Publication 901 |
2001 Tax Year |
Tax Exemptions Provided by Treaties
In addition to the tables in the back of this publication, this
publication contains discussions of the exemptions from tax and
certain other effects of the tax treaties on the following types of
income.
- Pay for certain personal services performed in the United
States.
- Pay of a professor, teacher, or researcher who teaches or
performs research in the United States for a limited time.
- Amounts received for maintenance and studies by a foreign
student or apprentice who is here for study or experience.
- Wages, salaries, and pensions paid by a foreign
government.
Personal Services Income
Pay for certain personal services performed in the United States is
exempt from U.S. income tax if you are a resident of one of the
countries discussed below, if you are in the United States for a
limited number of days and if you meet certain other conditions. For
this purpose, the word "day" means a day during any part of which
you are physically present in the United States.
Terms defined.
Several terms appear in many of the discussions that follow. The
exact meanings of the terms are determined by the particular tax
treaty under discussion; thus, the meanings vary among treaties. The
definitions that follow are, therefore, general definitions that may
not give the exact meaning intended by a particular treaty.
The terms fixed base and permanent establishment
generally mean a fixed place of business, such as an office, a
factory, a warehouse, or a mining site, through which an enterprise
carries on its business.
The term borne by generally means having ultimate
financial accounting responsibility for or providing the monetary
resources for an expenditure or payment, even if another entity in
another location actually made the expenditure or payment.
Australia
Income that residents of Australia receive for performing personal
services as independent contractors or self-employed individuals
(independent personal services) in the 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
- Do not have a fixed base regularly available to them in the
United States for the purpose of performing the services.
If they have a fixed base available in the United States, they
are taxed on the income attributable to the fixed base.
Pay that residents of Australia receive for labor or personal
services performed in the United States as employees (dependent
personal services), including services as a director of a company, 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,
- The pay is paid by, or on behalf of, an employer or company
that is not a resident of the United States, and
- The pay is not deductible in determining the taxable income
of the trade or business of the employer (or company) in the United
States.
These exemptions do not apply to public entertainers (such as
theater, motion picture, radio, or television entertainers, musicians
and athletes) from Australia who earn more than $10,000 in gross
receipts, including reimbursed expenses, from their entertainment
activities in the United States during the tax year.
Austria
Income that residents of Austria receive for personal services as
independent contractors or self-employed individuals (independent
personal services) in the United States is exempt from U.S. income tax
if they do not have a fixed base regularly available to them in the
United States for performing the services. If they have a fixed base
available in the United States, they are taxed on the income
attributable to the fixed base.
Income that residents of Austria receive for services performed in
the United States as employees (dependent personal services) is exempt
from U.S. income tax if the residents meet the following requirements.
- They are in the United States for no more than 183 days in
any 12-month period beginning or ending in the tax year.
- Their income is paid by, or on behalf of, an employer who is
not a U.S. resident.
- Their income is not borne by a permanent establishment or a
fixed base that the employer has in the United States.
These exemptions do not apply to public entertainers (such as
theater, motion picture, radio, or television entertainers, musicians
and athletes) from Austria who earn more than $20,000 in gross
receipts, including reimbursed expenses, from their entertainment
activities in the United States during the tax year.
Income received by a resident of Austria for services performed as
an employee and member of the regular complement of a ship or aircraft
operated in international traffic is exempt from U.S. income tax.
Barbados
Income that residents of Barbados receive for performing personal
services as independent contractors or self-employed individuals
(independent personal services) in the 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 89 days during the
tax year,
- Earn net income for independent services provided to U.S.
residents that is not more than $5,000 (there is no dollar limit if
the contractors are not U.S. residents), and
- Do not have a regular base available in the United States
for performing the services.
If they have a regular base available in the United States but
otherwise meet the conditions for exemption, they are taxed only on
the income attributable to the regular base.
Income that residents of Barbados receive for personal services
performed in the United States as employees (dependent personal
services) is exempt from U.S. tax if the residents meet four
requirements.
- They are in the United States for no more than 183 days
during the calendar year.
- The income earned in the calendar year in the United States
is not more than $5,000.
- Their income is paid by or for an employer who is not a U.S.
resident.
- The income is not borne by a permanent establishment or
regular base of the employer in the United States.
Income of a Barbadian resident from employment as a member of the
regular complement of a ship or aircraft operated in international
traffic is exempt from U.S. tax.
These exemptions do not apply to Barbadian resident public
entertainers (such as theater, motion picture, radio, or television
artists, musicians, or athletes) who receive gross receipts of more
than $250 per day or $4,000 in the tax year, not including reimbursed
expenses, from their entertainment activities in the United States.
However, the exemptions do apply regardless of these limits on gross
receipts if the entertainer's visit to the United States is
substantially supported by Barbadian public funds or if the
entertainer's services are provided to a nonprofit organization.
Belgium
Income that residents of Belgium receive for performing personal
services as independent contractors or self-employed individuals
(independent personal services) in the United States during the tax
year is exempt from U.S. income tax if the residents:
- Are present in the United States less than 183 days during
the tax year, and
- Do not maintain a fixed base in the United States for a
period or periods that total more than 182 days during the tax
year.
If they do not meet condition (2), they are taxed on the income
attributed to the fixed base.
The exemption for independent personal services does not apply to
individuals who are public entertainers (theater, motion picture, or
television artists, musicians, or athletes), if they are in the United
States for more than 90 days during the tax year or if their pay for
services as public entertainers is more than $3,000.
Income that residents of Belgium receive for labor or personal
services performed in the United States as employees (dependent
personal services), including services as an officer of a corporation,
is exempt from U.S. income tax if the residents meet three
requirements.
- They are present in the United States less than 183 days
during the tax year.
- They are employees of a resident of Belgium or of a
permanent establishment in Belgium.
- Their income is not borne by a permanent establishment that
the employer has in the United States.
Income for services performed by an individual as an employee
aboard a ship or an aircraft registered in Belgium and operated by a
resident of Belgium in international traffic is exempt from U.S. tax
if the individual is a member of the regular complement of the ship or
aircraft.
These exemptions do not apply to fees received by a resident of
Belgium for services performed as a director of a U.S. corporation if
the fees are treated as a distribution of profits and cannot be taken
as a deduction by the corporation.
Canada
Income that residents of Canada receive for personal services as
independent contractors or self-employed individuals (independent
personal services) that they perform during the tax year in the United
States (except as public entertainers) is exempt from U.S. tax if they
do not have a fixed base regularly available to them in the United
States for performing the services. If they have a fixed base
available in the United States, they are taxed on the income
attributable to the fixed base.
Income that residents of Canada receive for personal services
performed as employees (dependent personal services) in the United
States (except as public entertainers) is exempt from U.S. tax if it
is not more than $10,000 for the year. If the income is more than
$10,000 for the year, it is exempt only if:
- The residents are present in the United States for no more
than 183 days during the calendar year, and
- The income is not borne by a U.S. resident employer or by a
permanent establishment or fixed base of an employer in the United
States.
These exemptions do not apply to public entertainers (such as
theater, motion picture, radio, or television artists, musicians, or
athletes) from Canada who derive more than $15,000 in gross receipts,
including reimbursed expenses, from their entertainment activities in
the United States during the calendar year. However, the exemptions do
apply, regardless of this $15,000 limit, to athletes participating in
team sports in leagues with regularly scheduled games in both Canada
and the United States.
Pay received by a resident of Canada for employment regularly done
in more than one country on a ship, aircraft, motor vehicle, or train
operated by a Canadian resident is exempt from U.S. tax.
China, People's Republic of
Income that residents of the People's Republic of China receive for
personal services as independent contractors or self-employed
individuals (independent personal services) that they perform during
the tax year in the United States (except as athletes or public
entertainers) is exempt from U.S. income tax if the residents:
- Are present in the United States for no more than 183 days
in the calendar year, and
- Do not have a fixed base regularly available in the United
States for performing the services.
If they have a fixed base available in the United States, they
are taxable on the income attributable to the fixed base.
Pay received by residents of the People's Republic of China for
services performed as employees (dependent personal services) in the
United States (except as athletes or public entertainers) is exempt
from U.S. tax if:
- The residents are present in the United States for no more
than 183 days in the calendar year,
- The pay is paid by or for an employer who is not a U.S.
resident, and
- The pay is not borne by a permanent establishment or fixed
base that the employer has in the United States.
These exemptions do not apply to directors' fees for service on the
board of directors of a U.S. corporation.
These exemptions generally do not apply to income received as a
public entertainer (such as a theater, motion picture, radio, or
television artist, musician, or athlete). However, income of athletes
or public entertainers from China participating in a cultural exchange
program agreed upon by the U.S. and Chinese governments is exempt from
U.S. tax.
Commonwealth of
Independent States
Income that residents of a C.I.S. member receive for performing
personal services in the United States is exempt from U.S. income tax
if those residents are in the United States for no more than 183 days
during the tax year.
Pay received by an employee who is a member of the regular
complement of a ship or aircraft operated in international traffic by
a C.I.S. member or a resident of a C.I.S. member is exempt from U.S.
tax.
Cyprus
Income that residents of Cyprus receive for performing personal
services as independent contractors or self-employed individuals
(independent personal services) in the United States during the tax
year is exempt from U.S. income tax if the residents:
- Are present in the United States for less than 183 days in
the tax year, and
- Do not have a fixed base regularly available to them in the
United States for performing the services.
If they have a fixed base available in the United States, they
are taxable on the income attributable to the fixed base.
Pay received by residents of Cyprus from services performed as
employees (dependent personal services), including services as an
officer of a corporation, is exempt from U.S. income tax if:
- The residents are in the United States for less than 183
days during the tax year,
- The pay is paid by or for an employer who is not a U.S.
resident, and
- The pay is not borne by a permanent establishment, fixed
base, or trade or business that the employer has in the United
States.
Pay received by a Cyprus resident for performing personal services
as an employee and member of the regular complement of a ship or
aircraft operated in international traffic by a resident of Cyprus is
exempt from U.S. tax.
These exemptions do not apply to Cyprus resident public
entertainers (theater, motion picture, radio, or television artists,
musicians, or athletes) who receive gross receipts of more than $500
per day or $5,000 for the tax year, not including reimbursed expenses,
from their entertainment activities in the United States.
Directors' fees received by residents of Cyprus for service on the
board of directors of a U.S. corporation are exempt from U.S. income
tax to the extent of a reasonable fixed amount payable to all
directors for each day of attendance at directors' meetings held in
the United States.
Czech Republic
Income that residents of the Czech Republic receive for performing
personal services as independent contractors or self-employed
individuals (independent personal services) in the United States is
exempt from U.S. income tax if the residents:
- Are present in the United States for no more than 183 days
in any 12-month period, and
- Do not have a fixed base regularly available to them in the
United States for performing the services.
If they have a fixed base available, they are taxed only on
income attributable to the fixed base.
Income that residents of the Czech Republic receive for employment
in the United States (dependent personal services) is exempt from U.S.
income tax if the following three requirements are met.
- The resident is present in the United States for no more
than 183 days in any 12-month period.
- The income is paid by, or on behalf of, an employer who is
not a U.S. resident.
- The income is not borne by a permanent establishment or a
fixed base that the employer has in the United States.
These exemptions do not apply to income residents of the Czech
Republic receive as public entertainers (such as theater, motion
picture, radio, or television artists, or musicians) or sportsmen if
their gross receipts, including reimbursed expenses, are more than
$20,000 during the tax year. Regardless of these limits, income of
Czech entertainers and sportsmen is exempt from U.S. income tax if
their visit to the United States is substantially supported by public
funds of the Czech Republic, its political subdivisions, or local
authorities, or the visit is made pursuant to a specific arrangement
between the United States and the Czech Republic.
These exemptions do not apply to directors' fees and similar
payments received by a resident of the Czech Republic as a member of
the board of directors of a company that is a resident of the United
States.
Income from employment as a member of the regular complement of a
ship or aircraft operated by a Czech enterprise in international
traffic is exempt from U.S. income tax.
Denmark
Note:
See the effective dates of the new treaty under Important
Changes at the beginning of this publication.
New treaty.
Income that residents of Den- mark receive for personal services as
independent contractors or self-employed individuals (independent
personal services) in the United States is exempt from U.S. income tax
if they do not have a fixed base regularly available to them in the
United States for performing the services. If they have a fixed base
available in the United States, they are taxed on the income
attributable to the fixed base.
Income that residents of Denmark receive for services performed in
the United States as employees (dependent personal services) is exempt
from U.S. income tax if the residents meet the following requirements.
- They are in the United States for no more than 183 days in
any 12-month period beginning or ending in the tax year.
- Their income is paid by, or on behalf of, an employer who is
not a U.S. resident.
- Their income is not borne by a permanent establishment or a
fixed base that the employer has in the United States.
These exemptions do not apply to directors' fees and similar
payments received by a resident of Denmark as a member of the board of
directors of a company that is a resident of the United States.
These exemptions do not apply to public entertainers (such as
theater, motion picture, radio, or television artists, musicians, and
athletes) from Denmark who earn more than $20,000 in gross receipts,
including reimbursed expenses, from their entertainment activities in
the United States during the tax year.
Income received by a resident of Denmark for services performed as
an employee and member of the regular complement of a ship or aircraft
operated in international traffic is exempt from U.S. income tax.
Former treaty.
Income that residents of Denmark receive for labor or personal
services (including practicing liberal professions) performed in the
United States is exempt from U.S. income tax if they are temporarily
in the United States for no more than 90 days during the tax year and
their pay is not more than $3,000.
All income for labor or personal services that residents of Denmark
perform as employees of, or under contract with, a resident,
corporation, or other entity of Denmark is exempt from U.S. income tax
if they are in the United States for no more than 180 days during the
tax year.
Egypt
Income that residents of Egypt receive for performing personal
services as independent contractors or as self-employed individuals
(independent personal services) in the United States during the tax
year is exempt from U.S. income tax if they are in the United States
for no more than 89 days during the tax year.
Income that residents of Egypt receive for labor or personal
services performed in the United States as employees (dependent
personal services), including income for services performed by an
officer of a corporation or company, is exempt from U.S. income tax if
the residents meet four requirements.
- They are in the United States for no more than 89 days
during the tax year.
- They are employees of a resident of, or a permanent
establishment in, Egypt.
- Their income is not borne by a permanent establishment that
the employer has in the United States.
- Their income is subject to Egyptian tax.
Pay received by a resident of Egypt who is an employee and member
of the regular complement of a ship or an aircraft operated in
international traffic by a resident of Egypt is exempt.
These exemptions do not apply to Egyptian resident public
entertainers (theater, motion picture, radio, or television artists,
musicians, or athletes), who earn income for services as public
entertainers (both independent and dependent personal services) if the
gross amount of the income is more than $400 for each day they are in
the United States performing the services.
Estonia
Income that residents of Estonia receive for performing personal
services as independent contractors or self-employed individuals
(independent personal services) in the United States is exempt from
U.S. income tax if the residents:
- Are in the United States for no more than 183 days in any
12-month period beginning or ending in the tax year, and
- Do not have a fixed base regularly available to them in the
United States for performing the services.
If they have a fixed base available, they are taxed on the
income attributable to the fixed base.
