services performed in connection United States.
• Is a U.S. citizen, or
with a trade or business carried on by Italy or its
• Did not become a U.S. resident only to subdivisions or local authorities.
perform the services. Korea, Republic of
Pensions paid by Indonesia for services per- Jamaica Wages, salaries, and similar income, including
formed for Indonesia are exempt from U.S. tax. pensions and similar benefits, paid from public
These exemptions do not apply to income or Income, other than a pension, paid by the Gov- funds of the Republic of Korea to a citizen of
pensions for services performed in connection ernment of Jamaica or its political subdivisions Korea (other than a U.S. citizen or an individual
with a trade or business carried on by Indonesia, or local authorities for personal services per- admitted to the United States for permanent
its subdivisions, or local authorities. formed for the paying governmental body is ex- residence) for services performed as an em-
empt from U.S. income tax. ployee of Korea discharging government func-
This exemption does not apply to payments tions are exempt from U.S. income tax.
Ireland for services performed in the United States by
an individual who is a citizen and resident of the
Income, other than a pension, paid by Ireland or United States. Latvia
its political subdivisions or local authorities to an Pensions paid by Jamaica for services per-
individual for services performed for the paying formed for Jamaica generally are exempt from Income, other than a pension, paid by or from
governmental body is exempt from U.S. income U.S. income tax. However, if the recipient of the public funds of Latvia, its political subdivisions,
tax. However, the exemption does not apply to pension is a citizen and resident of the United or local authorities to an individual for services
payments for services performed in the United States and was a U.S. citizen at the time the performed as an employee for the paying gov-
States by a resident of the United States who services were performed, the pension is taxable ernmental body in the discharge of governmen-
either: in the United States. tal functions is exempt from U.S. income tax.
However, the exemption does not apply if the
• Is a U.S. citizen, or These exemptions do not apply to income or
services are performed in the United States by a
• Did not become a U.S. resident only to with a trade or business carried on by Jamaica resident of the United States who either:
perform the services. or its subdivisions or local authorities. • Is a U.S. citizen, or
Pensions paid by Ireland for services per- • Did not become a U.S. resident only to
formed for Ireland are exempt from U.S. income Japan perform the services.
tax unless the recipient is both a resident and
citizen of the United States. Income, other than a pension, paid by Japan, its Pensions paid by or from the public funds of
These exemptions do not apply to income or political subdivisions, or local authorities to an Latvia, its political subdivisions, or local authori-
pensions for services performed in connection individual for services performed for the paying ties for services performed for Latvia are exempt

from U.S. income tax unless the recipient is both These exemptions do not apply to income or authorities in the discharge of governmental
a resident and citizen of the United States. pensions connected with commercial or indus- functions are exempt from U.S. income tax.
trial activities carried on by Mexico, its political
subdivisions, or local authorities.
Lithuania Pakistan
Income, other than a pension, paid by or from Morocco Income, including pensions and annuities, paid
public funds of Lithuania, its political subdivi- to certain individuals by or on behalf of the Gov-
sions, or local authorities to an individual for Wages, salaries, and similar income, including ernment of Pakistan or the Government of a
services performed as an employee for the pay- pensions and similar benefits, paid from public Province in Pakistan or one of its local authori-
ing governmental body in the discharge of gov- funds of the Kingdom of Morocco to a citizen of ties for services performed in the discharge of
ernmental functions is exempt from U.S. income Morocco (other than a U.S. citizen or an individ- functions of that Government or local authority is
tax. However, the exemption does not apply if ual admitted to the United States for permanent exempt from U.S. income tax. To be exempt
the services are performed in the United States residence) for labor or personal services per- from tax, these payments must be made to citi-
by a resident of the United States who either: formed for Morocco or for any of its political
zens of Pakistan who do not have immigrant
subdivisions or local authorities in the discharge
• Is a U.S. citizen, or of governmental functions are exempt from U.S.
status in the United States. This exemption does
not apply to payments for services performed in
• Did not become a U.S. resident only to income tax.
perform the services. connection with any trade or business carried on
for profit.
Pensions paid by or from the public funds of Netherlands
Lithuania, its political subdivisions, or local au-
thorities for services performed for Lithuania are Income, other than a pension, paid by the Philippines
exempt from U.S. income tax unless the recipi- Netherlands, its political subdivisions, or local
authorities to an individual for services per- Wages, salaries, and similar income, including
ent is both a resident and citizen of the United
formed for the paying governmental body is ex- pensions, annuities, and similar benefits, paid
States.
empt from U.S. income tax. However, the from public funds of the Republic of the Philip-
exemption does not apply if the services are pines to a citizen of the Philippines (or to a
Luxembourg rendered in the United States and the individual citizen of another country other than the United
is a U.S. resident who either: States who comes to the United States specifi-
Income, other than a pension, paid by Luxem- cally to work for the Government of the Philip-
bourg, its political subdivisions, or local authori-
• Is a U.S. national, or pines) for labor or personal services performed
ties to an individual for services performed for • Did not become a U.S. resident solely for as an employee of the national Government of
the paying governmental body is exempt from the purpose of performing the services. the Philippines or any of its agencies in the
U.S. income tax. However, the exemption does discharge of governmental functions are exempt
not apply if the services are performed in the Pensions paid by the Netherlands for services from U.S. income tax.
United States by a resident of the United States performed for the Netherlands are exempt from
who either: U.S. income tax unless the individual is both a
• Is a U.S. citizen, or resident and national of the United States. Poland
These exemptions do not apply to income or
• Did not become a U.S. resident only to pensions for services performed in connection Wages, salaries, and similar income, including
perform the services. with a business carried on by the Netherlands, pensions, annuities, and similar benefits, paid
its political subdivisions, or local authorities. from public funds of Poland to a citizen of Poland
Pensions paid by Luxembourg, its political (other than a U.S. citizen or one admitted to the
subdivisions, or local authorities for services United States for permanent residence) for labor
performed for Luxembourg are exempt from New Zealand or personal services performed as an employee
U.S. income tax unless the recipient is both a of the national Government of Poland in the
resident and citizen of the United States. Income (other than pensions) paid by the Gov- discharge of governmental functions are exempt
These exemptions do not apply to income or ernment of New Zealand, its political subdivi- from U.S. income tax.
pensions for services performed in connection sions, or local authorities for services performed
with a trade or business carried on by Luxem- in the discharge of governmental functions is
bourg, its political subdivisions, or local authori- exempt from U.S. income tax. However, the Portugal
ties. income is not exempt if the services are per-
formed in the United States by a U.S. citizen Income, other than a pension, paid by Portugal,
resident in the United States or by a resident of its political or administrative subdivisions, or lo-
Mexico the United States who did not become a resident cal authorities to an individual for services per-
only to perform the services. formed for the paying governmental body is
Income, other than a pension, paid by Mexico, Pensions paid by New Zealand in considera- exempt from U.S. income tax. However, the
its political subdivisions, or local authorities to an tion for past governmental services are exempt exemption does not apply to payments for serv-
individual for services performed for the paying from U.S. income tax unless paid to U.S. citizens ices performed in the United States by a U.S.
governmental body is exempt from U.S. income resident in the United States. resident who either:
tax. However, the exemption does not apply if These exemptions do not apply to payments
the services are performed in the United States for services performed in connection with any • Is a U.S. national, or
by a U.S. resident who either: trade or business carried on for profit by the • Did not become a U.S. resident only to
• Is a U.S. national, or Government of New Zealand (or its subdivisions perform the services.
or local authorities).
• Did not become a resident of the United
Pensions paid by Portugal for services per-
States solely for purposes of performing
formed for Portugal are exempt from U.S. in-
the services. Norway come tax unless the recipient is a resident and
Pensions paid by Mexico, its political subdivi- Wages, salaries, and similar income, including national of the United States.
sions, or local authorities for services performed pensions and similar benefits paid by or from These exemptions do not apply to income or
for the paying governmental body are exempt public funds of Norway or its political subdivi- pensions for services performed in connection
from U.S. income tax unless the individual is sions or local authorities to a citizen of Norway with a business carried on by Portugal or its
both a resident and national of the United for labor or personal services performed for Nor- political or administrative subdivisions, or local
States. way or any of its political subdivisions or local authorities.

Romania South Africa • Did not become a U.S. resident solely for
the purpose of performing the services.
Wages, salaries, and similar income, including Income, other than a pension, paid by South
pensions, annuities, and similar benefits, paid Africa or its political subdivisions or local authori- Pensions paid by Sweden, its political subdivi-
from public funds of Romania to a citizen of ties to an individual for services performed for sions, or local authorities for services performed
Romania (other than a U.S. citizen or one admit- the paying governmental body is exempt from for Sweden are exempt from U.S. tax unless the
ted to the United States for permanent resi- U.S. income tax. However, the exemption does individual is both a resident and citizen of the
dence) for labor or personal services performed not apply to payments for services performed in
United States.
as an employee of the national Government of the United States by a resident of the United
Romania in the discharge of governmental func- States who either: These exemptions do not apply to income or
tions are exempt from U.S. income tax. pensions for services performed in connection
• Is a U.S. citizen, or with a business carried on by Sweden, its politi-
• Did not become a U.S. resident only to cal subdivisions, or local authorities.
Russia perform the services.
Income, other than a pension, paid by Russia, its Pensions paid by South Africa for services Switzerland
republics, or local authorities to an individual for performed for South Africa are exempt from U.S.
government services is exempt from U.S. tax. income tax unless the recipient is both a resident Income, other than a pension, paid by Switzer-
However, the exemption does not apply if the and citizen of the United States. land or its political subdivisions or local authori-
services are performed in the United States by a ties to an individual for services performed for
U.S. resident who either: These exemptions do not apply to income or
the paying governmental body is exempt from
• Is a U.S. citizen, or U.S. income tax. However, the exemption does
with a business carried on by South Africa or its
not apply to payments for services performed in
• Did not become a U.S. resident solely for subdivisions or local authorities.
the United States by a resident of the United
the purpose of performing the services. States who either:
Pensions paid by Russia, its republics, or lo- Spain • Is a U.S. citizen, or