Income that residents of Estonia receive for services performed in
the United States as employees (dependent personal services) is exempt
from U.S. income tax if the following requirements are met.
- The resident is in the United States for no more than 183
days in any 12-month period beginning or ending in the tax
year.
- The income is paid by, or on behalf of, an employer who is
not a U.S. resident.
- The income is not borne by a permanent establishment or a
fixed base that the employer has in the United States.
These exemptions do not apply to directors' fees and similar
payments received by a resident of Estonia as a member of the board of
directors or similar body of a company that is a U.S. resident.
Income from employment as a member of the regular complement of a
ship or an aircraft operated by an Estonian enterprise in
international traffic is exempt from U.S. income tax.
These exemptions do not apply to income residents of Estonia
receive as public entertainers (such as theater, motion picture,
radio, or television artists, or musicians) or sportsmen if their
gross receipts, including reimbursed expenses, are more than $20,000
for their personal activities in the United States during the tax
year. Regardless of these limits, income of Estonian entertainers or
athletes is exempt from U.S. income tax if their visit to the United
States is wholly or mainly supported by public funds of Estonia, its
political subdivisions, or local authorities.
Finland
Income that residents of Finland receive for performing personal
services as independent contractors or self-employed individuals
(independent personal services) in the United States is exempt from
U.S. income tax if they do not have a fixed base regularly available
to them in the United States for performing the services. If they have
a fixed base available in the United States, they are taxed on the
income attributable to the fixed base.
Income that residents of Finland receive for labor or personal
services performed in the United States as employees (dependent
personal services) is exempt from U.S. income tax if the residents
meet three requirements.
- They are in the United States for no more than 183 days
during any 12-month period.
- Their income is paid by, or on behalf of, an employer who is
not a resident of the United States.
- Their income is not borne by a permanent establishment,
fixed base, or trade or business that the employer has in the United
States.
Income received for performing personal services as an employee and
member of the regular complement of a ship or aircraft operated in
international traffic by a resident of Finland is exempt from U.S.
tax.
These exemptions do not apply to income residents of Finland
receive as public entertainers or sportsmen if the gross income,
including reimbursed expenses, is more than $20,000 for their personal
activities in the United States during the calendar year.
France
Income that residents of France receive for performing personal
services as independent contractors or self-employed individuals
(independent personal services) in the United States is exempt from
U.S. income tax if they do not have a fixed base regularly available
to them in the United States for performing the services. If they have
a fixed base available in the United States, they are taxed on the
income attributable to the fixed base.
Income that residents of France receive for labor or personal
services performed in the United States as employees (dependent
personal services) is exempt from U.S. income tax if the residents
meet three requirements.
- They are in the United States for no more than 183 days in
any 12-month period.
- Their income is paid by, or on behalf of, an employer who is
not a resident of the United States.
- Their income is not borne by a permanent establishment or a
fixed base that the employer has in the United States.
Income for services performed by a resident of France as an
employee and member of the regular complement of a ship or an aircraft
operated in international traffic is exempt from tax in the United
States.
These exemptions do not apply to public entertainers (such as
theater, motion picture, radio, or television artists, musicians), or
sportsmen from France who earn more than $10,000 in gross receipts,
including reimbursed expenses, from their entertainment activities in
the United States during the tax year. Regardless of these limits,
income of French entertainers or sportsmen is exempt from U.S. tax if
their visit is principally supported by public funds of France.
These exemptions do not apply to directors' fees and similar
payments received by a resident of France as a member of the board of
directors of a company that is a resident of the United States.
Germany
Income that residents of Germany receive for performing personal
services as independent contractors or self-employed individuals
(independent personal services) in the United States is exempt from
U.S. income tax if the income is not attributable to a fixed base
regularly available in the United States.
Income that residents of Germany receive for labor or personal
services performed in the United States as employees (dependent
personal services) is exempt from U.S. tax if the residents meet three
requirements.
- They are in the United States for no more than 183 days
during the calendar year.
- The income is paid by, or on behalf of, an employer who is
not a resident of the United States.
- The income is not borne by a permanent establishment or a
fixed base that the employer has in the United States.
Pay received by a resident of Germany for services performed as an
employee and member of the regular complement of a ship or aircraft
operated in international traffic is exempt from U.S. tax.
These exemptions do not apply to directors' fees and other similar
payments received by a resident of Germany for services performed in
the United States as a member of the board of directors of a company
resident in the United States.
These exemptions do not apply to income residents of Germany
receive as public entertainers (such as theater, motion picture, radio
or television artists, or musicians) or athletes if their gross
receipts, including reimbursed expenses, are more than $20,000 during
the calendar year. Regardless of these limits, income of German
entertainers or athletes is exempt from U.S. tax if their visit to the
United States is substantially supported by public funds of Germany,
its political subdivisions, or local authorities.
Greece
Income that residents of Greece receive for labor or personal
services (including practicing liberal and artistic professions) is
exempt from U.S. income tax if they are in the United States for no
more than 183 days during the tax year and the pay is not more than
$10,000. The pay, regardless of amount, is exempt from U.S. income tax
if it is for labor or personal services performed as employees of, or
under contract with, a resident of Greece or a Greek corporation or
other entity of Greece, and if the residents are in the United States
for no more than 183 days during the tax year.
Hungary
Income that residents of Hungary receive for performing personal
services as independent contractors or self-employed individuals
(independent personal services) in the United States during the tax
year is exempt from U.S. tax if the residents:
- Are in the United States for no more than 183 days during
the tax year, and
- Do not have a fixed base regularly available in the United
States.
If they have a fixed base available in the United States, they
are taxed on the income attributable to the fixed base.
Income that residents of Hungary receive for labor or personal
services performed in the United States as employees (dependent
personal services) is exempt from U.S. income tax if the residents
meet three requirements.
- They are in the United States for no more than 183 days
during the tax year
- Their income is paid by or on behalf of an employer who is
not a resident of the United States.
- Their income is not borne by a permanent establishment or a
fixed base that the employer has in the United States.
Pay received by an employee who is a member of the regular
complement of a ship or aircraft operated by a resident of Hungary in
international traffic is also exempt.
Iceland
Income that residents of Iceland receive for performing personal
services as independent contractors or self-employed individuals
(independent personal services) in the United States during the tax
year is exempt from U.S. income tax if the residents:
- Are present in the United States for no more than 182 days
during the tax year, and
- Do not maintain a fixed base in the United States for a
period or periods totaling more than 182 days during the tax
year.
If they do not meet condition (2), they are taxed on the income
that is attributable to the fixed base.
This exemption does not apply to residents of Iceland who are
public entertainers (theater, motion picture, or television artists,
musicians, or athletes) if they are in the United States for more than
90 days during the tax year or their pay for services as public
entertainers is more than $100 per day.
Income that residents of Iceland receive for labor or personal
services performed in the United States as employees (dependent
personal services) is exempt from U.S. income tax if the employees
meet three requirements:
- They are in the United States for no more than 182 days
during the tax year.
- They are employees of a resident of Iceland or of a
permanent establishment of a resident of a state other than Iceland if
the permanent establishment is located in Iceland.
- Their income is not borne by a permanent establishment that
the employer has in the United States.
Income for services performed by an employee aboard a ship or an
aircraft operated by a resident of Iceland in international traffic or
in fishing on the high seas is exempt from U.S. tax if the individual
is a member of the regular complement of the ship or aircraft.
India
Income that residents of India receive for performing personal
services in the United States during the tax year as independent
contractors or self-employed individuals (independent personal
services) is exempt from U.S. income tax if the residents:
- Are present in the United States for no more than 89 days
during the tax year, and
- Do not have a fixed base regularly available to them in the
United States for performing the services.
If they have a fixed base available, they are taxed only on income
attributable to the fixed base.
Income that residents of India receive for personal services
performed in the United States as employees (dependent personal
services) is exempt from U.S. income tax if the residents meet three
requirements.
- They are present in the United States for no more than 183
days during the tax year.
- The income is paid by, or on behalf of, an employer who is
not a resident of the United States.
- The income is not borne by a permanent establishment, fixed
base, or trade or business the employer has in the United
States.
These exemptions do not apply to directors' fees and similar
payments received by an Indian resident as a member of the board of
directors of a company that is a U.S. resident.
Pay received by a resident of India for services performed as an
employee aboard a ship or aircraft operated by an Indian enterprise in
international traffic is exempt from U.S. tax.
These exemptions do not apply to income residents of India receive
as public entertainers (such as theater, motion picture, radio, or
television artists, or musicians) or athletes if their net income is
more than $1,500 during the tax year for their entertainment
activities in the United States. Regardless of this limit, the income
of Indian entertainers and athletes is exempt from U.S. tax if their
visit to the United States is wholly or substantially supported from
the public funds of the Indian Government, its political subdivisions,
or local authorities.
Indonesia
Income that residents of Indonesia receive for performing personal
services as individual contractors or self-employed individuals
(independent personal services) in the United States during the tax
year is exempt from U.S. income tax if the residents:
- Are present in the United States for no more than 119 days
during any consecutive 12-month period, and
- Do not have a fixed base regularly available to them in the
United States for performing the services.
If they have a fixed base available, they are taxed only on the
income attributable to the fixed base.
Income that residents of Indonesia receive for personal services
performed in the United States as employees (dependent personal
services) is exempt from U.S. income tax if the residents meet three
requirements.
- They are present in the United States no more than 119 days
during any consecutive 12-month period.
- The income is paid by, or on behalf of, an employer who is
not a resident of the United States.
- The income is not borne or reimbursed by a permanent
establishment the employer has in the United States.
Pay received by an individual for services performed as an employee
aboard a ship or aircraft operated by an Indonesian resident in
international traffic is exempt from U.S. tax if the individual is a
member of the regular complement of the ship or aircraft.
These exemptions do not apply to income residents of Indonesia
receive as public entertainers (such as theater, motion picture,
radio, or television artists, or musicians) or athletes if their gross
receipts, including reimbursed expenses, are more than $2,000 during
any consecutive 12-month period. Regardless of these limits, income of
Indonesian entertainers and athletes is exempt from U.S. tax if their
visit to the United States is substantially supported or sponsored by
the Indonesian Government and the Indonesian competent authority
certifies that the entertainers or athletes qualify for this
exemption.
Ireland
Income that residents of Ireland receive for personal services as
independent contractors or self-employed individuals (independent
personal services) in the United States is exempt from U.S. income tax
if they do not have a fixed base regularly available to them in the
United States for performing the services. If they have a fixed base
available in the United States, they are taxed on the income
attributable to the fixed base.
Income that residents of Ireland receive for services performed in
the United States as employees (dependent personal services) is exempt
from U.S. income tax if the residents meet the following requirements.
- They are in the United States for no more than 183 days in
any 12-month period beginning or ending in the tax year.
- Their income is paid by, or on behalf of, an employer who is
not a U.S. resident.
- Their income is not borne by a permanent establishment or a
fixed base that the employer has in the United States.
These exemptions do not apply to directors' fees and similar
payments received by a resident of Ireland as a member of the board of
directors of a company that is a resident of the United States.
However, amounts received for attending meetings in Ireland are not
subject to U.S. income tax.
Income received by a resident of Ireland for services performed as
an employee and member of the regular complement of a ship or aircraft
operated in international traffic is exempt from U.S. income tax.
These exemptions do not apply to public entertainers (such as
theater, motion picture, radio, or television entertainers, musicians
and athletes) from Ireland who earn more than $20,000 in gross
receipts, including reimbursed expenses, from their entertainment
activities in the United States during the tax year.
Israel
Income that residents of Israel receive for performing personal
services as independent contractors or as self-employed individuals
(independent personal services) in the United States during the tax
year is exempt from U.S. income tax if they are in the United States
for no more than 182 days during the tax year.
Income that residents of Israel receive for labor or personal
services performed in the United States as employees (dependent
personal services), including income for services performed by an
officer of a corporation or company, is exempt from U.S. income tax if
the residents meet four requirements.
- They are in the United States for no more than 182 days
during the tax year.
- They are employees of a resident of, or a permanent
establishment in, Israel.
- Their income is not borne by a permanent establishment that
the employer has in the United States.
- Their income is subject to Israeli tax.
Generally, pay received by an employee of a resident of Israel for
labor or personal services performed as a member of the regular
complement of a ship or an aircraft operated in international traffic
by a resident of Israel is exempt.
These exemptions do not apply to income that residents of Israel
receive as public entertainers (such as theater, motion picture, radio
or television artists, musicians, or athletes), if the gross amount of
the income is more than $400 for each day they are in the United
States performing the services.
Italy
Income that residents of Italy receive for performing personal
services in the United States during the tax year as independent
contractors or self-employed individuals (independent personal
services) is exempt from U.S. income tax if the residents:
- Are present in the United States for no more than 183 days
in the tax year, and
- Do not have a fixed base regularly available to them in the
United States for performing the services.
If they have a fixed base available, they are taxed only on the
income attributable to the fixed base.
Income that residents of Italy receive for personal services
performed in the United States as employees (dependent personal
services) is exempt from U.S. income tax if:
- The residents are present in the United States for not more
than 183 days during the tax year,
- The income is paid by or for an employer who is not a U.S.
resident, and
- The income is not borne by a permanent establishment or
fixed base that the employer has in the United States.
Pay received by a resident of Italy from employment regularly
exercised aboard a ship or aircraft operated by an Italian enterprise
in international traffic is exempt from U.S. tax.
These exemptions do not apply to directors' fees and similar
payments received by an Italian resident as a member of the board of
directors of a company that is a U.S. resident.
These exemptions do not apply to income residents of Italy receive
as public entertainers (such as theater, motion picture, radio, or
television artists, musicians, or athletes) if they are present in the
United States for more than 90 days during the tax year or their gross
receipts, including reimbursed expenses, are more than $12,000 during
the tax year for their entertainment activities in the United States.
Jamaica
Income that residents of Jamaica receive for the performance of
personal services as independent contractors or self-employed
individuals (independent personal services) in the 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 89 days during the
tax year,
- Do not have a fixed base regularly available to them in the
United States for performing their services, and
- Earn net income for those services that is not more than
$5,000 during the tax year if the income is from a U.S.
contractor.
If they have a fixed base available in the United States, they
are taxed only on the income that is attributable to the fixed base.
There is no dollar limit for condition (3) if the contractor is from a
country other than the United States.
Income that residents of Jamaica receive for personal services
performed in the United States as employees (dependent personal
services) is exempt from U.S. income tax if the residents meet four
requirements.
- They are in the United States for no more than 183 days
during the tax year.
- Their income is paid by or for an employer who is not a
resident of the United States.
- Their income is not borne by a permanent establishment or a
fixed base that the employer has in the United States.
- Their net income received for the services is not more than
$5,000 during the tax year.
Pay received from employment as a member of the regular complement
of a ship or an aircraft operated in international traffic by a
Jamaican enterprise is exempt.
These exemptions do not apply to income that residents of Jamaica
receive for performing services (both independent and dependent
personal services) in the United States as entertainers, such as
theater, motion picture, radio, or television artists, musicians, or
athletes, if the gross receipts (excluding reimbursements for
expenses) from the services are more than $400 a day or $5,000 for the
tax year.