cal authorities for services performed for Russia Income, other than a pension, paid by Spain, its • Did not become a U.S. resident only to
are exempt from U.S. tax unless the individual is political subdivisions, or local authorities to an perform the services.
both a resident and citizen of the United States. individual for services performed for the paying
These exemptions do not apply to income or governmental body is exempt from U.S. income Pensions paid by Switzerland for services
pensions for services performed in connection tax. However, the exemption does not apply to performed for Switzerland are exempt from U.S.
with a business. payments for services performed in the United income tax unless the recipient is both a resident
States by a resident of the United States who and citizen of the United States.
either:
Slovak Republic These exemptions do not apply to income or
• Is a U.S. citizen, or pensions for services performed in connection
Income, including a pension, paid from the pub- with a business carried on by Switzerland or its
lic funds of the Slovak Republic, its political • Did not become a U.S. resident only to
perform the services. subdivisions or local authorities.
subdivisions, or local authorities to a Slovak
citizen for services performed in the discharge of
governmental functions is exempt from U.S. in- Pensions paid by Spain, its political subdivi-
sions, or local authorities for services performed Thailand
come tax. This exemption does not apply to
income paid for services performed in connec- for Spain are exempt from U.S. tax unless the Income, other than a pension, paid by Thailand
tion with a business carried on by the Slovak individual is both a citizen and resident of the or its political subdivisions or local authorities to
Republic, its political subdivisions, or local au- United States.
an individual for services performed for the pay-
thorities. These exemptions do not apply to income or ing governmental body is exempt from U.S. in-
pensions for services performed in connection come tax. However, the exemption does not
with a trade or business carried on by Spain, its apply to payments for services performed in the
Slovenia subdivisions, or local authorities. United States by a resident of the United States
who either:
Income, other than a pension, paid from public
funds of Slovenia, its political subdivisions, or Sri Lanka • Is a U.S. citizen, or
local authorities to an individual for services per-
formed for the paying governmental body in the Income, including a pension, paid from the pub- • Did not become a U.S. resident only to
discharge of governmental functions is exempt lic funds of Sri Lanka, its political subdivisions, or perform the services.
from U.S. income tax. However, the exemption local authorities to a citizen or national of Sri
does not apply if the services are performed in Lanka for services performed for Sri Lanka in the Pensions paid by Thailand for services per-
the United States by a resident of the United discharge of functions of a governmental nature formed for Thailand are exempt from U.S. in-
States who either: is exempt from U.S. income tax. This exemption come tax unless the recipient is both a resident
does not apply to income paid for services per- and citizen of the United States.
• Is a U.S. citizen, or formed in connection with a business carried on These exemptions do not apply to income or
• Did not become a U.S. resident only to by Sri Lanka, its political subdivisions, or local pensions for services performed in connection
perform the services. authorities. with a business carried on by Thailand or its
subdivisions or local authorities.
Pensions paid from the public funds of Slove-
nia, its political subdivisions, or local authorities Sweden
for services performed for Slovenia in the dis- Trinidad and Tobago
charge of governmental functions are exempt Income, other than a pension, paid by Sweden,
from U.S. income tax unless the recipient is both its political subdivisions, or local authorities to an Wages, salaries, and similar income and pen-
a resident and citizen of the United States. individual for services performed for the paying sions, annuities, and similar benefits paid by or
governmental body is exempt from U.S. income from the public funds of the Government of Trini-
tax. However, the exemption does not apply if dad and Tobago to a national of that country for
the services are performed in the United States services performed for Trinidad and Tobago in
by a U.S. resident who either:
the discharge of governmental functions are ex-
• Is a U.S. citizen, or empt from U.S. tax.

Tunisia subdivisions, or local authorities to an individual rents, and royalties. The income code numbers
for services performed for the paying govern- shown in this table are the same as the income
Income, other than a pension, paid by Tunisia, mental body is exempt from U.S. income tax. codes on Form 1042-S, Foreign Person’s U.S.
its political subdivisions, or local authorities to a However, the exemption does not apply if the Source Income Subject to Withholding.
Tunisian citizen for personal services performed
services are performed in the United States by a
in the discharge of governmental functions is Interest. If you are a nonresident alien who
exempt from U.S. income tax. receives interest that is not effectively con-
Pensions paid by Tunisia, its political subdi- • Is a U.S. citizen, or nected with the conduct of a U.S. trade or busi-
visions, or local authorities for services per-
• Did not become a U.S. resident only to ness, you do not include the interest in income if
formed for Tunisia are exempt from U.S. income it is paid on deposits with banks, on accounts or
tax unless the recipient is a U.S. citizen. deposits with certain financial institutions, or on
These exemptions do not apply to income or certain amounts held by insurance companies.
Pensions paid by, or funds created by, the
pensions for services performed in connection These amounts are exempt from U.S. tax even
United Kingdom, its political subdivisions, or lo-
with a trade or business carried on by Tunisia, its though they are considered to be income from a
political subdivisions, or local authorities. cal authorities for services performed for the
United Kingdom are exempt from U.S. income U.S. source. Also exempt from U.S. tax (al-
tax unless the recipient is both a resident and though considered from U.S. sources) is certain
citizen of the United States. portfolio interest on obligations issued after July
Turkey 18, 1984. See Publication 519 for more informa-
These exemptions do not apply to income or tion.
Income, other than a pension, paid by Turkey or
its political subdivisions or local authorities to an
with a business carried on by the United King-
individual for services performed for the paying
dom, its political subdivisions, or local authori-
Table 2
governmental body is exempt from U.S. income
tax. However, the exemption does not apply to ties. This table lists the different kinds of personal
payments for services performed in the United service income that may be fully or partly ex-
States by a resident of the United States who empt from U.S. income tax. You must meet all of
either:
Venezuela the treaty requirements before the item of in-
come can be exempt from U.S. income tax. The
• Is a U.S. citizen, or Income, other than a pension, paid by Vene-
income code numbers shown in this table are
zuela, its political subdivisions, or local authori-
• Did not become a U.S. resident only to ties to an individual for services performed for
the same as the income codes on Form 1042-S,
perform the services. Foreign Person’s U.S. Source Income Subject
the paying governmental body is exempt from
to Withholding.
U.S. income tax. However, the exemption does
Pensions paid by Turkey for services per-
formed for Turkey are exempt from U.S. income not apply to payments for services performed in
Independent personal services. The term
tax unless the recipient is both a resident and the United States by a resident of the United “independent personal services” generally
citizen of the United States. States who either: means services you perform for your own ac-
These exemptions do not apply to income or • Is a U.S. citizen, or count if you receive the income and bear the
pensions for services performed in connection losses arising from those services. Examples of
with a business carried on by Turkey or its subdi- • Did not become a U.S. resident only to these services are those provided by physi-
visions or local authorities. perform the services. cians, lawyers, engineers, dentists, and ac-
countants who perform personal services as
Pensions paid by Venezuela, its political sub- sole proprietors or partners.
Ukraine divisions, or local authorities for services per-
formed for Venezuela are exempt from U.S. Dependent personal services. Dependent
Income, other than a pension, paid from public income tax unless the recipient is both a resident personal services usually are those you perform
funds of Ukraine, its political subdivisions, or and citizen of the United States. for someone else as an employee.
local authorities to an individual for services per-
These exemptions do not apply to payments
formed in the discharge of governmental func-
tions is exempt from U.S. income tax. However, or pensions for services performed in connec- Table 3
the exemption does not apply if the services are tion with a business carried on by Venezuela, its
performed in the United States by a resident of political subdivisions, or local authorities. This table lists the countries that have tax trea-
the United States who either: ties with the United States. Some treaties are
published in the Cumulative Bulletins (C.B.),
• Is a U.S. citizen, or which contain official matters of the Internal
• Did not become a U.S. resident only to Explanation Revenue Service. The column headed Citation
perform the services. shows the number of the C.B. and the page on
of Tables which a particular treaty may be found.
Regulations implementing some treaties
Pensions paid by, or by funds created by,
Ukraine, its political subdivisions, or local au- The paragraphs below describe the tables that were issued as Treasury Decisions (T.D.). Other
thorities for services performed for Ukraine are follow and provide additional information that treaties are explained by Treasury explanation.
exempt from U.S. income tax unless the recipi- may make the tables more useful to you. Be- The fifth column lists the T.D. numbers and the
ent is both a resident and citizen of the United cause there is an effective date election avail- C.B. in which each T.D. or Treasury explanation
States. is printed.
able for the new treaty with Belgium and the
These exemptions do not apply to income or You can buy volumes of the C.B. from the
protocol with Germany, two entries are shown
pensions for services performed in connection Government Printing Office or you are welcome
for those countries. The effective date of these
with a trade or business carried on by Ukraine, to read them in most Internal Revenue Service
items is shown under What’s New at the begin-
its political subdivisions, or local authorities. offices. Many public libraries and business orga-
ning of this publication.
nizations subscribe to a commercial tax service
that publishes the treaties and regulations or
United Kingdom Table 1 explanations.
Income, other than a pension, paid from the This table lists the income tax rates on such
public funds of the United Kingdom, its political income as interest, dividends, capital gains,

Page 34
Table 1. Tax Rates on Income Other Than Personal Service Income Under Chapter 3, Internal Revenue Code, and Income Tax Treaties
Income Code Number 1 2 3 6 7 9 10 11 12 13 14 21
Country of Residence of Payee Dividends Copyright Royalties
Real
Interest Property
Interest Paid to a Paid by Income
Paid by Interest Controlling U.S. Qualifying Motion and
U.S. on Real Foreign Corpora- for Direct Pictures Natural Pensions Social
Obligors Property Corpora- tions— Dividend Capitalv Industrial and Resourcesv and Security
Name Code General Mortgages tion Generala Ratea,b Gains Royalties Television Other Royalties Annuities Payment u
g,tt,uu g,ff,tt,uu g,tt,uu g,pp g,pp,xx g g g d
Australia AS 10
g,m
10
g,m,ff
10
g,m
15
g,x
5
g,x
30
g,l
0 g g
5 5 g
30 0 30
Austria AU 0 0 0 15 5 0 0 10 0 30 0 30
g,m,yy g,m,ff,yy g,m,yy g,pp g,pp g,hh g g g d,f,q
Bangladesh BG 10 10 10 15 10 0 10 10 10 30 0 30
g g g g,x g,x g,l g g g d,f
Barbados BB 5 5 5 15 5 0 5 5 5 30 0 30
g g g g g g,l g h g d,f
Belgium (old treaty) BE 15 15 15 15 5 0 0 0 0 30 0 30
g,m g,m,ff g,m g,zz,ab g,xx,zz,ab g,l g g g d,f
Page 34 of 52 of Publication 901
Belgium (new treaty) BE 15 15 15 15 5 0 0 0 0 30 0 30

g g,ff g g, x g,x r g g g
Canada CA g
10
g
10
g
10
g
15 5 30 0 10 0 30 15 0
g g,w g g d, mm
China, People’s Rep. of CH 10 10 10 10 10 30 10 10 10 30 0 30
Commonwealth of
n o
Independent States 0 30 30 30 30 0 0 0 0 30 30 30
g g g g g g,l g g g d,f
Cyprus CY 10 10 10 15 5 0 0 0 0 30 0 30
g g,ff g g,x g,x g,l g g g d,f
Czech Republic EZ 0 0 0 15 5 0 10 0 0 30 0 30
g,oo g,ff,oo g,oo g,zz,ab g,xx,zz,ab g g g g d,mm,ss
Denmark DA 0 0 0 15 5 0 0 0 0 30 30 30
h h h h h,l h h g d,f
Egypt EG 15 30 15 15 5 0 0 0 15 30 0 0
g,oo g,ff,oo g,oo g,x g,x g,l g,bb g g d,f
Estonia EN 10 10 10 15 5 0 5 10 10 30 d,f
0 30
g,oo g,ff,oo g,oo g,zz,ab g,xx,zz,ab g,l g g g
Finland FI 0 0 0 15 5 0 0 0 0 30 0 30
g g,ff g b,g,pp g,x g,l g g g d 30
France FR 0 0 0 15 5 0 5 0 0 30 30
g g g g,x g,x g,l g g,dd g d
Germany GM 0 0 0 15 5 0 0 0 0 30 0 0
g,m g,m,ff g,m g,zz,ab g,xx,zz,ab g,l g g,dd g d,f
Germany (as modified) GM 0 0 0 15 5 0 0 0 0 30 0 0
h h h h d
Greece GR 0 0 30 30 30 30 0 30 0 30 0 30
Hungary HU 0 0 0 15 5 0 0 0 0 30 0 30
g g g g g g,l g g d,f
Iceland IC 0 0 0 15 5 0 0 30 0 30 0 30
g,aa g,aa g,aa g,x g,x g,bb g g d,f ee
India IN 15 15 15 25 15 30 10 15 15 30 0 30
g g g g g g,l,z g,bb g g d,f,q
Indonesia ID 10 10 10 g,pp
15 10 0 10 10 10 30 15 30
g g,ff g g,pp g,l g g g d,f
Ireland EI 0 0 0 15 5 0 0 0 0 30 0 0
g,aa,ii g,aa,ff,ii g,aa,ii g,x g,x g,cc g g g f
Israel IS 171⁄2 171⁄2 171⁄2 25 121⁄2 0 15 10 10 30 0 0
g g g g e,g g,l g,s g g d,f
Italy IT 15 15 15 15 5 0 10 8 5 30 0 0
g g g g g g,l g g g d,f,p
Jamaica JM 121⁄2 121⁄2 121⁄2 15 10 0 10 10 10 30 0 30
g,ww,zz,ac g,ff,ww,zz,ac g,ww,zz,ac g,w,zz,ab e,g,ww,zz,ab g,l g,ww g,ww g,ww d
Japan JA 10 10 10 10 5 0 0 0 0 30 0 0
g g,ff g g,gg g,gg g,l g,jj g g d,f
Kazakhstan KZ 10 10 10 15 5 0 10 10 10 30 0 30
Korea, Rep. of KS 12 12 12 15 10 0 15 10 10 30 0 30
Latvia LG 10 10 10 15 5 0 5 10 10 30 0 30
Lithuania LH 10
g,h
10
g,ff,h
10
g,h g,x
15 5 0 5 10 10 30 0 30
g,x g g g g d
Luxembourg LU 0 0 0 15 5 0 0 0 0 30 0 30
g,qq g,ff,qq g g,pp,vv g,pp,vv,xx g,l g g g d
Mexico MX 15 15 15 10 5 0 10 10 10 30 0 30
g g g g g g,l h g g d,f
Morocco MO 15 15 15 15 10 0 10 10 10 30 0 30
g g g g g g,hh g g,dd g d,f,t
Netherlands NL 0 0 0 15 5 0 0 0 0 30 0 30
g g g g g g,l g g g d
New Zealand NZ 10 10 10 15 15 0 10 10 10 30 0 30
g g g g g g,l g h g d,f
Norway NO 0 0 0 15 15 0 0 0 0 30 0 30
Publication 901 (April 2008)

12:36 - 23-APR-2008
Table 1. Tax Rates on Income Other Than Personal Service Income Under Chapter 3, Internal Revenue Code, and Income Tax Treaties
Income Code Number 1 2 3 6 7 9 10 11 12 13 14 21
Country of Residence of Payee Dividends Copyright Royalties
Real
Interest Property
Interest Paid to a Paid by Income
Paid by Interest Controlling U.S. Qualifying Motion and

U.S. on Real Foreign Corpora- for Direct Pictures Natural Pensions Social
Obligors Property Corpora- tions— Dividend Capitalv Industrial and Resourcesv and Security
Name Code General Mortgages tion Generala Ratea,b Gains Royalties Television Other Royalties Annuities Payment u
h h h d,j
Pakistan PK 30 30 30 30 15 30 0 30 0 30 0 30
g g g g g g,l g g g q
Philippines RP 15 15 15 25 20 0 15 15 15 30 30 30
g g g g g g,l g g g
Poland PL 0 0 0 15 5 0 10 10 10 30 30 30
g g,ff g g,x g,x g,l g g g d,f
Portugal PO 10 10 10 15 5 0 10 10 10 30 0 30
Romania RO 10 10 10 10 10 0 15 10 10 30 0 0
g g,ff g g,gg g,gg g,l g g g d
Russia RS g
0
g,ff
0
g
0
g,x
10 5 0 0 0 0 30 0 30
g,x g,l g g g d,f
Slovak Republic LO 0 0 0 15 5 0 10 0 0 30 0 30
g g,ff g g,pp g,pp g g g g d,f
Slovenia SI 5 5 5 15 5 0 5 5 5 30 0 30
g,m g,m,ff g,m g,x g,x l g g g d,kk
South Africa SF g
0
g
0
g
0
g,x
15 5 0 0 0 0 30 15 30
g,x g,l g,y g,y g,y d,f
Spain SP 10 10 10 15 10 0 8 8 5 30 0 30
g,m10 g,m,ff10 g,m10 g,rr15 g,rr15 g,hh0 g g
Sri Lanka CE 0 10 g,s10 30 d,mm0 30
g g,ff g g,zz,ab g,l g g g d
Sweden SW 0 0 0 15 g,xx,zz,ab5 0 0 0 0 30 0 30
g,m g,m,ff g,m g,x g,x l g g g d
Switzerland SZ 0 0 0 15 5 0 0 0 0 30 0 15
g,aa g,aa,ff g,aa g,x g,x bb ll d,f
Thailand TH 15 15 15 15 10 30 8 5 15 30 0 30
g g d,f
Trinidad & Tobago TD 30 30 30 30 30 30 15 30 0 30 0 30
g g g g,x g,x g,l g,bb g g f
Tunisia TS 15 15 15 20 14 0 10 15 15 30 0 30
g,i,aa g,i,aa,ff g,i,aa g,x g,x g,l bb d
Turkey TU 15 15 15 20 15 0 5 10 10 30 0 30
g g,ff g g,gg g,gg g g g g d
Ukraine UP 0 0 0 15 5 0 10 10 10 30 0 30
g,oo,ww g,ff,oo,ww g,oo,ww g,pp,ww g,pp,ww,xx g g,ww g,ww g,ww d,f
United Kingdom UK 0 0 0 15 5 0 0 0 0 30 0 0
g,nn,oo g,ff,nn,oo g,ff,nn,oo g,pp g,l g,bb g g d,mm
Venezuela VE 10 10 10 15 g,pp5 0 5 10 10 30 0 30
Other Countries 30 30 30 30 30 30 30 30 30 30 30 30
Page 35
12:36 - 23-APR-2008
a l bb
Page 36
No U.S. tax is imposed on a dividend paid by a U.S. corporation that Exemption does not apply to gains from the sale of real property. This is the rate for royalties for the use of, or the right to use,
received at least 80% of its gross income from an active foreign However, for U.S. real property that was owned continuously industrial, commercial, and scientific equipment. The rate for
business for the 3-year period before the dividend is declared. since June 18, 1980, by a Netherlands resident, the taxable gain royalties for information concerning industrial, commercial and
b may be limited to the appreciation after 1984. For details, see
The reduced rate applies to dividends paid by a subsidiary to scientific know-how is subject to the rate in column 12.
Article 14(2) of the treaty. cc
a foreign parent corporation that has the required percentage The exemption does not apply to gain from the sale or other
m
of stock ownership. In some cases, the income of the subsidiary The rate is 15% (30% for Germany and Switzerland) for disposition of property described in Article 14(2)(c) (copyrights
must meet certain requirements (e.g., a certain percentage of contingent interest that does not qualify as portfolio interest. of literary, artistic, or scientific works).
its total income must consist of income other than dividends n dd
The exemption applies only to interest on credits, loans, and The exemption does not apply to cinematographic items, or
and interest). works on film, tape, or other means of reproduction for use in
c other indebtedness connected with the financing of trade
The exemption or reduction in rate applies only if the recipient between the United States and the C.I.S. member. It does not radio or television broadcasting.
is subject to tax on this income in the country of residence. ee
include interest from the conduct of a general banking business. U.S. social security benefits paid to individuals who are both
Otherwise, a 30% rate applies. o
d The exemption applies only to gains from the sale or other residents and nationals of India are exempt from tax if they are
Exemption does not apply to U.S. Government (federal, state, disposition of property acquired by gift or inheritance. for services performed for the United States, its subdivisions,
or local) pensions and annuities; a 30% rate applies to these p or local authorities.
The exemption does not apply if the recipient was a resident of ff
pensions and annuities. For this purpose, railroad retirement tier Exemption or reduced rate does not apply to an excess inclusion
the United States when the pension was earned or when the
2, dual, and supplemental benefits are not considered U.S. for a residual interest in a real estate mortgage investment
annuity was purchased.
Government pensions or annuities. U.S. Government pensions q conduit (REMIC).
paid to an individual who is both a resident and national of Annuities paid in return for other than the recipient’s services gg
are exempt. For Bangladesh, exemption does not apply to The rate in column 6 applies to dividends paid by a regulated
Bangladesh, Belgium, China, Denmark, Estonia, Finland, investment company (RIC). Dividends paid by a real estate
Germany, Hungary, India, Ireland, Italy, Latvia, Lithuania, annuity received for services rendered.
r investment trust (REIT) are subject to a 30% rate.
Luxembourg, Mexico, the Netherlands, Portugal, Russia, Generally, if the property was owned by the Canadian resident hh
The exemption does not apply to a sale of a U.S. company’s
Slovenia, South Africa, Spain, Switzerland, Thailand, Turkey, the on September 26, 1980, not as part of the business property
United Kingdom, or Venezuela are exempt from U.S. tax. U.S. of a permanent establishment or fixed base in the U.S., the stock representing ownership of 50% or more.
Government pensions paid to an individual who is both a taxable gain is limited to the appreciation after 1984. Capital ii
An election can be made to treat this interest income as if it
resident and citizen of Kazakstan, New Zealand, or Sweden are gains on personal property not belonging to a permanent were industrial and commercial profits taxable under article 8
exempt from U.S. tax. establishment or fixed base of the taxpayer in the U.S. are of the treaty.
e exempt. jj
For Italy, the reduced rate is 10% if the foreign corporation owns s If the payments were for the use of, or the right to use, industrial,
10% to 50% of the voting stock (for a 12-month period) of the The rate for royalties with respect to tangible personal property commercial, or scientific equipment, an election may be made
company paying the dividends. For Japan, dividends received is 7% (5% in the case of Sri Lanka). to compute the tax on a net basis as if such income were
t
from a more than 50% owned corporate subsidiary are exempt The exemption does not apply if (1) the recipient was a U.S. attributable to a permanent establishment or fixed base in the
if certain conditions are met. resident during the 5-year period before the date of payment, U.S.
f
Includes alimony. (2) the amount was paid for employment performed in the United kk
g
The reduced rate does not apply if the distribution is subject to
The exemption or reduction in rate does not apply if the recipient States, and (3) the amount is not a periodic payment, or is a a penalty for early withdrawal. Annuities that were purchased
has a permanent establishment in the United States and the lump-sum payment in lieu of a right to receive an annuity. while the annuitant was not a resident of the United States are
u
property giving rise to the income is effectively connected with Applies to 85% of the social security payments received from not taxable in the United States.
ll
this permanent establishment. Under certain treaties, exemption the U.S. Government. The effective rate on the total social The rate is 5% for royalties on the use of any copyright of literary,
or reduction in rate also does not apply if the property producing security payments received is 85% of the rate shown in the artistic, or scientific work, including software.
the income is effectively connected with a fixed base in the table. These rates also apply to the social security equivalent mm
Does not apply to annuities. For Denmark, annuities are exempt.
United States from which the recipient performs independent portion of tier 1 railroad retirement benefits (income code 22) nn
personal services. Even with the treaty, if the income is not received from the U.S. The remainder of tier 1, all of tier 2, dual, The rate is 4.95% if the interest is beneficially owned by a
effectively connected with a trade or business in the United and supplemental railroad retirement benefits (income code 23) financial institution (including an insurance company).
oo
States by the recipient, the recipient will be considered as not are taxed as shown in column 14, “Pensions and Annuities.” The rate is 15% for interest determined with reference to (a) receipts,
having a permanent establishment in the United States under v sales, income, profits or other cash flow of the debtor or a related
Gains on the disposition of U.S. real property interests are
Internal Revenue Code section 894(b). considered effectively connected with a U.S. trade or business person, (b) any change in the value of any property of the debtor
h or a related person, or (c) any dividend, partnership distribution, or
The exemption or reduction in rate does not apply if the recipient and thus are subject to graduated rates of tax rather than the
is engaged in a trade or business in the United States through flat percentage shown in this column. similar payment made by the debtor or related person.
pp
w The rate in column 6 applies to dividends paid by a regulated
a permanent establishment that is in the United States. Tax imposed on 70% of gross royalties for rentals of industrial,
However, if the income is not effectively connected with a trade commercial, or scientific equipment. investment company (RIC) or real estate investment trust (REIT).
or business in the United States by the recipient, the recipient x However, that rate applies to dividends paid by a REIT only if
The rate in column 6 applies to dividends paid by a regulated the beneficial owner of the dividends is (a) an individual holding
will be considered as not having a permanent establishment in
investment company (RIC) or a real estate investment trust not more than a 10% interest in the REIT, (b) a person holding
the United States to apply the reduced treaty rate to that item
(REIT). However, that rate applies to dividends paid by a REIT not more than 5% of any class of the REIT’s stock and the
of income.
i
only if the beneficial owner of the dividends is an individual dividends are paid on stock that is publicly traded, or (c) a
Contingent interest that does not qualify as portfolio interest is holding less than a 10% interest (25% in the case of Portugal,
treated as a dividend and is subject to the rate under column person holding not more than a 10% interest in the REIT and
Spain, and Tunisia) in the REIT. the REIT is diversified.
6 or 7. y
Royalties not taxed at the 5% or 8% rate are taxed at a 10% qq
j The rate is 4.9% for interest derived from (1) loans granted by
Exemption is not available when paid from a fund under an rate, unless footnote (g) applies.
employees’ pension or annuity plan, if contributions to it are z
banks and insurance companies and (2) bonds or securities that
The exemption does not apply if the recipient of the gain is an are regularly and substantially traded on a recognized securities
deductible under U.S. tax laws in determining taxable income
individual who is present in the United States for more than 119 market. The rate is 10% for interest not described in the
of the employer.
k days during the year. preceding sentence and paid (i) by banks or (ii) by the buyer of
Applies to 100% of the social security and other public pensions aa
The rate is 10% if the interest is paid on a loan granted by a machinery and equipment to the seller due to a sale on credit.
received from the U.S. government.
bank or similar financial institution. For Thailand, the 10% rate