Directors' fees received by residents of Jamaica for services
performed in the United States as members of boards of directors of
U.S. corporations are exempt from U.S. tax if the fees (excluding
reimbursed expenses) are not more than $400 per day for each day the
directors are present in the United States to perform the services.
Japan
Income that residents of Japan receive for performing personal
services as independent contractors or self-employed individuals
(independent personal services) in the United States during the tax
year is exempt from U.S. income tax if the residents:
- Are present in the United States for no more than 183 days
during the tax year, and
- Do not maintain a fixed base in the United States for more
than 183 days during the tax year.
If they do not meet condition (2), they are taxed on only the
income attributable to the fixed base.
This exemption does not apply to residents of Japan who are public
entertainers (theater, motion picture, or television artists,
musicians, or athletes) if they are in the United States for more than
90 days during the tax year or their pay (excluding reimbursed travel
expenses) for services as public entertainers is more than $3,000
during the tax year.
Income that residents of Japan receive for labor or personal
services performed in the United States as employees (dependent
personal services), including pay received by an officer or a member
of the board of directors of a corporation, is exempt from U.S. income
tax if the residents meet three requirements.
- They are in the United States for no more than 183 days
during the tax year.
- They are employees of a resident of Japan or of a permanent
establishment of a resident of a state other than Japan if
the permanent establishment is located in Japan.
- Their income is not borne by a permanent establishment that
the employer has in the United States.
However, the exemption does not apply in certain cases in which the
employee owns stock of the employer or is a member of the employer's
board of directors.
Pay received from employment as a member of the regular complement
of a ship or aircraft operated in international traffic by a resident
of Japan is exempt.
Kazakstan
Income that residents of Kazakstan receive for performing personal
services as independent contractors or self-employed individuals
(independent personal services) in the United States is exempt from
U.S. income tax if:
- The residents are in the United States for no more than 183
days in any consecutive 12-month period, and
- The income is not attributable to a fixed base in the United
States which is regularly available to the residents.
If the residents have a fixed base available, they are taxed
only on the income attributable to the fixed base.
Income that residents of Kazakstan receive for employment in the
United States (dependent personal services) is exempt from U.S. income
tax if the following three requirements are met.
- The resident is in the United States for no more than 183
days in any 12-month period.
- The income is paid by, or on behalf of, an employer who is
not a resident of the United States.
- The income is not borne by a permanent establishment or a
fixed base that the employer has in the United States.
Income from employment as a member of the regular complement of a
ship or aircraft operated in international traffic is exempt from U.S.
tax.
These exemptions do not apply to directors' fees and similar
payments received by a resident of Kazakstan as a member of the board
of directors or similar body of a company that is a U.S. resident.
Korea, Republic of
Income that residents of the Republic of Korea receive for
performing personal services as independent contractors or
self-employed individuals (independent personal services) in the
United States during the tax year is exempt from U.S. tax if the
residents:
- Are in the United States for no more than 182 days during
the tax year,
- Earn income for those services that is not more than $3,000
during the tax year, and
- Do not maintain a fixed base in the United States for more
than 182 days during the tax year.
If they maintain a fixed base in the United States for more
than 182 days, they are taxed on the income attributable to the fixed
base.
Income that residents of Korea receive for labor or personal
services performed in the United States as employees (dependent
personal services), including pay for services performed as an officer
of a corporation, is exempt from U.S. tax if the residents meet four
requirements.
- They are in the United States for no more than 182 days
during the tax year.
- They are employees of a resident of Korea or of a permanent
establishment maintained in Korea.
- Their compensation is not borne by a permanent establishment
that the employer has in the United States.
- Their income for those services is not more than
$3,000.
Pay received by employees who are members of the regular complement
of a ship or aircraft operated by a resident of Korea in international
traffic is exempt.
Latvia
Income that residents of Latvia receive for performing personal
services as independent contractors or self-employed individuals
(independent personal services) in the United States is exempt from
U.S. income tax if the residents:
- Are in the United States for no more than 183 days in any
12-month period beginning or ending in the tax year, and
- Do not have a fixed base regularly available to them in the
United States for performing the services.
If they have a fixed base available, they are taxed only on the
income attributable to the fixed base.
Income that residents of Latvia receive for services performed in
the United States as employees (dependent personal services) is exempt
from U.S. income tax if the following requirements are met.
- The resident is in the United States for no more than 183
days in any 12-month period beginning or ending in the tax
year.
- The income is paid by, or on behalf of, an employer who is
not a U.S. resident.
- The income is not borne by a permanent establishment or a
fixed base that the employer has in the United States.
These exemptions do not apply to directors' fees and similar
payments received by a resident of Latvia as a member of the board of
directors or similar body of a company that is a U.S. resident.
Income from employment as a member of the regular complement of a
ship or an aircraft operated by a Latvian enterprise in international
traffic is exempt from U.S. income tax.
These exemptions do not apply to income residents of Latvia receive
as public entertainers (such as theater, motion picture, radio, or
television artists, or musicians) or sportsmen if their gross
receipts, including reimbursed expenses, are more than $20,000 for
their personal activities in the United States during the tax year.
Regardless of these limits, income of Latvian entertainers or athletes
is exempt from U.S. income tax if their visit to the United States is
wholly or mainly supported by public funds of Latvia, its political
subdivisions, or local authorities.
Lithuania
Income that residents of Lithuania receive for performing personal
services as independent contractors or self-employed individuals
(independent personal services) in the United States is exempt from
U.S. income tax if the residents:
- Are in the United States for no more than 183 days in any
12-month period beginning or ending in the tax year, and
- Do not have a fixed base regularly available to them in the
United States for performing the services.
If they have a fixed base available, they are taxed only on the
income attributable to the fixed base.
Income that residents of Lithuania receive for services performed
in the United States as employees (dependent personal services) is
exempt from U.S. income tax if the following requirements are met.
- The resident is in the United States for no more than 183
days in any 12-month period beginning or ending in the tax
year.
- The income is paid by, or on behalf of, an employer who is
not a U.S. resident.
- The income is not borne by a permanent establishment or a
fixed base that the employer has in the United States.
These exemptions do not apply to directors' fees and similar
payments received by a resident of Lithuania as a member of the board
of directors or similar body of a company that is a U.S. resident.
Income from employment as a member of the regular complement of a
ship or an aircraft operated by a Lithuanian enterprise in
international traffic is exempt from U.S. income tax.
These exemptions do not apply to income residents of Lithuania
receive as public entertainers (such as theater, motion picture,
radio, or television artists, or musicians) or sportsmen if their
gross receipts, including reimbursed expenses, are more than $20,000
for their personal activities in the United States during the tax
year. Regardless of these limits, income of Lithuanian entertainers or
athletes is exempt from U.S. income tax if their visit to the United
States is wholly or mainly supported by public funds of Lithuania, its
political subdivisions, or local authorities.
Luxembourg
Note:
See the effective dates of the new treaty under Important
Changes at the beginning of this publication.
New treaty.
Income that residents of Luxembourg receive for personal services
as independent contractors or self-employed individuals (independent
personal services) in the United States is exempt from U.S. income tax
if they do not have a fixed base regularly available to them in the
United States for performing the services. If they have a fixed base
available in the United States, they are taxed on the income
attributable to the fixed base.
Income that residents of Luxembourg receive for services performed
in the United States as employees (dependent personal services) is
exempt from U.S. income tax if the residents meet the following
requirements.
- They are in the United States for no more than 183 days in
any 12-month period beginning or ending in the tax year.
- Their income is paid by, or on behalf of, an employer who is
not a U.S. resident.
- Their income is not borne by a permanent establishment or a
fixed base that the employer has in the United States.
These exemptions do not apply to directors' fees and similar
payments received by a resident of Luxembourg for services performed
in the United States as a member of the board of directors of a
company that is a resident of the United States.
These exemptions do not apply to public entertainers (such as
theater, motion picture, radio, or television artists, musicians, or
athletes) from Luxembourg who earn more than $10,000 in gross
receipts, including reimbursed expenses, from their entertainment
activities in the United States during the tax year.
Income received by a resident of Luxembourg for services
continuously or predominantly performed as an employee of a ship or
aircraft operated in international traffic by a Luxembourg enterprise
may be taxed by Luxembourg.
Former treaty.
Income (other than corporate directors' fees) that residents of
Luxembourg receive for labor or personal services performed in the
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 180 days
during the tax year and the income is not more than $3,000.
All income (other than corporate directors' fees) that residents of
Luxembourg receive for labor or personal services performed in the
United States as an employee is exempt from U.S. income tax if:
- The residents are in the United States for no more than 180
days during the tax year, and
- The income is borne by an employer that is a resident or
corporation of Luxembourg, or a permanent establishment of a U.S.
enterprise in Luxembourg.
Mexico
Income that residents of Mexico receive for performing personal
services as independent contractors or self-employed individuals
(independent personal services) in the United States is exempt from
U.S. income tax if the residents:
- Are in the United States for no more than 183 days in a
12-month period, and
- Do not have a fixed base that they regularly use for
performing the services.
If they have a fixed base available, they are taxed only on
income attributable to the fixed base.
Income that residents of Mexico receive for employment in the
United States (dependent personal services) is exempt from U.S. tax if
the following three requirements are met.
- The resident is present in the United States for no more
than 183 days in a 12-month period.
- The income is paid by, or on behalf of, an employer who is
not a resident of the United States.
- The income is not borne by a permanent establishment or
fixed base that the employer has in the United States.
These exemptions do not apply to director's fees and similar
payments received by a resident of Mexico for services performed
outside Mexico as a director or overseer of a company that is a U.S.
resident.
These exemptions do not apply to income residents of Mexico receive
as public entertainers (such as theater, motion picture, radio, or
television artists, or musicians) or athletes if the income, including
reimbursed expenses, is more than $3,000 during the tax year for their
entertainment activities in the United States. This includes income
from activities performed in the United States relating to the
entertainer or athlete's reputation, such as endorsements of
commercial products. Regardless of this limit, the income of Mexican
entertainers and athletes is exempt from U.S. tax if their visit to
the United States is substantially supported by public funds of
Mexico, its political subdivisions, or local authorities.
Morocco
Income that residents of Morocco receive for performing personal
services as independent contractors or as self-employed persons
(independent personal services) in the 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 182 days during
the tax year,
- Do not maintain a fixed base in the United States for more
than 89 days during the tax year, and
- Earn total income for those services that is not more than
$5,000.
If they have a fixed base in the United States for more than 89
days, they are taxed only on the income attributable to the fixed
base.
Income that residents of Morocco receive for labor or personal
services performed in the United States as employees (dependent
personal services) is exempt from U.S. income tax if the residents
meet three requirements.
- They are in the United States for less than 183 days during
the tax year.
- They are employees of a resident of Morocco or of a
permanent establishment of a resident of a country other than Morocco
if the permanent establishment is located in Morocco.
- Their income is not borne by a permanent establishment that
the employer has in the United States.
Compensation received for services performed by a member of the
board of directors of a corporation does not qualify for this
exemption.
Income received by an individual for performing labor or personal
services as an employee aboard a ship or an aircraft operated in
international traffic by a Moroccan resident is exempt from U.S.
income tax if the individual is a member of the regular complement of
the ship or aircraft.
These exemptions do not apply to income received for services (both
independent and dependent personal services) performed in the United
States by professional entertainers, including theater, film, radio,
and television performers, musicians, and athletes, unless the
services are performed by, or for the account of, a Moroccan nonprofit
organization.
Netherlands
Income that residents of the Netherlands receive for performing
personal services as independent contractors or self-employed
individuals (independent personal services) in the United States is
exempt from U.S. income tax if the income is not attributable to a
fixed base in the United States that is regularly available for
performing the services.
Income that residents of the Netherlands receive for employment in
the United States (dependent personal services) is exempt from U.S.
income tax if the following three requirements are met.
- The resident is in the United States for no more than 183
days during the tax year.
- The income is paid by, or on behalf of, an employer who is
not a U.S. resident.
- The income is not borne by a permanent establishment or
fixed base the employer has in the United States.
Income received by a Netherlands resident for employment as a
member of the regular complement of a ship or aircraft operated in
international traffic is exempt from U.S. tax.
These exemptions do not apply to directors' fees and other similar
payments received by a resident of the Netherlands for services
performed outside the Netherlands as a member of the board of
directors of a company resident in the United States.
These exemptions do not apply to income residents of the
Netherlands receive as public entertainers (such as theater, motion
picture, radio, or television artists, or musicians) or athletes if
the gross income, including reimbursed expenses, is more than $10,000.
New Zealand
Income that residents of New Zealand receive for performing
personal services as independent contractors or self-employed
individuals (independent personal services) in the United States in
any tax year is exempt from U.S. income tax if the residents:
- Are present in the United States for no more than 183 days
during any consecutive 12-month period, and
- Do not have a fixed base regularly available to them in the
United States for performing the services.
If they have a fixed base available in the United States, they
are taxed on the income attributable to the fixed base.
Income that residents of New Zealand receive for labor or personal
services performed in the United States as employees (dependent
personal services) is exempt from U.S. income tax if the residents
meet these requirements.
- They are present in the United States for no more than 183
days in any consecutive 12-month period.
- Their income is paid by or on behalf of an employer that is
not a resident of the United States.
- Their income is not borne by a permanent establishment or
fixed base of the employer in the United States.
Pay received by a New Zealand resident as an employee and member of
the regular complement of a ship or aircraft operated in international
traffic is exempt from U.S. tax.
The exemption from U.S. tax on income from both independent and
dependent personal services does not apply to public entertainers
(artists, athletes, etc.) from New Zealand who earn more than $10,000
in gross receipts, including reimbursed expenses, from their
entertainment activities in the United States during the tax year.
Norway
Income that residents of Norway receive for performing personal
services as independent contractors or self-employed individuals
(independent personal services) in the United States during the tax
year is exempt from U.S. income tax if the residents:
- Are present in the United States for no more than 182 days
during the tax year, and
- Do not maintain a fixed base in the United States for more
than 182 days during the tax year.
If they do not meet requirement (2), they are taxed only on the
income attributable to the fixed base.
This exemption does not apply to residents of Norway who are public
entertainers (theater, motion picture, or television artists,
musicians, or athletes) if they are in the United States for more than
90 days during the tax year or their pay for services as public
entertainers is more than $10,000 during the tax year.
Income that residents of Norway receive for labor or personal
services performed in the United States as employees (dependent
personal services) is exempt from U.S. income tax if the residents
meet three requirements.
- They are in the United States less than 183 days during the
tax year.
- They are employees of a resident of Norway or of a permanent
establishment of a resident of a state other than Norway if the
permanent establishment is situated in Norway.
- Their income is not borne by a permanent establishment that
the employer has in the United States.
However, the exemption does not apply to a resident of Norway who
performs services as an employee aboard a ship or an aircraft operated
by a United States resident in international traffic or in fishing on
the high seas if the resident of Norway is a member of the regular
complement of the ship or aircraft.
Pakistan
Residents of Pakistan who perform personal services (including
professional services) for or on behalf of a resident of Pakistan
while in the United States for no more than 183 days during the tax
year are exempt from U.S. income tax on the income from the services
if they are subject to Pakistani tax.