also applies to interest from an arm’s length sale on credit of
equipment, merchandise, or services.

12:36 - 23-APR-2008
rr xx ab
The rate applies to dividends paid by a real estate investment Dividends received from an 80%-owned corporate subsidiary The rate in column 6 applies to dividends paid by a regulated
trust (REIT) only if the beneficial owner of the dividends is (a) an are exempt if certain conditions are met. investment company (RIC) or real estate investment trust (REIT).
individual holding less than a 10% interest in the REIT, (b) a However, that rate applies to dividends paid by a REIT only if
yy
person holding not more than 5% of any class of the REIT’s The rate is 5% for interest (a) beneficially owned by a bank or the beneficial owner of the dividends is (a) an individual or
stock and the dividends are paid on stock that is publicly traded, other financial institution (including an insurance company) or pension fund holding not more than a 10% interest in the
or (c) a person holding not more than a 10% interest in the REIT (b) paid due to a sale on credit of any industrial, commercial, REIT,(b) a person holding not more than 5% of any class of the
and the REIT is diversified. or scientific equipment, or of any merchandise to an enterprise. REIT’s stock and the dividends are paid on stock that is publicly
ss zz
traded, or (c) a person holding not more than a 10% interest in
Generally, if the person was receiving pension distributions Amounts paid to a pension fund that are not derived from the the REIT and the REIT is diversified. Dividends paid to a pension
before March 31, 2000, the distributions continue to be exempt carrying on of a business, directly or indirectly, by the fund are fund from a RIC, or a REIT that meets the above conditions, are
from U.S. tax. exempt. This includes amounts paid by a REIT only if the exempt. For Sweden, the pension fund must also satisfy the
conditions in footnote ab are met. For Sweden, to be entitled requirements in footnote (zz).
tt
Interest determined with reference to the profits of the issuer or to the exemption, the pension fund must not sell or make a
one of its associated enterprises is taxed at 15%. ac
contract to sell the holding from which the dividend is derived Interest is exempt if (a) paid to certain financial institutions, or
uu
within 2 months of the date the pension fund acquired the (b) paid on indebtedness from the sale on credit of equipment
Interest received by a financial institution is exempt. holding. or merchandise.
vv
Dividends received by a trust, company, or other organization
operated exclusively to administer or provide pension,
retirement, or other employee benefits generally are exempt if
certain conditions are met.
ww
Exemption does not apply to amount paid under, or as part of,
a conduit arrangement.
Page 37
12:36 - 23-APR-2008
Table 2. Compensation for Personal Services Performed in United States Exempt from U.S. Income Tax Under Income Tax Treaties
Page 38
Category of Personal Services Maximum Maximum
Presence Amount of Treaty Article
Country Code1 Purpose in U.S. Required Employer or Payer Compensation Citation
(1) (2) (3) (4) (5) (6) (7)
Australia 16 Independent personal services22 183 days Any contractor No limit 14
20 Public entertainment 183 days Any contractor $10,00025 17
17 Dependent personal services15 183 days Any foreign resident No limit 15
20 Public entertainment15 183 days Any foreign resident $10,00025 17
19 Studying and training:
Remittances or allowances10 No limit Any foreign resident No limit 20
Austria 16 Independent personal services22 No limit Any contractor No limit 14
20 Public entertainment No limit Any contractor $20,000 p.a.25 17
20 Public entertainment No limit Any U.S. or foreign resident $20,000 p.a.25 17
Remittances or allowances10 3 years11 Any foreign resident No limit 20
Bangladesh 15 Scholarship or fellowship grant4 2 years11 Any U.S. or foreign resident5 No limit 21(2)
16 Independent personal services22 183 days Any contractor No limit 15
20 Public entertainment No limit Any contractor $10,00030 18

18 Teaching or research4 2 years Any U.S. or foreign resident No limit 21(1)
19 Studying and training:4
Remittances or allowances 2 years11 Any foreign resident No limit 21(2)
Compensation during study or training 2 years11 Any U.S. or foreign resident $8,000 p.a. 21(2)
Barbados 16 Independent personal services7,22 89 days Any foreign contractor No limit 14
89 days Any U.S. contractor $5,000 14
20 Public entertainment No limit Any contractor $250 per day
or $4,000 p.a.6 17
17 Dependent personal services7,15 183 days Any foreign resident $5,000 15
20 Public entertainment No limit Any U.S. or foreign resident $250 per day 6
19 Studying and training:20 or $4,000 p.a. 17
Belgium (old treaty) 15 Scholarship or fellowship grant 5 years Any U.S. or foreign resident5 No limit 21(1)
16 Independent personal services22 182 days Any contractor No limit 14(2)(a)(b)
20 Public entertainment 90 days Any contractor $3,000 14(2)(c)
17 Dependent personal services15 182 days Belgian resident No limit 15
18 Teaching4 2 years U.S. educational institution No limit 20
Remittances or allowances 5 years Any foreign resident No limit 21(1)
Compensation during training 12 consec. mo. Belgian resident $5,000 21(2)(b)
5 years Other foreign or U.S. resident $2,000 p.a. 21(1)
Compensation while gaining experience2 12 consec. mo. Belgian resident $5,000 21(2)(a)
Compensation under U.S.
Government program 1 year U.S. Government or its contractor $10,000 21(3)
Belgium (new treaty) 16 Independent personal services54
17 Dependent personal services15,24 183 days Any foreign resident No limit 14
18 Teaching4 2 years Any U.S. educational or research
19 Studying and training:10 institution No limit 19(2)
Remittances or allowances No limit57 Any foreign resident No limit 19(1)(a)
Compensation during study or training No limit57 Any U.S. or foreign resident $9,000 p.a. 19(1)(b)
Canada 16 Independent personal services22 No limit Any contractor No limit12 XIV
20 Public entertainment No limit Any contractor $15,000 p.a.25 XVI
17 Dependent personal services No limit Any U.S. or foreign resident $10,000 XV
183 days Any foreign resident15 No limit12 XV

20 Public entertainment3 No limit Any U.S. or foreign resident $15,000 p.a.25 XVI
Remittances or allowances10 No limit Any foreign resident No limit XX

12:36 - 23-APR-2008
Table 2. ( Continued)
(1) (2) (3) (4) (5) (6) (7)
China, People’s Rep. of 15 Scholarship or fellowship grant No specific limit Any U.S. or foreign resident5 No limit 20(b)
20 Public entertainment29 No limit Any contractor No limit 16
20 Public entertainment29 No limit Any U.S. or foreign resident No limit 16

18 Teaching4 3 years U.S. educational or research institute No limit 19
Remittances or allowances No specific limit Any foreign resident No limit 20(a)
Compensation during training or while
gaining experience No specific limit Any U.S. or foreign resident $5,000 p.a. 20(c)
Commonwealth of 15 Scholarship or fellowship grant 5 years Any U.S. or foreign resident Limited19 VI(1)
Independent States 16 Independent personal services 183 days Any U.S. or foreign contractor No limit VI(2)
17 Dependent personal services 183 days Any U.S. or foreign resident No limit VI(2)
18 Teaching4,18 2 years Any U.S. educational or scientific institution No limit VI(1)
Remittances or allowances 5 years Any U.S. or foreign resident Limited19 VI(1)

Compensation while gaining experience 1 year C.I.S. resident No limit19 VI(1)
Government program 1 year Any U.S. or foreign resident No limit VI(1)
Cyprus 15 Scholarship or fellowship grant Generally, 5
years Any U.S. or foreign resident5 No limit 21(1)
20 Public entertainment No limit Any contractor $500 per day or
$5,000 p.a.6 19(1)
Directors’ fees No limit U.S. corporation No limit21 20
20 Public entertainment No limit Any U.S. or foreign resident $500 per day or
$5,000 p.a.6 19(1)
Remittances or allowances Generally, 5
years Any foreign resident No limit 21(1)
Compensation during training Generally, 5
years Any U.S. or foreign resident $2,000 p.a. 21(1)
Compensation while gaining experience2 1 year Cyprus resident $7,500 21(2)
Czech Republic 15 Scholarship or fellowship grant 5 years Any U.S. or foreign resident5 No limit 21(1)
20 Public entertainment 183 days Any contractor $20,000 p.a.30 18
20 Public entertainment 183 days Any foreign resident $20,000 p.a.30 18
18 Teaching4,35 2 years Any U.S. educational or research
institution No limit 21(5)
Remittances and allowances 5 years Any foreign resident No limit 21(1)
Compensation during training 5 years Any U.S. or foreign resident $5,000 p.a. 21(1)
Compensation while gaining experience2 12 consec. mos. Czech resident $8,000 21(2)
Government program 1 year U.S. Government $10,000 21(3)
Denmark 16 Independent personal services22 No limit Any contractor No limit 14

Page 39
12:36 - 23-APR-2008
Page 40
1
Country Code Purpose in U.S. Required Employer or Payer Compensation Citation
(1) (2) (3) (4) (5) (6) (7)
Egypt 15 Scholarship or fellowship grant Generally, 5 years Any U.S. or foreign resident5 No limit 23(1)
16 Independent personal services 89 days Any contractor No limit 15
20 Public entertainment No limit Any contractor $400 per day 17
17 Dependent personal services14,15 89 days Egyptian resident No limit 16
Remittances or allowances Generally, 5 years Any foreign resident No limit 23(1)
Compensation during training Generally, 5 years U.S. or any foreign resident $3,000 p.a. 23(1)
Compensation while gaining experience2 12 consec. mos. Egyptian resident $7,500 23(2)
Estonia 15 Scholarship or fellowship grants4 5 years Any U.S. or foreign resident5 No limit 20(1)

20 Public entertainment No limit Any U.S. or foreign resident $20,00030 17
Compensation during training 12 consec. mos. Estonian resident $8,000 20(2)
Compensation2 while gaining
experience 12 consec. mos. Estonian resident $8,000 20(2)
Finland 16 Independent personal services22 No limit Any contractor No limit 14
France 15 Scholarship or fellowship grant 5 years40 Any U.S. or foreign resident5 No limit 21(1)
16 Independent personal services22 No limit Any contractor No limit 14
18 Teaching4,39 2 years40 U.S. educational or research institution No limit 20
Compensation during study or
training 12 consec. mos. French resident $8,000 21(2)
2
Compensation while gaining experience 12 consec. mos. French resident $8,000 21(2)
Germany 15 Scholarship or fellowship grant No limit Any U.S. or foreign resident5 No limit 20(3)
20 Public entertainment22 No limit Any contractor $20,000 p.a.30 17
20 Public entertainment15 183 days Any foreign resident $20,000 p.a.30 17
18 Teaching4 2 years U.S. educational or research institution No limit 20(1)
Remittances or allowances10 No limit Any foreign resident No limit 20(2)
Compensation during study or training 4 years Any U.S. or foreign resident $5,000 p.a. 20(4)
Compensation while gaining experience2 1 year Any German enterprise or foreign
organization or institution $10,00028 20(5)

12:36 - 23-APR-2008
1
(1) (2) (3) (4) (5) (6) (7)
Germany (as modified) 15 Scholarship or fellowship grant No limit Any U.S. or foreign resident5 No limit 20(3)
16 Independent personal services54
18 Teaching4,56 2 years U.S. educational or research institution No limit 20(1)

Remittances or allowances No limit Any foreign resident No limit 20(2)
Compensation during study or training 4 years Any U.S. or foreign resident $9,000 p.a. 20(4)
Compensation while gaining experience2 1 year Any foreign resident $10,00028 20(5)
Greece 16 Independent personal services 183 days Greek resident contractor No limit X
183 days Other foreign or U.S. resident contractor $10,000 X
17 Dependent personal services 183 days Greek resident No limit X
183 days Other foreign or U.S. resident $10,000 X
18 Teaching 3 years U.S. educational institution No limit XII
Remittances or allowances No limit Any foreign resident No limit XIII

Hungary 16 Independent personal services22 183 days Any contractor No limit 13
Iceland 15 Scholarship and fellowship grant 5 years Any U.S. or foreign resident5 No limit 22(1)
20 Public entertainment 90 days Any contractor $100 per day 18
17 Dependent personal services15 182 days Iceland resident16 No limit 19
Compensation during training 5 years U.S. or any foreign resident $2,000 p.a. 22(1)
Compensation while gaining experience2 12 consec. mo. Iceland resident $5,000 22(2)
India 16 Independent personal services7,22 89 days Any contractor No limit 15
20 Public entertainment22 89 days Any contractor $1,500 p.a.26 18
Remittances or allowances No limit Any foreign resident27 No limit 21(1)
Indonesia 15 Scholarship and fellowship grant 5 years Any U.S. or foreign resident5 No limit 19(1)
20 Public entertainment43 No limit Any contractor $2,000 p.a.25 17
20 Public entertainment43 No limit Any U.S. or foreign resident $2,000 p.a.25 17
18 Teaching4,39 2 years U.S. educational institution No limit 20
Compensation during training 5 years Any foreign or U.S. resident $2,000 p.a. 19(1)
Compensation while gaining experience 12 consec. mo. Any U.S. or foreign resident $7,500 19(2)
Ireland 16 Independent personal services22 No limit Any contractor No limit 14

Remittances or allowances10 1 year11 Any foreign resident No limit 20
Page 41
12:36 - 23-APR-2008
Page 42
1
(1) (2) (3) (4) (5) (6) (7)
Israel 15 Scholarship and fellowship grant 5 years Any U.S. or foreign resident5 No limit 24(1)
20 Public entertainment No limit Any contractor $400 per day52 18
17 Dependent personal services14,15 182 days Israeli resident16 No limit 17
20 Public entertainment No limit Any U.S. or foreign resident $400 per day52 18
training 5 years Any U.S. or foreign resident $3,000 p.a. 24(1)
Compensation while gaining experience2 12 consec. mo. Israeli resident $7,500 24(2)
7,22
Italy 16 Independent personal services 183 days Any contractor No limit 14
20 Public entertainment 90 days Any contractor $12,000 p.a.25 17(1)

20 Public entertainment 90 days Any U.S. or foreign resident $12,000 p.a.25 17(1)
Remittances or allowances No limit Any foreign resident No limit 21
Jamaica 16 Independent personal services22 89 days Any foreign contractor No limit 14
89 days Any U.S. contractor $5,000 p.a. 14
or $5,000 p.a.6 18
17 Dependent personal services15 183 days Any foreign resident $5,000 p.a. 15
or $5,000 p.a. 18
Directors’ fees No limit U.S. resident $400 per day6 16
Compensation during study 12 consec. mo. Jamaican resident $7,500 p.a. 21(2)
Compensation while gaining experience2 12 consec. mo. Jamaican resident $7,500 p.a. 21(2)
Japan 16 Independent personal service 7,54
20 Public entertainment No limit Any contractor $10,000 p.a. 25 16
20 Public entertainment No limit Any U.S. or foreign resident $10,000 p.a. 25 16
18 Teaching or research 4 2 years Any U.S. educational institution No limit 20
Remittances or allowances 1 year 11 Any foreign resident No limit 19
44
Kazakhstan 15 Scholarship or fellowship grant 5 years31 Any U.S. or foreign resident5 No limit 19
Remittances or allowances 5 years Any foreign resident No limit 19
Korea, Rep. of 15 Scholarship or fellowship grant 5 years Any U.S. or foreign resident5 No limit 21(1)
16 Independent personal services22 182 days Any contractor $3,000 p.a. 18
17 Dependent personal services15 182 days Korean resident16 $3,000 p.a. 19
Compensation during training 5 years Any foreign or U.S. resident $2,000 p.a. 21(1)
Compensation while gaining experience2 1 year Korean resident $5,000 21(2)

12:36 - 23-APR-2008
1
(1) (2) (3) (4) (5) (6) (7)
Latvia 15 Scholarship or fellowship grants4 5 years Any U.S. or foreign resident5 No limit 20(1)

Compensation during training 12 consec. mos. Latvian resident $8,000 20(2)
Compensation while gaining
experience2 12 consec. mos. Latvian resident $8,000 20(2)
Lithuania 15 Scholarship or fellowship grants4 5 years Any U.S. or foreign resident5 No limit 20(1)

Compensation during training 12 consec. mos. Lithuanian resident $8,000 20(2)
Compensation while gaining
experience2 12 consec. mos. Lithuanian resident $8,000 20(2)
Luxembourg 16 Independent personal services22 No limit Any contractor No limit 15
20 Public entertainment No limit Any foreign resident $10,00025 18
18 Teaching or research8 2 years Any U.S. or foreign resident No limit 21(2)
Remittances or allowances10 2 years11 Any U.S. or foreign resident No limit 21(1)
Mexico 16 Independent personal services22 183 days Any contractor No limit 14
Remittances or allowances No limit Any foreign resident No limit 21
Morocco 15 Scholarship or fellowship grant 5 years Any U.S. or foreign resident5 No limit 18
16 Independent personal services12,22 182 days Any contractor $5,000 14
17 Dependent personal services12,15 182 days Moroccan resident16 No limit 15
Compensation during training 5 years U.S. or any foreign resident $2,000 p.a. 18
Netherlands 15 Scholarship or fellowship grant33 3 years Any U.S. or foreign resident5 No limit 22(2)
18 Teaching4,34 2 years U.S. educational institution No limit 21(1)
Remittances or allowances No limit Any foreign resident No limit 22(1)