Philippines
Income that residents of the Philippines receive for performing
personal services as independent contractors or as self-employed
individuals (independent personal services) in the 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 89 days during the
tax year,
- Earn gross income for those services that is not more than
$10,000 for the tax year if the income is from U.S. contractors,
and
- Do not have a fixed base regularly available to them in the
United States for performing their services.
If they have a fixed base available in the United States, they
are taxed only on the income attributable to the fixed base. There is
no dollar limit for condition (2) if the contractor is a resident of a
country other than the United States.
Income that residents of the Philippines receive for personal
services performed in the United States as employees (dependent
personal services) is exempt from U.S. income tax if the residents
meet three requirements.
- They are in the United States for no more than 89 days
during the tax year.
- They are employees of a resident of the Philippines or of a
permanent establishment maintained in the Philippines.
- Their income is not borne by a permanent establishment that
the employer has in the United States.
Pay received by an employee of a resident of the Philippines for
personal services performed as a member of the regular complement of a
ship or an aircraft operated in international traffic by a resident of
the Philippines is exempt.
These exemptions do not apply to income residents of the
Philippines receive for performing services (both independent and
dependent personal services) in the United States as entertainers,
such as theater, motion picture, radio, or television artists,
musicians, or athletes, if the income is more than $100 a day or
$3,000 for the tax year. Regardless of these limits, income of
Philippine entertainers is exempt from U.S. tax if their visit to the
United States is substantially supported or sponsored by the
Philippine Government and the entertainers are certified as qualified
for this exemption by the Philippine competent authority.
Poland
Income that residents of Poland receive for performing personal
services as independent contractors or self-employed individuals
(independent personal services) in the United States is exempt from
U.S. income tax if they are in the United States for no more than 182
days during the tax year.
Income that residents of Poland receive for labor or personal
services performed as employees (dependent personal services),
including services performed by an officer of a corporation or
company, in the United States during the tax year is exempt from U.S.
income tax if the residents meet three requirements.
- They are in the United States for no more than 182 days
during the tax year.
- Their income is paid by or on behalf of an employer who is
not a U.S. resident.
- Their income is not borne by a permanent establishment that
the employer has in the United States.
Pay received by employees who are members of the regular complement
of a ship or aircraft operated by a resident of Poland in
international traffic is exempt.
Portugal
Income that residents of Portugal receive for performing personal
services as independent contractors or self-employed individuals
(independent personal services) in the United States is exempt from
U.S. income tax if the residents:
- Are in the United States for no more than 182 days in any
12-month period, and
- Do not have a fixed base regularly available to them in the
United States for performing the activities.
If they have a fixed base available, they are taxed only on the
income attributable to the fixed base.
Income that residents of Portugal receive for employment in the
United States (dependent personal services) is exempt from U.S. income
tax if the following three requirements are met.
- The resident is in the United States for no more than 183
days in any 12-month period.
- The income is paid by, or on behalf of, an employer who is
not a U.S. resident.
- The income is not borne by a permanent establishment or
fixed base that the employer has in the United States.
Income received by a resident of Portugal for employment as a
member of the regular complement of a ship or aircraft operated in
international traffic is exempt from U.S. tax.
These exemptions do not apply to income residents of Portugal
receive as public entertainers (such as theater, motion picture,
radio, or television artists, or musicians) or athletes if that
income, including reimbursed expenses, is more than $10,000. The
income of Portuguese entertainers and athletes is exempt from U.S. tax
if their visit to the United States is substantially supported by
public funds of Portugal or its political or administrative
subdivisions.
These exemptions do not apply to directors' fees and similar
payments received by a resident of Portugal for services performed
outside of Portugal as a member of the board of directors of a company
that is a resident of the United States.
Romania
Income that residents of Romania receive for performing personal
services as independent contractors or self-employed individuals
(independent personal services) in the United States during the tax
year is exempt from U.S. income tax if the residents:
- Are present in the United States for no more than 182 days
during the tax year, and
- Do not maintain a permanent establishment in the United
States with which the income is effectively connected.
Income that residents of Romania receive for labor or personal
services performed as employees (dependent personal services),
including services performed by an officer of a corporation or
company, in the United States during the tax year is exempt from U.S.
income tax if the residents meet these requirements.
- They are in the United States for no more than 182 days
during the tax year.
- They are employees of a resident of Romania or of a
permanent establishment maintained in Romania by a resident of the
United States.
- Their income is not borne by a permanent establishment that
the employer has in the United States.
These exemptions do not apply to entertainers, such as theater,
motion picture, radio, or television artists, musicians, or athletes,
who are present in the United States for more than 90 days during the
tax year (90 days or more if the entertainers are employees) or who
earn gross income as entertainers in the United States of more than
$3,000 during the tax year ($3,000 or more if they are employees).
However, the exemptions do apply, without regard to the 90
day, $3,000 requirement, if the entertainers are present in the United
States by specific arrangements between the United States and Romania.
Pay received by employees who are members of the regular complement
of a ship or aircraft operated by a resident of Romania in
international traffic is exempt.
Russia
Income that residents of Russia receive for performing personal
services as independent contractors or self-employed individuals
(independent personal services) in the United States is exempt from
U.S. income tax if:
- The residents are in the United States for no more than 183
days during the calendar year, or
- The income is not attributable to a fixed base in the United
States which is regularly available to the residents.
If the residents have a fixed base available, they are taxed
only on the income attributable to the fixed base.
Income that residents of Russia receive for employment in the
United States (dependent personal services) is exempt from U.S. income
tax if the following three requirements are met.
- The resident is in the United States for no more than 183
days during the calendar year.
- The income is paid by, or on behalf of, an employer who is
not a resident of the United States.
- The income is not borne by a permanent establishment or a
fixed base that the employer has in the United States.
However, income from employment directly connected with a place
of business that is not a permanent establishment is exempt if the
resident is present in the United States not longer than 12
consecutive months. For this purpose, a place of business means a
construction site, assembly or installation project, or drilling
operation.
Income from employment as a member of the regular complement of a
ship or aircraft operated in international traffic is exempt from U.S.
tax.
Income from technical services directly connected with the
application of a right or property giving rise to a royalty is exempt
if those services are provided as part of a contract granting the use
of the right or property.
These exemptions do not apply to directors' fees and similar
payments received by a resident of Russia as a member of the board of
directors or similar body of a company that is a U.S. resident.
Slovak Republic
Income that residents of the Slovak Republic receive for performing
personal services as independent contractors or self-employed
individuals (independent personal services) in the United States is
exempt from U.S. income tax if the residents:
- Are present in the United States for no more than 183 days
in any 12-month period, and
- Do not have a fixed base regularly available to them in the
United States for performing the activities.
If they have a fixed base available, they are taxed only on
income attributable to the fixed base.
Income that residents of the Slovak Republic receive for employment
in the United States (dependent personal services) is exempt from U.S.
income tax if the following three requirements are met.
- The resident is present in the United States for no more
than 183 days in any 12-month period.
- The income is paid by, or on behalf of, an employer who is
not a U.S. resident.
- The income is not borne by a permanent establishment or a
fixed base that the employer has in the United States.
These exemptions do not apply to income residents of the Slovak
Republic receive as public entertainers (such as theater, motion
picture, radio, or television artists, or musicians) or sportsmen if
their gross receipts, including reimbursed expenses, are more than
$20,000 during the tax year. Regardless of these limits, income of
Slovak entertainers and sportsmen is exempt from U.S. income tax if
their visit to the United States is substantially supported by public
funds of the Slovak Republic, its political subdivisions, or local
authorities, or the visit is made pursuant to a specific arrangement
between the United States and the Slovak Republic.
These exemptions do not apply to directors' fees and similar
payments received by a resident of the Slovak Republic for services
performed in the United States as a member of the board of directors
of a company that is a resident of the United States.
Income from employment as a member of the regular complement of a
ship or aircraft operated by a Slovak enterprise in international
traffic is exempt from U.S. income tax.
South Africa
Income that residents of South Africa receive for performing
personal services as independent contractors or self-employed
individuals (independent personal services) in the United States is
exempt from U.S. income tax if the residents:
- Are in the United States for no more than 183 days in any
12-month period beginning or ending in the tax year, and
- Do not have a fixed base regularly available to them in the
United States for performing the services.
If they have a fixed base available, they are taxed only on
income attributable to the fixed base.
Income that residents of South Africa receive for services
performed in the United States as employees (dependent personal
services) is exempt from U.S. income tax if the following requirements
are met.
- The resident is in the United States for no more than 183
days in any 12-month period beginning or ending in the tax
year.
- The income is paid by, or on behalf of, an employer who is
not a U.S. resident.
- The income is not borne by a permanent establishment or a
fixed base that the employer has in the United States.
These exemptions do not apply to directors' fees and similar
payments received by a resident of South Africa for services performed
in the United States as a member of the board of directors of a
company resident in the United States.
These exemptions do not apply to income residents of South Africa
receive as public entertainers (such as theater, motion picture, radio
or television artists, or musicians) or athletes if their gross
receipts, including reimbursed expenses, are more than $7,500 during
the tax year. Regardless of these limits, income of South African
entertainers or athletes is exempt from U.S. income tax if their visit
to the United States is wholly or mainly supported by public funds of
South Africa, its political subdivisions, or local authorities.
Income received by a resident of South Africa for services
performed as an employee and member of the complement of a ship or
aircraft operated in international traffic is exempt from U.S. income
tax.
Spain
Income that residents of Spain receive as independent contractors
or self-employed individuals (independent personal services) in the
United States is exempt from U.S. income tax if the residents do not
have a fixed base available to them in the United States for
performing the services. If they have a fixed base, they are taxed
only on the income attributable to the fixed base.
Income that residents of Spain receive for personal services
performed in the United States as employees (dependent personal
services) is exempt from U.S. income tax if:
- The residents are present in the United States no more than
183 days in any 12-month period,
- The income is paid by, or on behalf of, an employer who is
not a U.S. resident, and
- The income is not borne by a permanent establishment or
fixed base the employer has in the United States.
Pay received by employees who are members of a regular complement
of a ship or aircraft operated in international traffic by a Spanish
enterprise may be taxed by Spain.
These exemptions do not apply to public entertainers (such as
theater, motion picture, radio, or television artists, or musicians)
or athletes from Spain who earn more than $10,000 in income, including
reimbursed expenses, from their entertainment activities in the United
States during the tax year. Regardless of these limits, Spanish
entertainers and athletes are exempt from U.S. tax if their visit to
the United States is substantially supported by public funds of Spain,
a political subdivision, or local authority.
Sweden
Income that residents of Sweden receive for performing personal
services as independent contractors or self-employed individuals
(independent personal services) in the United States during the tax
year is exempt from U.S. income tax if they do not have a fixed base
regularly available to them in the United States for performing the
services. If they have a fixed base available in the United States,
they are taxed on the income attributable to the fixed base.
Income that residents of Sweden receive for labor or personal
services performed in the United States as employees (dependent
personal services) is exempt from U.S. income tax if the residents
meet three requirements.
- They are in the United States for no more than 183 days
during any consecutive 12-month period.
- Their income is paid by, or on behalf of, an employer who is
not a resident of the United States.
- Their income is not borne by a permanent establishment or a
fixed base that the employer has in the United States.
Income received by a resident of Sweden for employment as a member
of the regular complement of a ship or aircraft operated in
international traffic is exempt from U.S. tax.
These exemptions do not apply to income residents of Sweden receive
as public entertainers (such as theater, motion picture, radio, or
television artists, or musicians) or athletes if the gross income,
including reimbursed expenses, is more than $6,000 for any 12-month
period.
These exemptions do not apply to directors' fees received by a
resident of Sweden for services performed outside of Sweden as a
member of the board of directors of a company that is a resident of
the United States.
Switzerland
Income that residents of Switzerland receive for personal services
as independent contractors or self-employed individuals (independent
personal services) that they perform during the tax year in the United
States is exempt from U.S. income tax if they do not have a fixed base
regularly available to them in the United States for performing the
services. If they have a fixed base available in the United States,
they are taxed on the income attributable to the fixed base.
Income that residents of Switzerland receive for services performed
in the United States as employees (dependent personal services) is
exempt from U.S. income tax if the residents meet the following
requirements.
- They are in the United States for no more than 183 days in
any 12-month period beginning or ending in the tax year.
- Their income is paid by, or on behalf of, an employer who is
not a U.S. resident.
- Their income is not borne by a permanent establishment or a
fixed base that the employer has in the United States.
These exemptions do not apply to directors' fees and similar
payments received by a resident of Switzerland for services performed
in the United States as a member of the board of directors of a
company resident in the United States.
These exemptions do not apply to public entertainers (such as
theater, motion picture, radio, or television entertainers, musicians
and athletes) from Switzerland who earn more than $10,000 in gross
receipts, including reimbursed expenses, from their entertainment
activities in the United States during the tax year.
Income received by a resident of Switzerland for services performed
as an employee and member of the regular complement of a ship or
aircraft operated in international traffic is exempt from U.S. income
tax.
Thailand
Income that residents of Thailand receive for performing personal
services as independent contractors or as self-employed individuals
(independent personal services) in the 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 89 days during the
tax year, and
- Do not have a fixed base regularly available to them in the
United States for performing their services.
If they have a fixed base available in the United States, they
are taxed only on the income attributable to the fixed base.
This exemption does not apply if a resident of Thailand earns more
than $10,000 for independent personal services and that income is paid
by a U.S. resident or borne by a permanent establishment or fixed base
in the United States.
Income that residents of Thailand receive for services performed in
the United States as employees (dependent personal services) is exempt
from U.S. income tax if the following requirements are met.
- The resident is in the United States for no more than 183
days in any 12-month period beginning or ending in the tax
year.
- The income is paid by, or on behalf of, an employer who is
not a U.S. resident.
- The income is not borne by a permanent establishment or a
fixed base that the employer has in the United States.
These exemptions do not apply to directors' fees and similar
payments received by a resident of Thailand for services performed
outside of Thailand as a member of the board of directors of a company
that is a resident of the United States.
These exemptions do not apply to income residents of Thailand
receive for performing services in the United States as entertainers
(such as theater, motion picture, radio, or television artists,
musicians) and athletes, if the income is more than $100 a day or
$3,000 for the tax year. Regardless of these limits, income of Thai
entertainers is exempt from U.S. tax if their visit to the United
States is substantially supported by public funds of Thailand or its
poilitical subdivisions or local authorities.
Pay received by employees of a ship or aircraft operated in
international traffic by a Thai enterprise may be taxed by Thailand.
Trinidad and Tobago
Income (including reimbursed travel expenses) that residents of
Trinidad and Tobago receive during the tax year for personal services
performed in the United States is exempt from U.S. income tax if the
individuals are in the United States for no more than 183 days during
the tax year and either:
- The residents are employees of a resident of a country other
than the United States or are employees of a permanent establishment
of a U.S. resident outside the United States and the income is not
deducted in figuring the profits of a permanent establishment in the
United States, or
- The income is not more than $3,000 (excluding reimbursed
travel expenses).
These exemptions do not apply to the professional earnings of
public entertainers such as actors, musicians, and professional
athletes or to any person providing their services if the pay is more
than $100 per day (excluding reimbursed travel expenses).