Compensation while gaining experience No limit Any U.S. or foreign resident $2,000 p.a. 22(1)
Compensation while recipient of
scholarship or fellowship grant 3 years Any U.S. or foreign resident $2,000 p.a.36 22(2)
Page 43
12:36 - 23-APR-2008
Page 44
(1) (2) (3) (4) (5) (6) (7)
New Zealand 16 Independent personal services22 183 days Any contractor No limit 14
20 Public entertainment15 183 days Any foreign resident $10,00025 17
Norway 15 Scholarship or fellowship grant 5 years Any U.S. or foreign resident5 No limit 16(1)
20 Public entertainment 90 days Any contractor $10,000 p.a. 13
17 Dependent personal services 182 days Norwegian resident16 No limit 14
Compensation while gaining experience2 12 consec. mo. Norwegian resident $5,000 16(2)
Pakistan 15 Scholarship or fellowship grant No limit Pakistani nonprofit organization No limit XIII(1)
16 Independent personal services14 183 days Pakistani resident contractor No limit XI
17 Dependent personal services14 183 days Pakistani resident No limit XI
18 Teaching 2 years U.S. educational institution No limit XII
Remittances or allowances No limit Any foreign resident No limit XIII(1)
Compensation during training No limit U.S. or any foreign resident $5,000 p.a. XIII(1)
Compensation while gaining experience2 1 year Pakistani resident $6,000 XIII(2)
Compensation while under U.S.
Government program No limit U.S. Government, its contractor, or any
foreign resident employer $10,000 XIII(3)
Philippines 15 Scholarship or fellowship grant 5 years Any U.S. or foreign resident5 No limit 22(1)
16 Independent personal services22 89 days Any foreign contractor No limit 15
89 days Any U.S. resident $10,000 p.a. 15
or $3,000 p.a. 17
17 Dependent personal services15 89 days Any Philippines resident16 No limit 16
20 Public entertainment No limit Any U.S. or foreign resident $100 per day
or $3,000 p.a. 17
Compensation during study 5 years Any U.S. or foreign resident $3,000 p.a. 22(1)
Compensation while gaining experience2 12 consec. mo. Philippines resident $7,500 p.a. 22(2)
Government program 1 year U.S. Government or its contractor $10,000 p.a. 22(3)
Poland 15 Scholarship or fellowship grant 5 years Any U.S. or foreign resident5 No limit 18(1)
Compensation while gaining experience2 1 year Polish resident $5,000 18(2)


12:36 - 23-APR-2008
(1) (2) (3) (4) (5) (6) (7)
Portugal 15 Scholarship or fellowship grant 5 years Any U.S. or foreign resident5 No limit 23(1)

training 12 consec. mos. Portuguese resident $8,000 23(2)
2
Compensation while gaining experience 12 consec. mos. Portuguese resident $8,000 23(2)
Romania 15 Scholarship or fellowship grant 5 years Any U.S. or foreign resident5 No limit 20(1)

17 Dependent personal services15 182 days Romanian resident No limit 15
20 Public entertainment 89 days Romanian resident $2,999.99 15
Compensation while gaining experience2 1 year Romanian resident $5,000 20(2)
Russia 15 Scholarship or fellowship grant44 5 years31 Any U.S. or foreign resident5 No limit 18
17 Dependent personal services7,15,32 183 days Any foreign resident No limit 14
Remittances 5 years31 Any foreign resident No limit 18
Slovak Republic 15 Scholarship or fellowship grant 5 years Any U.S. or foreign resident5 No limit 21(1)
20 Public entertainment 183 days Any contractor $20,000 p.a.30 18
18 Teaching4,35 2 years Any U.S. educational or research institution No limit 21(5)
Compensation while gaining experience2 12 consec. mos. Slovak resident $8,000 21(2)
4 47 5
Slovenia 15 Scholarship or fellowship grant 5 years Any U.S. or foreign resident No limit 20(1)
17 Dependent personal services15, 24 183 days Any foreign resident No limit 15
18 Teaching or research4 2 years48 Any U.S. or foreign resident No limit 20(3)
19 Studying and training4
Compensation during training 12 mos. Slovenian resident $8,000 20(2)
5 years47 Other foreign or U.S. resident $5,000 p.a. 20(1)

Compensation while gaining experience2 12 mos. Slovenian resident $8,000 20(2)
Page 45
12:36 - 23-APR-2008
Page 46
1
(1) (2) (3) (4) (5) (6) (7)
South Africa 16 Independent personal services22 183 days Any contractor No limit 14
19 Studying and training: 10
Remittances or allowances 1 year11 Any foreign resident No limit 20
5
Spain 15 Scholarship or fellowship grant 5 years Any U.S. or foreign resident No limit 22(1)

Compensation while gaining experience2 12 consec. mo. Spanish resident $8,000 22(2)
Sri Lanka 16 Independent personal services22, 24 183 days Any contractor No limit 15
20 Public entertainment22 183 days Any contractor $6,000 p.a.51 18
Compensation while gaining experience2 1 year Sri Lankan resident55 $6,000 21(2)
Sweden 16 Independent personal services22 No limit Any contractor No limit 14

Switzerland 16 Independent personal services22 No limit Any contractor No limit 14
Thailand 15 Scholarship or fellowship grant 5 years Any U.S. or foreign resident5 No limit 22(1)
16 Independent personal services22 89 days Any U.S. resident $10,000 15
89 days Any foreign contractor No limit45 15
20 Public entertainment No limit Any contractor $100 per day 9 19
or $3,000 p.a.
20 Public entertainment No limit Any U.S. or foreign resident $100 per day 9 19
or $3,000 p.a.
18 Teaching or research4,38 2 years Any U.S. or foreign resident No limit 23
Compensation while gaining experience2 12 consec. mos. Thai resident $7,500 22(2)

12:36 - 23-APR-2008
1

(1) (2) (3) (4) (5) (6) (7)
Trinidad and Tobago 15 Scholarship or fellowship grant 5 years Any U.S. or foreign resident5 No limit 19(1)
16 Independent personal services13 183 days Any foreign resident contractor No limit 17
183 days Any U.S. contractor $3,0006 17
183 days Any U.S. resident $3,0006 17
18 Teaching4 2 years U.S. educational institution or U.S. Government No limit 18
Compensation during training 5 years U.S. or any foreign resident $2,000 p.a.6 19(1)
Compensation during professional training 5 years U.S. or any foreign resident $5,000 p.a.6 19(1)
Compensation while gaining experience2 1 year Trinidad–Tobago resident $5,0006 19(2)
Tunisia 15 Scholarship or fellowship grant10 5 years Any U.S. or foreign resident5 No limit 20
16 Independent personal services22 183 days U.S. resident contractor $7,500 p.a. 14
Compensation during training 5 years Any U.S. or foreign resident $4,000 p.a. 20
Turkey 16 Independent personal services22 183 days Any contractor No limit 14
20 Public entertainment46 No limit Any contractor $3,00053 17
20 Public entertainment46 No limit Any U.S. or foreign resident $3,00053 17
18 Teaching or research 2 years Any foreign resident No limit 20(2)
44 31 5
Ukraine 15 Scholarship or fellowship grant 5 years Any U.S. or foreign resident No limit 20
16 Independent personal services22,50 No limit Any contractor No limit 14
17 Dependent personal services15,23,50 183 days Any foreign resident No limit 15
7,54
United Kingdom 16 Independent personal services
18 Teaching or research4 2 years Any U.S. educational institution No limit 20A
Remittances or allowances10 No limit57 Any foreign resident No limit 20
Page 47
12:36 - 23-APR-2008
Page 48
Table 2. (Continued)
1
(1) (2) (3) (4) (5) (6) (7)
Venezuela 15 Scholarship or fellowship grants4 5 years47 Any U.S. or foreign resident5 No limit 21(1)
16 Independent personal services22,24 No limit Any contractor No limit 14
18 Teaching4 2 years48 Any U.S. or foreign resident No limit 21(3)
Compensation during training 12 mos. Venezuelan resident $8,000 21(2)
47
Compensation2 while gaining
experience 12 mos. Venezuelan resident $8,000 21(2)

12:36 - 23-APR-2008
1 21 39
Refers to income code numbers under which the income is Amounts received in excess of a reasonable fixed amount Exemption does not apply if the individual previously claimed
reported on Forms 1042-S. Personal services must be payable to all directors for attending meetings in the United the benefit of this Article.
performed by a nonresident alien individual who is a resident States are taxable. 40
The combined period of benefits under Articles 20 and 21(1)
of the specified treaty country. 22
Exemption does not apply to the extent income is attributable cannot exceed 5 years.
2 41
Applies only if training or experience is received from a person to the recipient’s fixed U.S. base. For residents of Iceland, Exemption does not apply if the individual either (a)
other than alien’s employer. Korea, and Norway, the fixed base must be maintained for previously claimed the benefit of this Article, or (b) during the
3 more than 182 days; for residents of Morocco, the fixed
Employment with a team which participates in a league with immediately preceding period, claimed the benefit of Article
regularly scheduled games in both countries is covered base must be maintained for more than 89 days. 23. The benefits under Articles 22 and 23 cannot be claimed
under the provisions for dependent personal services. 23 at the same time.
Fees paid to a resident of the treaty country for services as a
4 42
Does not apply to compensation for research work primarily director of a U.S. corporation are subject to U.S. tax, unless Exemption does not apply if gross receipts (including
for private benefit. the services are performed in the country of residence. reimbursements) exceed this amount during any 12-month
5 24