Pay received by members of the regular complement of a ship or
aircraft operated in international traffic by a resident of Trinidad
and Tobago is exempt from U.S. tax.
Tunisia
Income that residents of Tunisia receive for performing personal
services as independent contractors or self-employed individuals
(independent personal services) in the United States are exempt from
U.S. income tax if:
- They are in the United States for no more than 183 days
during the tax year,
- They do not have a fixed base regularly available in the
United States for performing the services, and
- The gross income for the tax year from U.S. residents for
services performed in the United States is no more than $7,500.
If they do not meet condition (2), they are taxed on the income
that is attributable to the fixed base.
Income that residents of Tunisia receive for personal services
performed in the United States as employees (dependent personal
services) is exempt from U.S. income tax if:
- The residents are in the U.S. for no more than 183 days
during the tax year,
- Their income is paid by, or on behalf of, an employer who is
not a resident of the United States, and
- Their income is not borne by a permanent establishment or
fixed base the employer has in the United States.
Pay received by employees who are members of the regular complement
of a ship or aircraft operated by an enterprise in international
traffic is exempt from U.S. tax if the place of management of the
enterprise is in Tunisia.
These exemptions do not apply to income residents of Tunisia
receive as public entertainers (such as theater, motion picture,
radio, or television artists and musicians) or athletes if their gross
receipts, including reimbursed expenses, are more than $7,500 during
the tax year.
These exemptions do not apply to fees received by a resident of
Tunisia for services performed as a director of a U.S. corporation if
the fees are treated as a distribution of profits and cannot be taken
as a deduction by the corporation.
Turkey
Income that residents of Turkey receive for performing personal
services as independent contractors or self-employed individuals
(independent personal services) in the United States is exempt from
U.S. income tax if the residents:
- Are in the United States for purposes of performing the
services or activities for no more than 183 days in any 12-month
period, and
- Do not have a fixed base regularly available to them in the
United States for performing the services.
If they have a fixed base available, they are taxed only on
income attributable to the fixed base.
Income that residents of Turkey receive for services performed in
the United States as employees (dependent personal services) is exempt
from U.S. income tax if the following requirements are met.
- The resident is in the United States for no more than 183
days in any 12-month period.
- The income is paid by, or on behalf of, an employer who is
not a U.S. resident.
- The income is not borne by a permanent establishment or a
fixed base that the employer has in the United States.
These exemptions do not apply to directors' fees and similar
payments received by a resident of Turkey for services provided in the
United States as a member of the board of directors of a company that
is a resident of the United States.
These exemptions do not apply to income residents of Turkey receive
as public entertainers (such as theater, motion picture, radio, or
television artists, or musicians) or athletes if their gross receipts
are more than $3,000 during the tax year for their entertainment
activities in the United States. If their visit to the United States
is substantially supported by a Turkish non-profit organization or
from the public funds of Turkey, its political subdivisions, or local
authorities, the income is taxed as independent personal services or
dependent personal services.
These exemptions do not apply to a resident of Turkey who performs
services as a member of the regular complement of a ship or an
aircraft operated by a United States resident in international
traffic.
Ukraine
Note:
See the effective dates of the new treaty under Important
Changes at the beginning of this publication. For information on
the old provisions, see Commonwealth of Independent States.
Income that residents of Ukraine receive for performing personal
services as independent contractors or self-employed individuals
(independent personal services) in the United States is exempt from
U.S. income tax if the income is not attributable to a fixed base in
the United States that is regularly available for performing the
services.
Income that residents of Ukraine receive for employment in the
United States (dependent personal services) is exempt from U.S. income
tax if the following three requirements are met.
- The resident is in the United States for no more than 183
days during the tax year.
- The income is paid by, or on behalf of, an employer who is
not a resident of the United States.
- The income is not borne by a permanent establishment or a
fixed base that the employer has in the United States.
These exemptions do not apply to directors' fees and similar
payments received by a resident of Ukraine for services performed
outside of Ukraine as a member of the board of directors of a company
that is a resident of the United States.
These exemptions generally do not apply to income received as a
public entertainer (such as a theater, motion picture, radio, or
television artist, musician, or athlete). However, income of Ukranian
entertainers and sportsmen is exempt from U.S. income tax if their
visit to the United States is substantially supported by public funds
of Ukraine, its political subdivisions, or local authorities, or the
visit is made pursuant to a specific arrangement between the United
States and Ukraine.
Income from employment as a member of the regular complement of a
ship or aircraft operated in international traffic is exempt from U.S.
tax.
United Kingdom
Income that residents of the United Kingdom receive for performing
personal services as independent contractors or self-employed
individuals (independent personal services) in the United States
during the tax year is exempt from U.S. tax if the residents:
- Are in the United States for no more than 183 days during
the tax year, and
- Do not have a fixed base regularly available in the United
States.
Income that residents of the United Kingdom receive for labor or
personal services performed in the United States as employees
(dependent personal services) is exempt from U.S. tax if the employees
meet three requirements.
- They are in the United States for no more than 183
days.
- Their income is paid by or on behalf of an employer who is
not a resident of the United States.
- Their income is not borne by a permanent establishment or a
fixed base that the employer has in the United States.
Income for services performed by an employee and member of the
regular complement of a ship or aircraft operated in international
traffic is taxed by the country of which the employer operating the
ship or aircraft is a resident.
These exemptions do not apply to income received for services
performed in the United States as an entertainer, musician, or athlete
if the income, including reimbursed expenses, is more than $15,000 in
any tax year.
Venezuela
Income that residents of Venezuela receive for personal services as
independent contractors or self-employed individuals (independent
personal services) in the United States is exempt from U.S. income tax
if they do not have a fixed base regularly available to them in the
United States for performing the services. If they have a fixed base
available, they are taxed on the income attributable to the fixed
base.
Income that residents of Venezuela receive for services performed
in the United States as employees (dependent personal services) is
exempt from U.S. income tax if the residents meet the following
requirements.
- They are in the United States for no more than 183 days in
any 12-month period beginning or ending in the tax year.
- Their income is paid by, or on behalf of, an employer who is
not a U.S. resident.
- The income is not borne by a permanent establishment or a
fixed base that the employer has in the United States.
These exemptions do not apply to directors' fees and similar
payments received by a resident of Venezuela for services performed in
the United States as a member of the board of directors of a company
resident in the United States.
Pay received by a resident of Venezuela for services performed as
an employee of a ship or an aircraft operated in international traffic
is exempt from U.S. income tax.
These exemptions do not apply to income residents of Venezuela
receive as public entertainers (such as theater, motion picture,
radio, or television artists, or musicians) or sportsmen if their
gross income, including reimbursed expenses, is more than $6,000 for
their personal activities in the United States during the tax year.
Regardless of these limits, income of Venezuelan entertainers or
athletes is exempt from U.S. income tax if their visit to the United
States is wholly or mainly supported by public funds of Venezuela, its
political subdivisions, or local authorities.
Professors, Teachers,
and Researchers
Pay of professors and teachers who are residents of the following
countries is generally exempt from U.S. income tax for 2 or 3 years if
they temporarily visit the United States to teach or do research. The
exemption applies to pay earned by the visiting professor or teacher
during the applicable period. For most of the following countries, the
applicable period begins on the date of arrival in the United States
for the purpose of teaching or engaging in research. Furthermore, for
most of the following countries, the exemption applies even if the
stay in the United States extends beyond the applicable period.
The exemption generally applies to pay received during a second
teaching assignment if both are completed within the specified time,
even if the second assignment was not arranged until after arrival in
the United States on the first assignment. For each of the countries
listed, the conditions are stated under which the pay of a professor
or teacher from that country is exempt from U.S. income tax.
If you do not meet the requirements for exemption as a teacher or
if you are a resident of a treaty country that does not have a special
provision for teachers, you may qualify under a personal services
income provision discussed earlier.
Belgium
An individual who is a resident of Belgium on the date of arrival
in the United States and who is temporarily in the United States at
the invitation of the U.S. Government, a university, or other
recognized educational institution in the United States primarily to
teach or engage in research, or both, at a university or other
accredited educational institution is exempt from U.S. income tax on
income for the teaching or research for a maximum of 2 years from the
date of arrival in the United States.
This exemption does not apply to income from research carried on
mainly for the private benefit of any person rather than in the public
interest.
China, People's Republic of
An individual who is a resident of the People's Republic of China
and who is temporarily in the United States primarily to teach,
lecture, or conduct research at a university or other accredited
educational institution or scientific research institution is exempt
from U.S. income tax on income for the teaching, lecturing, or
research for a total of not more than 3 years.
This exemption does not apply to income from research carried on
mainly for the private benefit of any person rather than in the public
interest.
Commonwealth of
Independent States
An individual who is a resident of a C.I.S. member on the date of
arrival in the United States and who is temporarily in the United
States at the invitation of the U.S. Government or an educational or
scientific research institution in the United States primarily to
teach, engage in research, or participate in scientific, technical, or
professional conferences is exempt from U.S. income tax on income for
teaching, research, or participation in these conferences for a
maximum period of 2 years.
This exemption does not apply to income from research carried on
mainly for the benefit of a private person, including a commercial
enterprise of the United States or a foreign trade organization of a
C.I.S. member.
The exemption does, however, apply if the research is conducted
through an intergovernmental agreement on cooperation.
This exemption also applies to journalists and correspondents who
are temporarily in the United States for periods not longer than 2
years and who receive their compensation from abroad. It is not
necessary that the journalists or correspondents be invited by the
U.S. Government or other appropriate institution, nor does it matter
that they are employed by a private person, including commercial
enterprises and foreign trade organizations.
Czech Republic
An individual is exempt from U.S. income tax on income for teaching
or research for up to 2 years if he or she:
- Is a resident of the Czech Republic immediately before
visiting the United States, and
- Is in the United States primarily to teach or conduct
research at a university, college, school, or other accredited
educational or research institution.
A Czech resident is entitled to these benefits only once. However,
the exemption does not apply if:
- The resident claimed during the immediate preceding period
the benefits described later under Students and Apprentices,
or
- The income is from research undertaken primarily for the
private benefit of a specific person or persons.
Denmark
Note:
See the effective dates of the new treaty under Important
Changes at the beginning of this publication.
New treaty.
There is no special provision for professors or teachers.
Former treaty.
A professor or teacher who is a resident of Denmark and temporarily
visits the United States to teach at a university, college, school, or
other educational institution for a period not longer than 2 years is
exempt from U.S. income tax on income for teaching during that period.
Egypt
An individual who is a resident of Egypt on the date of arrival in
the United States and who is temporarily in the United States
primarily to teach or engage in research, or both, at a university or
other recognized educational institution is exempt from U.S. income
tax on income from the teaching or research for a maximum of 2 years
from the date of arrival in the United States. The individual must
have been invited to the United States for a period not expected to be
longer than 2 years by the U.S. government or a state or local
government, or by a university or other recognized educational
institution in the United States.
This exemption does not apply to income from research carried on
mainly for the private benefit of any person rather than in the public
interest.
France
An individual who is a resident of France on the date of arrival in
the United States and who is temporarily in the United States at the
invitation of the U.S. Government, a university, or other recognized
educational or research institution in the United States primarily to
teach or engage in research, or both, at a university or other
educational or research institution is exempt from U.S. income tax on
income from teaching or research for a maximum of 2 years from the
date of arrival in the United States.
An individual may claim this benefit only once. Also, this benefit
and the benefits described later under Students and Apprentices,
can be claimed for no more than 5 years.
This exemption does not apply to income from research carried on
mainly for the private benefit of any person rather than in the public
interest.
Germany
A professor or teacher who is a resident of Germany and who is in
the United States for not more than 2 years to engage in advanced
study or research or teaching at an accredited educational institution
or institution engaged in research for the public benefit is exempt
from U.S. tax on income received for such study, research, or
teaching. If the individual's visit to the United States exceeds 2
years, the exemption is lost for the entire visit unless the competent
authorities of Germany and the United States agree otherwise.
The exemption does not apply to income from research carried on
mainly for the private benefit of any person rather than in the public
interest.
Greece
A professor or teacher who is a resident of Greece and who is
temporarily in the United States to teach at a university, college, or
other educational institution for a maximum of 3 years is exempt from
U.S. income tax on the income received for teaching during that
period.
Hungary
An individual who is a resident of Hungary on the date of arrival
in the United States and who is temporarily in the United States
primarily to teach or engage in research, or both, at a university or
other recognized educational institution is exempt from U.S. income
tax on income for the teaching or research for a maximum of 2 years
from the date of arrival in the United States. The individual must
have been invited to the United States for a period not expected to be
longer than 2 years by the U.S. Government or a state or local
government, or by a university or other recognized educational
institution in the United States.
The exemption does not apply to income from research carried on
mainly for the private benefit of any person rather than in the public
interest.
Iceland
An individual who is a resident of Iceland on the date of arrival
in the United States and who is temporarily in the United States at
the invitation of the U.S. Government, a university, or other
recognized educational institution in the United States primarily to
teach or engage in research, or both, at a university or other
educational institution is exempt from U.S. income tax on income for
the teaching or research for a maximum of 2 years from the date of
arrival in the United States.
This exemption does not apply to income from research carried on
mainly for the private benefit of any person rather than in the public
interest.
India
An individual is exempt from U.S. tax on income received for
teaching or research if he or she:
- Is a resident of India immediately before visiting the
United States, and
- Is in the United States to teach or engage in research at an
accredited university or other recognized educational institution in
the United States for a period not longer than 2 years.
If the individual's visit to the United States exceeds 2 years, the
exemption is lost for the entire visit.
This exemption does not apply to income from research carried on
mainly for the private benefit of any person rather than in the public
interest.
Indonesia
An individual is exempt from U.S. tax on income for teaching or
research for a maximum of 2 years from the date of arrival in the
United States if he or she:
- Is a resident of Indonesia immediately before visiting the
United States, and
- Is in the United States at the invitation of a university,
school, or other recognized educational institution to teach or engage
in research, or both, at that educational institution.
A resident of Indonesia is entitled to this exemption only once.
But this exemption does not apply to income from research carried on
mainly for the private benefit of any person.
Israel
An individual who is a resident of Israel on the date of arrival in
the United States and who is temporarily in the United States
primarily to teach or engage in research, or both, at a university or
other recognized educational institution is exempt from U.S. income
tax on income from the teaching or research for a maximum of 2 years
from the date of arrival in the United States. The individual must
have been invited to the United States for a period not expected to be
longer than 2 years by the U.S. Government or a state or local
government, or by a university or other recognized educational
institution in the United States.
This exemption does not apply to income from research carried on
mainly for the private benefit of any person rather than in the public
interest. The exemption does not apply if, during the immediately
preceding period, the benefits described in Article 24(1) of the
treaty, pertaining to students, were claimed.
Italy
A professor or teacher who is a resident of Italy on the date of
arrival in the United States and who temporarily visits the United
States to teach or conduct research at a university, college, school,
or other educational institution, or at a medical facility primarily
funded from government sources, is exempt from U.S. income tax for up
to 2 years on pay from this teaching or research.
This exemption does not apply to income from research carried on
mainly for the private benefit of any person rather than in the public
interest.