Grant must be from a nonprofit organization. In many cases, Fees paid to a resident of the treaty country for services period.
43
the exemption also applies to amounts from either the U.S. or performed in the United States as a director of a U.S. This provision does not apply if the competent authority of
foreign government. For Indonesia and the Netherlands, the corporation are subject to U.S. tax. the treaty country certifies that the visit is substantially
exemption also applies if the amount is awarded under a 25 supported by that treaty country.
Exemption does not apply if gross receipts (including
technical assistance program entered into by the United States 44
reimbursements) exceed this amount. Applies to grants, allowances, and other similar payments
or the foreign government, or its political subdivisions or local 26 received for studying or doing research.
Exemption does not apply if net income exceeds this
authorities. 45
6
amount. A $10,000 limit applies if the expense is borne by a permanent
Reimbursed expenses are not taken into account in figuring 27 establishment or a fixed base in the United States.
Exemption does not apply to payments borne by a
any maximum compensation to which the exemption applies. 46
permanent establishment in the United States or paid by a This provision does not apply if these activities are substantially
For Japan and Trinidad and Tobago, only reimbursed travel U.S. citizen or resident or the federal, state, or local supported by a nonprofit organization or by public funds of the
expenses are disregarded in figuring the maximum government. treaty country or its political subdivisions or local authorities.
compensation. 28 47
7 Exemption does not apply if compensation exceeds this Applies to any additional period that a full-time student needs
Does not apply to fees of a foreign director of a U.S. amount. to complete the educational requirements as a candidate for
corporation. 29 a postgraduate or professional degree from a recognized
8 The exemption applies only to income from activities
Does not apply to compensation for research work for other performed under special cultural exchange programs agreed educational institution.
than the U.S. educational institution involved. 48
9
to by the U.S. and Chinese governments. The combined benefit for teaching cannot exceed 5 years.
Exemption does not apply if gross receipts exceed this amount. 30 49
Exemption does not apply if gross receipts (or compensation Exemption does not apply if the recipient maintains a
Income is fully exempt if visit to the United States is for Portugal), including reimbursements, exceed this amount. permanent establishment in the U.S. with which the income is
substantially supported by public funds of the treaty country Income is fully exempt if visit to the United States is effectively connected.
or its political subdivisions or local authorities. substantially supported by public funds of the treaty country 50
10 The exemption does not apply to income received for
Applies only to full-time student or trainee. or its political subdivisions or local authorities.
11
performing services in the United States as an entertainer or
The time limit pertains only to an apprentice or business trainee. 31
The 5-year limit pertains only to training or research. a sportsman. However, this income is exempt for U.S. income
12 32
Does not apply to compensation paid to public entertainers Compensation from employment directly connected with a tax if the visit is (a) substantially supported by public funds of
(actors, artists, musicians, athletes, etc.). place of business that is not a permanent establishment is Ukraine, its political subdivisions, or local authorities, or (b)
13
Does not apply to compensation paid to public entertainers exempt if the alien is present in the United States for a made under a specific arrangement agreed to by the
that is more than $100 a day. period not exceeding 12 consecutive months. Compensation governments of the treaty countries.
14 51
Exemption applies only if the compensation is subject to tax for technical services directly connected with the application Exemption does not apply if gross receipts, including
in the country of residence. of a right or property giving rise to a royalty is exempt if the reimbursements, exceed this amount during the year. Income
15 services are provided as part of a contract granting the use is fully exempt if visit is wholly or mainly supported by public
The exemption does not apply if the employee’s
compensation is borne by a permanent establishment (or in of the right or property. funds of one or both of the treaty countries or their political
33
some cases a fixed base) that the employer has in the Exemption does not apply if, during the immediately subdivisions or local authorities.
52
United States. preceding period, the individual claimed the benefits of If the compensation exceeds $400 per day, the entertainer may
16 Article 21. be taxed on the full amount. If the individual receives a fixed
The exemption also applies if the employer is a permanent 34
establishment in the treaty country but is not a resident of Exemption does not apply if, during the immediately amount for more than one performance, the amount is prorated
the treaty country. preceding period, the individual claimed the benefits of over the number of days the individual performs the services
17 Article 22. (including rehearsals).
This exemption does not apply in certain cases if the 35 53
employee is a substantial owner of that employer and the Exemption does not apply if the individual either (a) claimed Exemption does not apply if gross receipts exceed this amount.
54
employer is engaged in certain defined activities. the benefit of Article 21(5) during a previous visit, or (b) Treated as business profits under Article 7 of the treaty.
18 during the immediately preceding period, claimed the benefit 55
The exemption is also extended to journalists and Applies also to a participant in a program sponsored by the
correspondents who are temporarily in the U.S. for periods of Article 21(1), (2), or (3). U.S. Government or an international organization.
36
not longer than 2 years and who receive compensation from Exemption applies only to compensation for personal 56
Exemption does not apply if during the immediately preceding
abroad. services performed in connection with, or incidental to, the period, the individual claimed the benefit of Article 20(2), (3),
19 individual’s study, research, or training.
Also exempt are amounts of up to $10,000 received from or (4).
37 57
U.S. sources to provide ordinary living expenses. For Exemption does not apply if, during the immediately Exemption applies to buisiness apprentice (trainee) only for a
students, the amount will be less than $10,000, determined preceding period, the individual claimed the benefits of period not exceeding 1 year (2 years for Belgium) from the date
on a case by case basis. Article 24(1). of arrival in the United States.
20 38
A student or trainee may choose to be treated as a U.S. Exemption does not apply if, during the immediately
resident for tax purposes. If the choice is made, it may not preceding period, the individual claimed the benefits of
be changed without the consent of the U.S. competent Article 22(1).
authority.
Page 49
12:36 - 23-APR-2008
Table 3. List of Tax Treaties (Updated through December 31, 2007)

Applicable Treasury
Official Text General Explanations
Country Symbol1 Effective Date Citation or Treasury Decision (T.D.)
Australia TIAS 10773 Dec. 1, 1983 1986-2 C.B. 220 1986-2 C.B. 246
Protocol TIAS Jan. 1, 2004
Austria TIAS Jan. 1, 1999
Bangladesh TIAS Jan. 1, 2007
Barbados TIAS 11090 Jan. 1, 1984 1991-2 C.B. 436 1991-2 C.B. 466
Belgium TIAS Jan. 1, 2008
Canada2 TIAS 11087 Jan. 1, 1985 1986-2 C.B. 258 1987-2 C.B. 298
China, People’s Republic of TIAS 12065 Jan. 1, 1987 1988-1 C.B. 414 1988-1 C.B. 447
Commonwealth of Independent
States3 TIAS 8225 Jan. 1, 1976 1976-2 C.B. 463 1976-2 C.B. 475
Cyprus TIAS 10965 Jan. 1, 1986 1989-2 C.B. 280 1989-2 C.B. 314
Czech Republic TIAS Jan. 1, 1993
Denmark TIAS Jan. 1, 2001
Egypt TIAS 10149 Jan. 1, 1982 1982-1 C.B. 219 1982-1 C.B. 243
Estonia TIAS Jan. 1, 2000
Finland TIAS 12101 Jan. 1, 1991
France TIAS Jan. 1, 1996
Germany TIAS Jan. 1, 1990
Greece TIAS 2902 Jan. 1, 1953 1958-2 C.B. 1054 T.D. 6109, 1954-2 C.B. 638
Hungary TIAS 9560 Jan. 1, 1980 1980-1 C.B. 333 1980-1 C.B. 354
Iceland TIAS 8151 Jan. 1, 1976 1976-1 C.B. 442 1976-1 C.B. 456
India TIAS Jan. 1, 1991
Indonesia TIAS 11593 Jan. 1, 1990
Ireland TIAS Jan. 1, 1998
Israel TIAS Jan. 1, 1995
Italy TIAS 11064 Jan. 1, 1985 1992-1 C.B. 442 1992-1 C.B. 473
Jamaica TIAS 10207 Jan. 1, 1982 1982-1 C.B. 257 1982-1 C.B. 291
Japan TIAS Jan. 1, 2005
Kazakhstan TIAS Jan. 1, 1996
Korea, Republic of TIAS 9506 Jan. 1, 1980 1979-2 C.B. 435 1979-2 C.B. 458
Latvia TIAS Jan. 1, 2000
Lithuania TIAS Jan. 1, 2000
Luxembourg TIAS Jan. 1, 2001
Mexico TIAS Jan. 1,1994
Morocco TIAS 10195 Jan. 1, 1981 1982-2 C.B. 405 1982-2 C.B. 427
Netherlands TIAS Jan. 1, 1994
New Zealand TIAS 10772 Nov. 2, 1983 1990-2 C.B. 274 1990-2 C.B. 303
Norway TIAS 7474 Jan. 1, 1971 1973-1 C.B. 669 1973-1 C.B. 693
Protocol TIAS 10205 Jan. 1, 1982 1982-2 C.B. 440 1982-2 C.B. 454
Pakistan TIAS 4232 Jan. 1, 1959 1960-2 C.B. 646 T.D. 6431, 1960-1 C.B. 755