Jamaica
An individual who is a resident of Jamaica on the date of arrival
in the United States and who temporarily visits the United States to
teach or engage in research at a university, college, or other
recognized educational institution is exempt from U.S. income tax on
the income received for the teaching or research for not more than 2
years from the date of arrival in the United States. A resident of
Jamaica is entitled to this exemption only once.
This exemption does not apply to income from research carried on
mainly for the private benefit of any person rather than in the public
interest.
Japan
An individual who is a resident of Japan on the date of arrival in
the United States and who is temporarily in the United States at the
invitation of the U.S. Government, a university, or other accredited
educational institution located in the United States primarily to
teach or engage in research, or both, at a university or other
educational institution is exempt from U.S. income tax on income for
the teaching or research for a maximum of 2 years from the date of
arrival in the United States.
This exemption does not apply to income from research carried on
mainly for the private benefit of any person rather than in the public
interest.
Korea, Republic of
An individual who is a resident of the Republic of Korea on the
date of arrival in the United States and who is temporarily in the
United States primarily to teach or engage in research, or both, at a
university or other recognized educational institution is exempt from
U.S. income tax on income for the teaching or research for a maximum
of 2 years from the date of arrival in the United States. The
individual must have been invited to the United States for a period
not expected to be longer than 2 years by the U.S. Government or a
state or local government, or by a university or other recognized
educational institution in the United States.
The exemption does not apply to income from research carried on
mainly for the private benefit of any person rather than in the public
interest.
Luxembourg
Note:
See the effective dates of the new treaty under Important
Changes at the beginning of this publication.
New treaty.
A resident of Luxembourg who is temporarily in the United States at
the invitation of a U.S. university, college, school, or other
recognized educational institution only to teach or engage in
research, or both, at that educational institution is exempt from U.S.
income tax on income for the teaching or research for not more than 2
years from the date of arrival in the United States.
If the individual's visit to the United States is longer than 2
years, the exemption is lost for the entire visit unless the competent
authorities of Luxembourg and the United States agree otherwise.
This exemption does not apply to pay for research carried on for
the benefit of any person other than the educational institution that
extended the invitation.
Former treaty.
A resident of Luxembourg who is temporarily in the United States at
the invitation of a U.S. university, college, school, or other
recognized educational institution only to teach or engage in
research, or both, at that educational institution is exempt from U.S.
income tax on income for the teaching or research for not more than 2
years from the date of arrival in the United States.
This exemption does not apply to pay for research carried on for
the benefit of any person other than the educational institution that
extended the invitation.
Netherlands
An individual is exempt from U.S. income tax on income received for
teaching or research for a maximum of 2 years from the date of arrival
if he or she:
- Is a resident of the Netherlands immediately before visiting
the United States, and
- Is in the United States to teach or engage in research at a
university, college, or other recognized educational institution for
not more than 2 years.
If the individual's visit to the United States is longer than 2
years, the exemption is lost for the entire visit unless the competent
authorities of the Netherlands and the United States agree otherwise.
The exemption does not apply to income from research carried on
primarily for the private benefit of any person rather than in the
public interest. Nor does the exemption apply if the resident claimed
during the immediate preceding period the benefits described later
under Students and Apprentices.
Norway
An individual who is a resident of Norway on the date of arrival in
the United States and who is temporarily in the United States at the
invitation of the U.S. Government, a university, or other recognized
educational institution in the United States primarily to teach or
engage in research, or both, at a university or other recognized
educational institution is exempt from U.S. income tax on income for
the teaching or research for a maximum period of 2 years from the date
of arrival in the United States.
This exemption does not apply to income from research carried on
mainly for the private benefit of any person rather than in the public
interest.
Pakistan
A professor or teacher who is a resident of Pakistan and who
temporarily visits the United States to teach at a university,
college, school, or other educational institution for not longer than
2 years is exempt from U.S. income tax on the income received for
teaching for that period.
Philippines
An individual who is a resident of the Philippines on the date of
arrival in the United States and who is temporarily in the United
States primarily to teach or engage in research, or both, at a
university or other recognized educational institution is exempt from
U.S. income tax on income from the teaching or research for not more
than 2 years from the date of arrival in the United States. The
individual must have been invited to the United States for a period
not expected to be longer than 2 years by the U.S. Government or a
state or local government, or by a university or other recognized
educational institution in the United States.
This exemption does not apply to income from research carried on
mainly for the private benefit of any person rather than in the public
interest.
Poland
An individual who is a resident of Poland on the date of arrival in
the United States and who is temporarily in the United States at the
invitation of the U.S. Government, a university, or other recognized
educational institution in the United States primarily to teach or
engage in research, or both, at a university or other recognized
educational institution is exempt from U.S. income tax on income for
the teaching or research for a maximum of 2 years from the date of
arrival in the United States.
This exemption does not apply to income from research carried on
mainly for the private benefit of any person rather than in the public
interest.
Portugal
An individual who is a resident of Portugal on the date of arrival
in the United States and who is temporarily in the United States at
the invitation of the U.S. Government, a university, other accredited
educational institution, or recognized research institution in the
United States, or under an official cultural exchange program, only to
teach or engage in research, or both, at a university or educational
institution is exempt from U.S. income tax on income from teaching or
research for a maximum of 2 years from the date of arrival in the
United States. An individual is entitled to these benefits only once.
However, these benefits, and the benefits described later under
Students and Apprentices cannot be claimed either
simultaneously or consecutively.
This exemption does not apply to income from research carried on
mainly for the private benefit of any person rather than in the public
interest.
Romania
An individual who is a resident of Romania on the date of arrival
in the United States and who is temporarily in the United States at
the invitation of the U.S. Government, a university, or other
recognized educational institution in the United States primarily to
teach or engage in research, or both, at a university or other
recognized educational institution is exempt from U.S. income tax on
income for the teaching or research for a maximum of 2 years from the
date of arrival in the United States.
This exemption does not apply to income from research carried on
mainly for the private benefit of any person rather than in the public
interest.
Slovak Republic
An individual is exempt from U.S. income tax on income for teaching
or research for up to 2 years if he or she:
- Is a resident of the Slovak Republic immediately before
visiting the United States, and
- Is in the United States primarily to teach or conduct
research at a university, college, school, or other accredited
educational or research institution.
A Slovak resident is entitled to these benefits only once. However,
the exemption does not apply if:
- The resident claimed during the immediate preceding period
the benefits described later under Students and Apprentices,
or
- The income is from research undertaken primarily for the
private benefit of a specific person or persons.
Thailand
An individual who is a resident of Thailand on the date of arrival
in the United States and who is in the United States for not longer
than 2 years primarily to teach or engage in research at a university,
college, school, or other recognized educational institution is exempt
from U.S. income tax on income for the teaching or research. The
exemption from tax applies only if the visit does not exceed two years
from the date the individual first visits the United States for the
purpose of engaging in teaching or research.
This exemption does not apply to income from research carried on
mainly for the private benefit of any person rather than in the public
interest. This exemption does not apply if, during the immediately
preceding period, the benefits described in treaty Article 22(1),
pertaining to students, were claimed.
Trinidad and Tobago
An individual who is a resident of Trinidad and Tobago on the date
of arrival in the United States and who is temporarily in the United
States at the invitation of the U.S. Government, a university, or
other accredited educational institution in the United States
primarily to teach or engage in research, or both, at a university or
other accredited educational institution is exempt from U.S. income
tax on the income received for the teaching or research for a maximum
of 2 years from the date of arrival in the United States.
This exemption does not apply to income from research carried on
mainly for the private benefit of any person rather than in the public
interest. Nor does the exemption apply to income if an agreement
exists between the Governments of Trinidad and Tobago and the United
States for providing the services of these individuals.
Turkey
An individual who was a resident of Turkey immediately before
visiting the United States who is in the United States for not longer
than 2 years for the purpose of teaching or engaging in scientific
research is exempt from U.S. income tax on payments received from
outside the United States for teaching or research.
Ukraine
Note:
See the effective dates of the new treaty under Important
Changes at the beginning of this publication. For information on
the old provisions, see Commonwealth of Independent States.
New treaty.
There is no special provision for professors or teachers.
United Kingdom
A professor or teacher who is a resident of the United Kingdom on
the date of arrival in the United States and who is in the United
States for not longer than 2 years primarily to teach or engage in
research at a university, college, or other recognized educational
institution is exempt from U.S. income tax on income for the teaching
or research. If the individual's 2-year period is exceeded, the
exemption is lost for the entire visit, including the 2-year period.
The exemption does not apply to income from research carried on
mainly for the private benefit of any person rather than in the public
interest.
Venezuela
An individual who is a resident of Venezuela on the date of arrival
in the United States and who temporarily visits the United States to
teach or engage in research at a recognized educational or research
institution is exempt from U.S. income tax on the income received for
the teaching or research for not more than 2 years from the date of
arrival in the United States. This benefit can be claimed for no more
than 5 years.
The exemption does not apply to income from research carried on
mainly for the private benefit of any person rather than in the public
interest.
Students and Apprentices
Residents of the following countries who are in the United States
to study or acquire technical experience are exempt from U.S. income
tax, under certain conditions, on amounts received from abroad for
their maintenance and studies.
This exemption does not apply to the salary paid by a foreign
corporation to one of its executives, a citizen and resident of a
foreign country who is temporarily in the United States to study a
particular industry for an employer. That amount is a continuation of
salary and is not received to study or acquire experience.
For each country listed there is a statement of the conditions
under which the exemption applies to students and apprentices from
that country.
Amounts received from the National Institutes of Health (NIH) under
provisions of the Visiting Fellows Program are generally
treated as a grant, allowance, or award for purposes of whether an
exemption is provided by treaty. Amounts received from NIH under the
Visiting Associate Program and Visiting Scientist
Program are not exempt from U.S. tax as a grant, allowance, or
award.
Australia
A resident of Australia or an individual who was a resident of
Australia immediately before visiting the United States who is
temporarily here for full-time education is exempt from U.S. income
tax on payments received from outside the United States for the
individual's maintenance or education.
Austria
A student, apprentice, or business trainee who is a resident of
Austria immediately before visiting the United States and is in the
United States for the purpose of full-time education at a recognized
educational institution or full-time training is exempt from U.S.
income tax on amounts received from sources outside the United States
for the individual's maintenance, education, or training.
Apprentices and business trainees are entitled to the benefit of
this exemption for a maximum period of 3 years.
Barbados
A student or business apprentice who is a resident of Barbados on
the date of arrival in the United States and is here for full-time
education or training is exempt from U.S. income tax on payments
received from outside the United States for the individual's
maintenance, education, or training.
Nevertheless, an individual who qualifies for this exemption may
instead choose to be treated as a resident alien of the United States
for all U.S. income tax purposes. Once made, this choice applies for
the entire period that the individual remains qualified for exemption
and may not be revoked without the permission of the U.S. competent
authority.
Belgium
An individual who is a resident of Belgium on the date of arrival
in the United States and who is temporarily in the United States
primarily to study at a university or other recognized educational
institution in the United States, obtain professional training, or
study or do research as a recipient of a grant, allowance, or award
from a governmental, religious, charitable, scientific, literary, or
educational organization is exempt from U.S. income tax on the
following amounts.
- Gifts from abroad for maintenance, education, study,
research, or training.
- The grant, allowance, or award.
- Income from personal services performed in the United States
of up to $2,000 for each tax year.
An individual is entitled to the benefit of this exemption for a
maximum of 5 years.
An individual who is a resident of Belgium on the date of arrival
in the United States and who is in the United States as an employee
of, or under contract with, a resident of Belgium is exempt from U.S.
income tax for a period of 12 consecutive months on up to $5,000
received for personal services if the individual is in the United
States primarily to:
- Acquire technical, professional, or business experience from
a person other than that resident of Belgium or other than a person
related to that resident, or
- Study at an educational institution.
An individual who is a resident of Belgium on the date of arrival
in the United States and who is temporarily present in the United
States for not longer than one year as a participant in a program
sponsored by the U.S. Government primarily to train, research, or
study is exempt from U.S. income tax on income received for personal
services for the training, research, or study in the amount of
$10,000.
Canada
A full-time student, trainee, or business apprentice who is or was
a Canadian resident immediately before visiting the United States is
exempt from U.S. income tax on amounts received from sources outside
the United States for maintenance, education, or training.
Also see Publication 597,
Information on the United
States--Canada Income Tax Treaty.
China, People's Republic of
A student, business apprentice, or trainee who is a resident of the
People's Republic of China on the date of arrival in the United States
and who is present in the United States solely to obtain training,
education, or special technical experience is exempt from U.S. income
tax on the following amounts.
- Payments received from abroad for maintenance, education,
study, research, or training.
- Grants or awards from a government, scientific, educational,
or other tax-exempt organization.
- Income from personal services performed in the United States
of up to $5,000 for each tax year.
An individual is entitled to this exemption only for the time
reasonably necessary to complete the education or training.
Commonwealth of
Independent States
An individual who is a resident of a C.I.S. member and who is
temporarily in the United States primarily to study at an educational
or scientific research institution or to obtain training for
qualification in a profession or specialty is exempt from U.S. income
tax on amounts received as stipends, scholarships, or other substitute
allowances necessary to provide ordinary living expenses. An
individual is entitled to the benefit of this exemption for a maximum
of 5 years and for less than $10,000 in each tax year.
An individual who is a resident of a C.I.S. member and who is
temporarily in the United States primarily to acquire technical,
professional, or commercial experience or perform technical services
and who is an employee of, or under contract with, a resident of a
C.I.S. member is exempt from U.S. income tax on the amounts received
from that resident. Also exempt is an amount received from U.S.
sources, of not more than $10,000, that is necessary to provide for
ordinary living expenses. The exemption contained in this paragraph is
limited to one year.
An individual who is a resident of a C.I.S. member and who is
temporarily present in the United States under an exchange program
provided for by an agreement between governments on cooperation in
various fields of science and technology is exempt from U.S. income
tax on all income received in connection with the exchange program for
a period not longer than one year.
Cyprus
An individual who is a resident of Cyprus on the date of arrival in
the United States and who is temporarily here primarily to study at a
university or other recognized educational institution in the United
States, obtain professional training, or study or do research as a
recipient of a grant, allowance, or award from a governmental,
religious, charitable, scientific, literary, or educational
organization is exempt from U.S. income tax on the following amounts.
- Gifts from abroad for maintenance, education, or
training.
- The grant, allowance, or award.
- Income from personal services performed in the United States
of up to $2,000 for each tax year.
An individual is entitled to this exemption for up to 5 tax years
and for an additional period as is necessary to complete, as a
full-time student, educational requirements for a postgraduate or
professional degree from a recognized educational institution.
An individual who is a resident of Cyprus on the date of arrival in
the United States and who is temporarily here as an employee of, or
under contract with, a resident of Cyprus is exempt from U.S. income
tax for not more than one year on income from personal services for a
maximum of $7,500 if the individual is in the United States primarily
to either:
- Acquire technical, professional, or business experience from
a person other than a resident of Cyprus or other than a person
related to that resident, or
- Study at a university or other recognized educational
institution.
An individual who is a resident of Cyprus on the date of arrival in
the United States and who is temporarily here for a period of not more
than one year as a participant in a program sponsored by the U.S.
Government primarily to train, research, or study is exempt from U.S.
income tax on income for personal services for the training, research,
or study. This exemption is limited to $10,000.
Czech Republic
An individual who is a resident of the Czech Republic at the
beginning of his or her visit to the United States and who is
temporarily present in the United States is exempt from U.S. income
tax on certain amounts for a period of up to 5 years. To be entitled
to the exemption, the individual must be in the United States for the
primary purpose of:
- Studying at a university or other accredited educational
institution in the United States,
- Obtaining training required to qualify him or her to
practice a profession or professional specialty, or
- Studying or doing research as a recipient of a grant,
allowance, or award from a governmental, religious, charitable,
scientific, literary, or educational organization.
If the individual meets any of these requirements, the
following amounts are exempt from U.S. tax.
- The payments from abroad, other than compensation for
personal services, for the purpose of maintenance, education, study,
research, or training.
- The grant, allowance, or award.
- The income from personal services performed in the United
States of up to $5,000 for the tax year.
An individual who is a Czech resident at the beginning of the visit
to the United States and who is temporarily present in the United
States as an employee of, or under contract with, a Czech resident is
exempt from U.S. income tax for a period of 12 consecutive months on
up to $8,000 received for personal services if the individual is in
the United States primarily to:
- Acquire technical, professional, or business experience from
a person other than the Czech resident, or
- Study at a university or other accredited educational
institution in the United States.
An individual who is a Czech resident at the time he or she becomes
temporarily present in the United States and who is temporarily
present in the United States for a period not longer than 1 year as a
participant in a program sponsored by the U.S. government for the
primary purpose of training, research, or study, is exempt from U.S.
income tax on up to $10,000 of income from personal services for that
training, research, or study.
These exemptions do not apply to income from research undertaken
primarily for the private benefit of a specific person or persons.
Denmark
Note:
See the effective dates of the new treaty under Important
Changes at the beginning of this publication.
New treaty.
A student, apprentice, or business trainee who is a resident of
Denmark immediately before visiting the United States and is in the
United States for the purpose of full-time education at an accredited
educational institution, or full-time training, is exempt from U.S.
income tax on amounts received from sources outside the United States
for the individual's maintenance, education, or training.
Apprentices and business trainees are entitled to the benefit of
this exemption for a maximum period of 3 years.
The exemption does not apply to income from research undertaken
primarily for the private benefit of a specific person or persons.
Former treaty.
A student or apprentice who is a citizen of Denmark and lives in
the United States only to study or acquire business experience is
exempt from U.S. income tax on amounts (other than the student's own
income) received from abroad for maintenance and studies.
Egypt
An individual who is a resident of Egypt on the date of arrival in
the United States and who is temporarily in the United States
primarily to study at a university or other recognized educational
institution in the United States, obtain professional training, or
study or do research as a recipient of a grant, allowance, or award
from a governmental, religious, charitable, scientific, literary, or
educational organization is exempt from U.S. income tax on the
following amounts.
- Gifts from abroad for maintenance, education, study,
research, or training.
- The grant, allowance, or award.
- Income from personal services performed in the United States
of up to $3,000 each tax year.
An individual is entitled to the benefit of this exemption for a
maximum of 5 tax years and for any additional period of time needed to
complete, as a full-time student, educational requirements as a
candidate for a postgraduate or professional degree from a recognized
educational institution.
An individual who is a resident of Egypt on the date of arrival in
the United States and who is temporarily in the United States as an
employee of, or under contract with, a resident of Egypt is exempt
from U.S. income tax for a period of 12 consecutive months on up to
$7,500 received for personal services if the individual is in the
United States primarily to:
- Acquire technical, professional, or business experience from
a person other than that resident of Egypt or other than a person
related to that resident, or
- Study at a university or other educational
institution.
An individual who is a resident of Egypt on the date of arrival in
the United States and who is temporarily in the United States for no
more than one year as a participant in a program sponsored by the U.S.
Government primarily to train, research, or study is exempt from U.S.
income tax on income received for personal services for the training,
research, or study for a maximum of $10,000.
Estonia
An individual who is a resident of Estonia on the date of arrival
in the United States and who is temporarily in the United States
primarily to study at a university or other accredited educational
institution in the United States, obtain professional training, or
study or do research as a recipient of a grant, allowance, or award
from a governmental, religious, charitable, scientific, literary, or
educational organization is exempt from U.S. income tax on the
following amounts.
- Payments from abroad, other than compensation for personal
services, for maintenance, education, study, research, or
training.
- The grant, allowance, or award.
- Income from personal services performed in the United States
of up to $5,000 for each tax year.
An individual is entitled to the benefit of this exemption for a
maximum of 5 years.
An individual who is a resident of Estonia on the date of arrival
in the United States and who is in the United States as an employee
of, or under contract with, a resident of Estonia is exempt from U.S.
income tax for a period of 12 consecutive months on up to $8,000
received for personal services if the individual is in the United
States primarily to:
- Acquire technical, professional, or business experience from
a person other than that resident of Estonia, or
- Study at an educational institution.
An individual who is a resident of Estonia on the date of arrival
in the United States and who is temporarily present in the United
States for not longer than 1 year as a participant in a program
sponsored by the U.S. Government primarily to train, research, or
study is exempt from U.S. income tax on income received for personal
services for the training, research, or study in the amount of
$10,000.
These provisions do not apply to income from research carried on
mainly for the private benefit of any person rather than in the public
interest.
Finland
A full-time student, trainee, or business apprentice who is a
resident of Finland immediately before visiting the United States is
exempt from U.S. income tax on amounts received from sources outside
the United States for maintenance, education, or training.
France
An individual who is a resident of France on the date of arrival in
the United States and who is temporarily in the United States
primarily to study at a university or other recognized educational
institution in the United States, obtain professional training, or
study, or do research as a recipient of a grant, allowance, or award
from a not-for-profit governmental, religious, charitable, scientific,
artistic, cultural, or educational organization is exempt from U.S.
income tax on the following amounts.
- Gifts from abroad for maintenance, education, study,
research, or training.
- The grant, allowance, or award.
- Income from personal services performed in the United States
of up to $5,000 each tax year.
An individual is entitled to this benefit and the benefit described
earlier under Professors, Teachers, and Researchers for a
maximum of 5 tax years.
This exemption does not apply to income from research carried on
mainly for the private benefit of any person rather than in the public
interest.
An individual who is a resident of France on the date of arrival in
the United States and who is in the United States as an employee of,
or under contract with, a resident of France is exempt from U.S.
income tax for a period of 12 consecutive months on up to $8,000
received for personal services if the individual is in the United
States primarily to:
- Acquire technical, professional, or business experience from
a person other than that resident of France, or
- Study at an educational institution.
Germany
A student or business apprentice (including Volontaere and
Praktikanten) who is or was immediately before visiting the United
States a resident of Germany and who is present in the United States
for full-time education or training is exempt from U.S. income tax on
amounts from sources outside the United States for maintenance,
education, or training.
An individual who is or was immediately before visiting the United
States a resident of Germany is exempt from U.S. tax on amounts
received as a grant, allowance, or award from a nonprofit religious,
charitable, scientific, literary, or educational organization.
Individuals described in the previous two paragraphs are also
exempt from U.S. tax on compensation for dependent personal services
of up to $5,000 per year if:
- They are present in the United States for not more than 4
years, and
- The services are performed for the purpose of supplementing
funds available otherwise for maintenance, education, or
training.
If the individual's visit exceeds 4 years, the exemption is lost
for the entire visit unless the competent authorities of Germany and
the United States agree otherwise.
An individual who is a resident of Germany and who is employed by a
German enterprise or by a nonprofit religious, charitable, scientific,
literary, or educational organization is exempt from U.S. tax on
compensation paid by the employer from outside the United States if:
- The individual is temporarily in the United States for not
more than one year to acquire technical, professional, or business
experience from any person other than his or her employer, and
- The compensation is not more than $10,000.
If the compensation is more than $10,000, none of the income is
exempt.
Greece
A student or business apprentice who is a resident of Greece and is
temporarily in the United States only to study or acquire business
experience is exempt from U.S. income tax on amounts received from
sources outside the United States for maintenance or studies.
Hungary
An individual who is a resident of Hungary immediately before
arrival in the United States and is here for full-time education or
training is exempt from U.S. income tax on payments received from
outside the United States for the individual's maintenance, education,
or training.
The full-time student or trainee may instead choose to be treated
as a resident alien of the United States for U.S. income tax purposes.
Once made, the choice applies for the entire period that the
individual remains qualified for exemption as a full-time student or
trainee and may not be changed unless permission is obtained from the
U.S. competent authority.
Iceland
An individual who is a resident of Iceland on the date of arrival
in the United States and who is temporarily in the United States
primarily to study at a university or other recognized educational
institution in the United States, obtain professional training, or
study or do research as a recipient of a grant, allowance, or award
from a governmental, religious, charitable, scientific, literary, or
educational organization is exempt from U.S. income tax on the
following amounts.
- Gifts from abroad for maintenance, education, study,
research, or training.
- The grant, allowance, or award.
- Income from personal services performed in the United States
of up to $2,000 each tax year.
An individual is entitled to the benefit of this exemption for a
maximum of 5 years.
An individual who is a resident of Iceland on the date of arrival
in the United States and who is temporarily in the United States as an
employee of, or under contract with, a resident of Iceland is exempt
from U.S. income tax for a period of 12 consecutive months on up to
$5,000 received for personal services if the individual is in the
United States primarily to:
- Acquire technical, professional, or business experience from
a person other than that resident of Iceland or other than a person
related to that person, or
- Study at an educational institution.
An individual who is a resident of Iceland on the date of arrival
in the United States and who is temporarily present in the United
States for not longer than one year as a participant in a program
sponsored by the U.S. Government primarily to train, research, or
study is exempt from U.S. income tax on income received for personal
services for the training, research, or study for a maximum of
$10,000.
India
An individual who is a resident of India immediately before
visiting the United States and who is temporarily in the United States
primarily for studying or training is exempt from U.S. income tax on
payments from abroad for maintenance, study, or training. The
exemption does not apply to payments borne by a permanent
establishment in the United States or paid by a U.S. citizen or
resident, the U.S. Government, or any of its agencies,
instrumentalities, political subdivisions, or local authorities.
Under the treaty, if the payments are not exempt under the rule
described above, an individual described in the previous paragraph may
be eligible to deduct exemptions for his or her spouse and dependents
and the standard deduction. The individual must file Form
1040NR or Form 1040NR-EZ to claim these amounts. For information
on how to claim these amounts, see chapter 5 in Publication 519.
The individual is entitled to these benefits only for a period of
time considered reasonable or customarily required to complete
studying or training.
Indonesia
An individual who is a resident of Indonesia immediately before
visiting the United States and who is temporarily in the United States
is exempt from U.S. income tax on certain amounts for a period of up
to 5 years. To be entitled to the exemption, the individual must be
temporarily in the United States for full-time study at a U.S.
university, school, or other recognized educational institution, or
for full-time study, research, or training as a recipient of a grant,
allowance, or award from either the U.S. or Indonesian Government, a
scientific, educational, religious, or charitable organization, or
under a technical assistance program entered into by either the U.S.
or Indonesian Government. If the individual meets any of these
requirements, the following amounts are exempt from tax.
- All payments from abroad for maintenance, education, study,
research, or training.
- The grant, allowance, or award.
- Income from personal services performed in the United States
of up to $2,000 each tax year.
An individual who is a resident of Indonesia immediately before
visiting the United States and is temporarily in the United States
only as a business or technical apprentice is exempt from U.S. income
tax for a period of 12 consecutive months on up to $7,500 received for
personal services.
Ireland
A student, apprentice, or business trainee who is a resident of
Ireland immediately before visiting the United States and is in the
United States for the purpose of full-time education at a recognized
educational institution or full-time training is exempt from U.S.
income tax on amounts received from sources outside the United States
for the individual's maintenance, education, or training.
Apprentices and business trainees are entitled to the benefit of
this exemption for a maximum period of 1 year.
Israel
An individual who is a resident of Israel on the date of arrival in
the United States and who is temporarily in the United States
primarily to study at a university or other recognized educational
institution in the United States, obtain professional training, or
study or do research as a recipient of a grant, allowance, or award
from a governmental, religious, charitable, scientific, literary, or
educational organization is exempt from U.S. income tax on the
following amounts.
- Gifts from abroad for maintenance, education, study,
research, or training.
- The grant, allowance, or award.
- Income from personal services performed in the United States
of up to $3,000 each tax year.
An individual is entitled to the benefit of this exemption for a
maximum of 5 tax years.
An individual who is a resident of Israel on the date of arrival in
the United States and who is temporarily in the United States as an
employee of, or under contract with, a resident of Israel is exempt
from U.S. income tax for a period of 12 consecutive months on up to
$7,500 received for personal services if the individual is in the
United States primarily to:
- Acquire technical, professional, or business experience from
a person other than that resident of Israel or other than a person
related to that resident, or
- Study at a university or other educational
institution.
An individual who is a resident of Israel on the date of arrival in
the United States and who is temporarily in the United States for no
more than one year as a participant in a program sponsored by the U.S.
Government primarily to train, research, or study is exempt from U.S.
income tax on income received for personal services for the training,
research, or study for a maximum of $10,000.
Italy
A student or business apprentice (trainee) who is a resident of
Italy on the date of arrival in the United States and who is
temporarily in the United States only for education or training is
exempt from U.S. income tax on amounts received from outside the
United States for maintenance, education, and training.
Jamaica
A student who is a resident of Jamaica on the date of arrival in
the United States and is here for full-time education or training is
exempt from U.S. income tax on payments received from outside the
United States for the student's maintenance, education, or training.
An individual who is a resident of Jamaica on the date of arrival
in the United States and who is temporarily in the United States as an
employee of, or under contract with, a resident of Jamaica is exempt
from U.S. income tax for a period of 12 consecutive months on up to
$7,500 of net income from personal services if the individual is in
the United States primarily to:
- Acquire technical, professional, or business experience from
a person other than that resident of Jamaica or other than a person
related to that resident, or
- Study at a university or other recognized educational
institution.
An individual who qualifies for one of the exemptions discussed
above may instead choose to be treated as a resident alien of the
United States for all U.S. income tax purposes. Once made, the choice
applies for the entire period that the individual remains qualified
for exemption and may not be revoked unless permission is obtained
from the U.S. competent authority.
Japan
An individual who is a resident of Japan on the date of arrival in
the United States and who is temporarily in the United States
primarily to study at a university or other accredited educational
institution in the United States, obtain professional training, or
study or do research as a recipient of a grant, allowance, or award
from a governmental, religious, charitable, scientific, literary, or
educational organization is exempt from U.S. income tax on the
following amounts.
- Gifts from abroad for maintenance, education, study,
research, or training.
- The grant, allowance, or award.
- Income from personal services performed in the United States
of up to $2,000 each tax year.
An individual is entitled to the benefit of this exemption for a
maximum of 5 years.
An individual who is a resident of Japan on the date of arrival in
the United States and who is in the United States as an employee of,
or under contract with, a resident of Japan is exempt from U.S. income
tax for a period of 12 consecutive months on up to $5,000 received for
personal services if the individual is in the United States primarily
to:
- Acquire technical, professional, or business experience from
a person other than that resident of Japan, or
- Study at an educational institution.