Table 3. (continued)
Applicable Treasury
Official Text General Explanations
Country Symbol1 Effective Date Citation or Treasury Decision (T.D.)
Philippines TIAS 10417 Jan. 1, 1983 1984-2 C.B. 384 1984-2 C.B. 412
Poland TIAS 8486 Jan. 1, 1974 1977-1 C.B. 416 1977-1 C.B. 427
Portugal TIAS Jan. 1, 1996
Romania TIAS 8228 Jan. 1, 1974 1976-2 C.B. 492 1976-2 C.B. 504
Russia TIAS Jan. 1, 1994
Slovak Republic TIAS Jan. 1, 1993
Slovenia TIAS Jan. 1, 2002
South Africa TIAS Jan. 1, 1998
Spain TIAS Jan. 1, 1991
Sri Lanka TIAS Jan. 1, 2004
Sweden TIAS Jan. 1, 1996
Switzerland TIAS Jan. 1, 1998
Thailand TIAS Jan. 1, 1998
Trinidad and Tobago TIAS 7047 Jan. 1, 1970 1971-2 C.B. 479
Tunisia TIAS Jan. 1, 1990
Turkey TIAS Jan. 1, 1998
Ukraine TIAS Jan. 1, 2001
United Kingdom TIAS Jan. 1, 2004
Venezuela TIAS Jan. 1, 2000
1 (TIAS) — Treaties and Other International Act Series.
2 Information on the treaty can be found in Publication 597, Information on the United States-Canada Income Tax Treaty.
3 The U.S.-U.S.S.R. income tax treaty applies to the countries of Armenia, Azerbaijan, Belarus, Georgia, Kyrgyzstan, Moldova, Tajikistan, Turkmenistan, and Uzbekistan.
or for a nominal charge. The clinics also provide • Figure your withholding allowances using
How To Get Tax Help tax education and outreach for taxpayers with
limited English proficiency or who speak English
the withholding calculator online at
www.irs.gov/individuals.
You can get help with unresolved tax issues, as a second language. Publication 4134, Low
Income Taxpayer Clinic List, provides informa- • Determine if Form 6251 must be filed us-
order free publications and forms, ask tax ques-
tion on clinics in your area. It is available at www. ing our Alternative Minimum Tax (AMT)
tions, and get information from the IRS in sev-
eral ways. By selecting the method that is best irs.gov or at your local IRS office. Assistant.
for you, you will have quick and easy access to • Sign up to receive local and national tax
tax help. Free tax services. To find out what services news by email.
are available, get Publication 910, IRS Guide to
Contacting your Taxpayer Advocate. The
Free Tax Services. It contains a list of free tax • Get information on starting and operating
Taxpayer Advocate Service (TAS) is an inde- a small business.
publications and describes other free tax infor-
pendent organization within the IRS whose em-
mation services, including tax education and
ployees assist taxpayers who are experiencing
assistance programs and a list of TeleTax top-
economic harm, who are seeking help in resolv-
ics. Phone. Many services are available by
ing tax problems that have not been resolved
Accessible versions of IRS published prod- phone.
through normal channels, or who believe that an
IRS system or procedure is not working as it ucts are available on request in a variety of
should. alternative formats for people with disabilities. • Ordering forms, instructions, and publica-
You can contact the TAS by calling the TAS Internet. You can access the IRS web- tions. Call 1-800-829-3676 to order cur-
toll-free case intake line at 1-877-777-4778 or site at www.irs.gov 24 hours a day, 7 rent-year forms, instructions, and
TTY/TDD 1-800-829-4059 to see if you are eligi- days a week to: publications, and prior-year forms and in-
ble for assistance. You can also call or write to structions. You should receive your order
your local taxpayer advocate, whose phone • E-file your return. Find out about commer-
within 10 days.
number and address are listed in your local cial tax preparation and e-file services
telephone directory and in Publication 1546, The available free to eligible taxpayers. • Asking tax questions. Call the IRS with
Taxpayer Advocate Service of the IRS - How To • Check the status of your 2007 refund. your tax questions at 1-800-829-1040.
Get Help With Unresolved Tax Problems. You Click on Where’s My Refund. Wait at least • Solving problems. You can get
can file Form 911, Request for Taxpayer Advo- 6 weeks from the date you filed your re- face-to-face help solving tax problems
cate Service Assistance (And Application for turn (3 weeks if you filed electronically). every business day in IRS Taxpayer As-
Taxpayer Assistance Order), or ask an IRS em- Have your 2007 tax return available be-
ployee to complete it on your behalf. For more sistance Centers. An employee can ex-
cause you will need to know your social plain IRS letters, request adjustments to
information, go to www.irs.gov/advocate. security number, your filing status, and the your account, or help you set up a pay-
Taxpayer Advocacy Panel (TAP). The exact whole dollar amount of your refund.
ment plan. Call your local Taxpayer Assis-
TAP listens to taxpayers, identifies taxpayer is- • Download forms, instructions, and publica- tance Center for an appointment. To find
sues, and makes suggestions for improving IRS tions. the number, go to www.irs.gov/localcon-
services and customer satisfaction. If you have
suggestions for improvements, contact the TAP, • Order IRS products online. tacts or look in the phone book under
toll free at 1-888-912-1227 or go to United States Government, Internal Reve-
• Research your tax questions online. nue Service.
www.improveirs.org.
• Search publications online by topic or • TTY/TDD equipment. If you have access
Low Income Taxpayer Clinics (LITCs).
keyword. to TTY/TDD equipment, call
LITCs are independent organizations that pro-
vide low income taxpayers with representation • View Internal Revenue Bulletins (IRBs) 1-800-829-4059 to ask tax questions or to
in federal tax controversies with the IRS for free published in the last few years. order forms and publications.

• TeleTax topics. Call 1-800-829-4477 to lis- visit your local Taxpayer Assistance • Internal Revenue Bulletins.
ten to pre-recorded messages covering Center where you can spread out your
various tax topics. records and talk with an IRS representa-
• Toll-free and email technical support.
tive face-to-face. No appointment is nec- • The CD which is released twice during the
• Refund information. To check the status of essary, but if you prefer, you can call your year.
your 2007 refund, call 1-800-829-4477
local Center and leave a message re- – The first release will ship the beginning
and press 1 for automated refund informa-
questing an appointment to resolve a tax of January 2008.
tion or call 1-800-829-1954. Be sure to
account issue. A representative will call – The final release will ship the beginning
wait at least 6 weeks from the date you
you back within 2 business days to sched- of March 2008.
filed your return (3 weeks if you filed elec-
ule an in-person appointment at your con-
tronically). Have your 2007 tax return
venience. To find the number, go to www. Purchase the CD/DVD from National Techni-
available because you will need to know
irs.gov/localcontacts or look in the phone cal Information Service (NTIS) at www.irs.gov/
your social security number, your filing
book under United States Government, In- cdorders for $35 (no handling fee) or call
status, and the exact whole dollar amount
ternal Revenue Service. 1-877-CDFORMS (1-877-233-6767) toll free to
of your refund.
buy the CD/DVD for $35 (plus a $5 handling
Mail. You can send your order for fee). Price is subject to change.
Evaluating the quality of our telephone
services. To ensure IRS representatives give forms, instructions, and publications to
CD for small businesses. Publication
accurate, courteous, and professional answers, the address below. You should receive
3207, The Small Business Resource
we use several methods to evaluate the quality a response within 10 days after your request is
Guide CD for 2007, is a must for every
of our telephone services. One method is for a received.
small business owner or any taxpayer about to
second IRS representative to listen in on or start a business. This year’s CD includes:
record random telephone calls. Another is to ask National Distribution Center
some callers to complete a short survey at the P.O. Box 8903 • Helpful information, such as how to pre-
end of the call. Bloomington, IL 61702-8903 pare a business plan, find financing for
your business, and much more.
Walk-in. Many products and services After May 2008, send your order to the following
• All the business tax forms, instructions,
are available on a walk-in basis. address.
and publications needed to successfully
manage a business.
• Products. You can walk in to many post Internal Revenue Service
• Tax law changes for 2007.
offices, libraries, and IRS offices to pick up 1201 N. Mitsubishi Motorway
certain forms, instructions, and publica- Bloomington, IL 61704-6613 • Tax Map: an electronic research tool and
tions. Some IRS offices, libraries, grocery finding aid.
stores, copy centers, city and county gov- CD/DVD for tax products. You can
order Publication 1796, IRS Tax Prod- • Web links to various government agen-
ernment offices, credit unions, and office
ucts CD/DVD, and obtain: cies, business associations, and IRS orga-
supply stores have a collection of products
nizations.
available to print from a CD or photocopy • Current-year forms, instructions, and pub-
from reproducible proofs. Also, some IRS lications. • “Rate the Product” survey — your opportu-
offices and libraries have the Internal Rev- nity to suggest changes for future editions.
enue Code, regulations, Internal Revenue • Prior-year forms, instructions, and publica-
tions. • A site map of the CD to help you navigate
Bulletins, and Cumulative Bulletins avail-
the pages of the CD with ease.
able for research purposes. • Bonus: Historical Tax Products DVD -
• An interactive “Teens in Biz” module that
• Services. You can walk in to your local Ships with the final release.
gives practical tips for teens about starting
Taxpayer Assistance Center every busi- • Tax Map: an electronic research tool and their own business, creating a business
ness day for personal, face-to-face tax finding aid. plan, and filing taxes.
help. An employee can explain IRS letters,
request adjustments to your tax account, • Tax law frequently asked questions.
An updated version of this CD is available
or help you set up a payment plan. If you • Tax Topics from the IRS telephone re- each year in early April. You can get a free copy
need to resolve a tax problem, have ques- sponse system. by calling 1-800-829-3676 or by visiting www.irs.
tions about how the tax law applies to your
individual tax return, or you’re more com- • Fill-in, print, and save features for most tax gov/smallbiz.
fortable talking with someone in person, forms.

IRS Pub 901 - US Tax Treaty Benefits

Uploaded by

Document Information

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

IRS Pub 901 - US Tax Treaty Benefits

Uploaded by

Copyright:

Available Formats

Userid: ________ DTD TIP04 Leadpct: 0% Pt.

size: 8 ❏ Draft ❏ Ok to Print

Page 1 of 52 of Publication 901 12:36 - 23-APR-2008

We respond to many letters by telephone.

Comments and suggestions. We welcome

Page 2 Publication 901 (April 2008)

Publication 901 (April 2008) Page 3

Page 4 Publication 901 (April 2008)

Publication 901 (April 2008) Page 5

Estonia • They are in the United States for no more Germany

Page 6 Publication 901 (April 2008)

Income that residents of Iceland receive for per-

Publication 901 (April 2008) Page 7

Page 8 Publication 901 (April 2008)

Kazakhstan • They are employees of a resident of Korea Lithuania

• The income is not borne by a permanent

Publication 901 (April 2008) Page 9

Page 10 Publication 901 (April 2008)

Publication 901 (April 2008) Page 11

Page 12 Publication 901 (April 2008)

Publication 901 (April 2008) Page 13

Page 14 Publication 901 (April 2008)

Publication 901 (April 2008) Page 15

Bangladesh Commonwealth of This exemption does not apply to income

Page 16 Publication 901 (April 2008)

Greece Indonesia This exemption does not apply to income

Publication 901 (April 2008) Page 17

Page 18 Publication 901 (April 2008)

Publication 901 (April 2008) Page 19

Canada longer than 1 year. • Studying or doing research as a recipient

Page 20 Publication 901 (April 2008)

France • The services are performed for the pur-

Publication 901 (April 2008) Page 21

Page 22 Publication 901 (April 2008)

Publication 901 (April 2008) Page 23

Page 24 Publication 901 (April 2008)

Publication 901 (April 2008) Page 25

Page 26 Publication 901 (April 2008)

Thailand • Gifts from abroad for maintenance, educa- Ukraine

Publication 901 (April 2008) Page 27

Page 28 Publication 901 (April 2008)

Cyprus Estonia Treaty as modified. Wages, salaries, and

Publication 901 (April 2008) Page 29

Page 30 Publication 901 (April 2008)

Publication 901 (April 2008) Page 31

Pensions paid by Russia, its republics, or lo- Spain • Is a U.S. citizen, or

Page 32 Publication 901 (April 2008)

Publication 901 (April 2008) Page 33

Belgium (new treaty) BE 15 15 15 15 5 0 0 0 0 30 0 30

Publication 901 (April 2008)

Paid by Interest Controlling U.S. Qualifying Motion and

bank or similar financial institution. For Thailand, the 10% rate

Publication 901 (April 2008)

17 Dependent personal services15 183 days Any foreign resident No limit 16

183 days Any foreign resident15 No limit12 XV

Publication 901 (April 2008)

Publication 901 (April 2008)

Remittances or allowances 5 years Any U.S. or foreign resident Limited19 VI(1)

20 Public entertainment 183 days Any foreign resident $20,000 p.a.25 17

20 Public entertainment No limit Any contractor $20,00030 17

Publication 901 (April 2008)

Publication 901 (April 2008)

Remittances or allowances No limit Any foreign resident No limit XIII

17 Dependent personal services15,23 183 days Any foreign resident No limit 15