An individual who is a resident of Japan on the date of arrival in
the United States and who is temporarily present in the United States
for not longer than one year as a participant in a program sponsored
by the U.S. Government primarily to train, research, or study is
exempt from U.S. income tax on income received for personal services
for the training, research, or study in the amount of $10,000.
Kazakstan
An individual who is a resident of Kazakstan at the beginning of
his or her visit to the United States is exempt from U.S. tax on
payments from abroad for maintenance, education, study, research, or
training and on any grant, allowance, or other similar payments. To be
entitled to the exemption, the individual must be temporarily present
in the United States primarily to:
- Study at a university or other accredited educational
institution,
- Obtain training required to qualify him or her to practice a
profession or professional specialty, or,
- Study or do research as a recipient of a grant, allowance,
or other similar payments from a governmental, religious, charitable,
scientific, literary, or educational organization.
The individual is entitled to this exemption only for a period of
time necessary to complete the study, training, or research, but the
exemption for training or research may not extend for a period
exceeding 5 years.
These exemptions do not apply to income from research if it is
undertaken primarily for the private benefit of a specific person or
persons.
Korea, Republic of
An individual who is a resident of the Republic of Korea on the
date of arrival in the United States and who is temporarily in the
United States primarily to study at a university or other recognized
educational institution in the United States, obtain professional
training, or study or do research as a recipient of a grant,
allowance, or award from a governmental, religious, charitable,
scientific, literary, or educational organization is exempt from U.S.
income tax on the following amounts.
- Amounts from abroad for maintenance, education, study,
research, or training.
- The grant, allowance, or award.
- Income from personal services performed in the United States
of up to $2,000 each tax year.
An individual is entitled to the benefit of this exemption for a
maximum of 5 years.
An individual who is a resident of Korea on the date of arrival in
the United States and who is temporarily in the United States as an
employee of, or under contract with, a resident of Korea is exempt
from U.S. income tax for one year on up to $5,000 received for
personal services if the individual is in the United States primarily
to:
- Acquire technical, professional, or business experience from
a person other than that resident of Korea or other than a person
related to that resident, or
- Study at an educational institution.
An individual who is a resident of Korea on the date of arrival in
the United States and who is temporarily present in the United States
for not longer than one year as a participant in a program sponsored
by the U.S. Government primarily to train, research, or study is
exempt from U.S. income tax on income received for personal services
for the training, research, or study for a maximum of $10,000.
Latvia
An individual who is a resident of Latvia on the date of arrival in
the United States and who is temporarily in the United States
primarily to study at a university or other accredited educational
institution in the United States, obtain professional training, or
study or do research as a recipient of a grant, allowance, or award
from a governmental, religious, charitable, scientific, literary, or
educational organization is exempt from U.S. income tax on the
following amounts.
- Payments from abroad, other than compensation for personal
services, for maintenance, education, study, research, or
training.
- The grant, allowance, or award.
- Income from personal services performed in the United States
of up to $5,000 for each tax year.
An individual is entitled to the benefit of this exemption for a
maximum of 5 years.
An individual who is a resident of Latvia on the date of arrival in
the United States and who is in the United States as an employee of,
or under contract with, a resident of Latvia is exempt from U.S.
income tax for a period of 12 consecutive months on up to $8,000
received for personal services if the individual is in the United
States primarily to:
- Acquire technical, professional, or business experience from
a person other than that resident of Latvia, or
- Study at an educational institution.
An individual who is a resident of Latvia on the date of arrival in
the United States and who is temporarily present in the United States
for not longer than one year as a participant in a program sponsored
by the U.S. Government primarily to train, research, or study is
exempt from U.S. income tax on income received for personal services
for the training, research, or study in the amount of $10,000.
These provisions do not apply to income from research carried on
mainly for the private benefit of any person rather than in the public
interest.
Lithuania
An individual who is a resident of Lithuania on the date of arrival
in the United States and who is temporarily in the United States
primarily to study at a university or other accredited educational
institution in the United States, obtain professional training, or
study or do research as a recipient of a grant, allowance, or award
from a governmental, religious, charitable, scientific, literary, or
educational organization is exempt from U.S. income tax on the
following amounts.
- Payments from abroad, other than compensation for personal
services, for maintenance, education, study, research, or
training.
- The grant, allowance, or award.
- Income from personal services performed in the United States
of up to $5,000 for each tax year.
An individual is entitled to the benefit of this exemption for a
maximum of 5 years.
An individual who is a resident of Lithuania on the date of arrival
in the United States and who is in the United States as an employee
of, or under contract with, a resident of Lithuania is exempt from
U.S. income tax for a period of 12 consecutive months on up to $8,000
received for personal services if the individual is in the United
States primarily to:
- Acquire technical, professional, or business experience from
a person other than that resident of Lithuania, or
- Study at an educational institution.
An individual who is a resident of Lithuania on the date of arrival
in the United States and who is temporarily present in the United
States for not longer than one year as a participant in a program
sponsored by the U.S. Government primarily to train, research, or
study is exempt from U.S. income tax on income received for personal
services for the training, research, or study in the amount of
$10,000.
These provisions do not apply to income from research carried on
mainly for the private benefit of any person rather than in the public
interest.
Luxembourg
Note:
See the effective dates of the new treaty under Important
Changes at the beginning of this publication.
New treaty.
A student, apprentice, or business trainee who is a resident of
Luxembourg immediately before visiting the United States and is in the
United States for the purpose of full-time education at a recognized
educational institution or full-time training is exempt from U.S.
income tax on amounts received for the individual's maintenance,
education, or training.
Apprentices and business trainees are entitled to the benefit of
this exemption for a maximum period of 2 years.
If the individual's visit to the United States is longer than 2
years, the exemption is lost for the entire visit unless the competent
authorities of Luxembourg and the United States agree otherwise.
Former treaty.
Certain residents of Luxembourg are exempt from U.S. income tax on
income received from abroad for employment or amounts received from
abroad for their maintenance, education, or training if they are
temporarily in the United States. To qualify for this exemption they
must be temporarily in the United States only as:
- Students at a university, college, school, or other
recognized educational institution, or
- Business apprentices for not more than one year, or
- Recipients of a grant, allowance, or award from a religious,
charitable, scientific, literary, or educational organization
primarily to study or research.
Certain other residents of Luxembourg who are temporarily in the
United States for no more than one year are exempt from U.S. income
tax for that period on pay, including pay from an employer abroad, of
not more than $5,000. To qualify for this exemption they must be
employees of, or under contract with, a Luxembourg enterprise or a
Luxem- bourg religious, charitable, scientific, literary, or
educational organization and be in the United States only to acquire
technical, professional, or business experience from a person other
than that enterprise or organization.
Residents of Luxembourg are also exempt from U.S. income tax on
certain income if they are in the United States for no more than one
year only for training, research, or study under an arrangement with
the U.S. Government. The income that is exempt in this case is that
received for services directly related to this training, research, or
study and includes pay from their employer abroad. The amount exempt
may not be more than $10,000.
Mexico
A student or business apprentice who is a resident of Mexico
immediately before visiting the United States and is in the United
States solely for the purpose of education or training is exempt from
U.S. tax on amounts received from sources outside the United States
for the individual's maintenance, education, or training.
Morocco
An individual who is a resident of Morocco on the date of arrival
in the United States and who is temporarily in the United States
primarily to study at a university or other recognized educational
institution in the United States, obtain professional training, or
study or do research as a recipient of a grant, allowance, or award
from a governmental, religious, charitable, scientific, literary, or
educational organization is exempt from U.S. income tax on the
following amounts.
- Gifts from abroad for maintenance, education, study,
research, or training.
- The grant, allowance, or award.
- Income from personal services performed in the United States
of up to $2,000 each tax year.
An individual is entitled to the benefit of this exemption for a
maximum of 5 years.
Netherlands
An individual who immediately before visiting the United States is
a resident of the Netherlands and who is present in the United States
primarily for full-time study at a recognized university, college, or
school or securing training as a business apprentice is exempt from
U.S. income tax on the following amounts.
- Payments from abroad for maintenance, education, or
training.
- Income from personal services performed in the United States
of up to $2,000 each tax year.
The individual is entitled to this exemption only for a period of
time considered reasonable or customarily required to complete
studying or training.
An individual who immediately before visiting the United States is
a resident of the Netherlands and is temporarily present in the United
States for a period not exceeding 3 years for the purpose of study,
research, or training solely as a recipient of a grant, allowance, or
award from a scientific, educational, religious, or charitable
organization or under a technical assistance program entered into by
either the Netherlands or the United States, or its political
subdivisions or local authorities is exempt from U.S. income tax on
the following amounts.
- The amount of the grant, allowance, or award.
- Income of up to $2,000 for personal services performed in
the United States for any tax year if the services are connected with,
or incidental to, the study, research, or training.
An individual is not entitled to these exemptions if, during the
immediately preceding period, the individual claimed the exemption
discussed earlier under Professors, Teachers, and Researchers.
New Zealand
A resident of New Zealand or an individual who was a resident of
New Zealand immediately before visiting the United States who is in
the United States for full-time education is exempt from U.S. income
tax on amounts received from abroad for maintenance or education.
Norway
An individual who is a resident of Norway on the date of arrival in
the United States and who is temporarily in the United States
primarily to study at a university or other recognized educational
institution in the United States, obtain professional training, or
study or do research as a recipient of a grant, allowance, or award
from a governmental, religious, charitable, scientific, literary, or
educational organization is exempt from U.S. income tax on the
following amounts.
- Gifts from abroad for maintenance, education, study,
research, or training.
- The grant, allowance, or award.
- Income from personal services performed in the United States
up to $2,000 each tax year.
An individual is entitled to the benefit of this exemption for a
maximum of 5 tax years.
An individual who is a resident of Norway on the date of arrival in
the United States and who is in the United States as an employee of,
or under contract with, a resident of Norway is exempt from U.S.
income tax for a period of 12 consecutive months on up to $5,000
received for personal services if the individual is in the United
States primarily to:
- Acquire technical, professional, or business experience from
a person other than that resident of Norway or other than a person
related to that resident of Norway, or
- Study at an educational institution.
Also exempt is a resident of Norway who is present in the United
States for not longer than 1 year as a participant in a program
sponsored by the Government of the United States primarily to train,
research, or study. The individual is exempt from tax on income from
personal services performed in the United States and received for the
training, research, or study, for a maximum of $10,000.
Pakistan
Residents of Pakistan temporarily in the United States are exempt
from U.S. income tax on certain income they may receive. To be
entitled to this exemption, they must be in the United States only as
students at a recognized university, college, or school, or as
recipients of grants, allowances, or awards from religious,
charitable, scientific, or educational organizations of Pakistan
primarily to study or research. The income exempt in these cases is
any payment from abroad for maintenance, education, or training, and
any pay for personal services of not more than $5,000 for any tax
year.
Other residents of Pakistan who are temporarily in the United
States for no more than one year are exempt from U.S. income tax on
pay of not more than $6,000 received for that period, including pay
from the enterprise or organization of which they are employees or
with which they are under contract. To qualify for this exemption,
they must be employees of, or under contract with, a Pakistani
enterprise or religious, charitable, scientific, or educational
organization and be in the United States only to acquire technical,
professional, or business experience from a person other than that
enterprise or organization.
Also exempt from U.S. income tax on certain income are residents of
Pakistan temporarily in the United States under an arrangement with
the U.S. Government, or any of its agencies or instrumentalities, only
for study, training, or orientation. They are exempt from tax on
income of not more than $10,000 for services directly related to their
training, study, or orientation, including income from their employer
abroad.
Philippines
An individual who is a resident of the Philippines on the date of
arrival in the United States and who is temporarily in the United
States primarily to study at a university or other recognized
educational institution in the United States, obtain professional
training, or study or do research as a recipient of a grant,
allowance, or award from a governmental, religious, charitable,
scientific, literary, or educational organization is exempt from U.S.
income tax on the following amounts.
- Gifts from abroad for maintenance, education, study,
research, or training.
- The grant, allowance, or award.
- Income from personal services performed in the United States
of up to $3,000 each tax year.
An individual is entitled to the benefit of this exemption for a
maximum of 5 years.
An individual who is a resident of the Philippines on the date of
arrival in the United States and who is temporarily in the United
States as an employee of, or under contract with, a resident of the
Philippines is exempt from U.S. income tax for a period of 12
consecutive months on up to $7,500 received for personal services if
the individual is in the United States primarily to:
- Acquire technical, professional, or business experience from
a person other than that resident of the Philippines or other than a
person related to that resident, or
- Study at an educational institution.
An individual who is a resident of the Philippines on the date of
arrival in the United States, and who is temporarily in the United
States (for no more than one year as a participant in a program
sponsored by the U.S. Government) primarily to train, research, or
study, is exempt from U.S. income tax on income received for personal
services for the training, research, or study, up to a maximum of
$10,000.
Poland
An individual who is a resident of Poland on the date of arrival in
the United States and who is temporarily in the United States
primarily to study at a university or other recognized educational
institution in the United States, obtain professional training, or
study or do research as a recipient of a grant, allowance, or award
from a governmental, religious, charitable, scientific, literary, or
educational organization is exempt from U.S. income tax on the
following amounts.
- Gifts from abroad for maintenance, education, study,
research, or training.
- The grant, allowance, or award.
- Any other payments received from Poland, except income from
performing personal services.
- Income from personal services performed in the United States
of up to $2,000 each tax year.
An individual is entitled to the benefit of this exemption for a
maximum of 5 years.
An individual who is a resident of Poland on the date of arrival in
the United States and who is temporarily in the United States as an
employee of, or under contract with, a resident of Poland is exempt
from U.S. income tax for one year on up to $5,000 received for
personal services if the individual is in the United States primarily
to:
- Acquire technical, professional, or business experience from
a person other than that resident of Poland or other than a person
related to that resident, or
- Study at an educational institution.
An individual who is a resident of Poland on the date of arrival in
the United States and who is temporarily in the United States for not
longer than one year as a participant in a program sponsored by the
U.S. Government primarily to train, research, or study is exempt from
U.S. income tax on up to $10,000 of income received for personal
services for the training, research, or study.
Portugal
An individual who is a resident of Portugal on the date of arrival
in the United States and who is temporarily in the United States
primarily to study at a university or other accredited educational
institution in the United States, obtain professional training, or
study, or do research as a recipient of a grant, allowance, or award
from a governmental, religious, charitable, scientific, literary, or
educational organization is exempt from U.S. income tax on the
following amounts.
- Payments from abroad for maintenance, education, study,
research, or training.
- The grant, allowance, or award.
- Income from personal services performed in the United States
of up to $5,000 each tax year.
An individual is entitled to the benefit of this exemption for a
maximum of 5 tax years from the date of arrival in the United States.
The benefits provided here and the benefits described earlier under
Professors, Teachers, and Researchers cannot be claimed
simultaneously or consecutively.
An individual who is a resident of Portugal on the date of arrival
in the United States and who is in the United States as an employee
of, or under contract with, a resident of Portugal is exempt from U.S.
income tax for a period of 12 consecutive months on up to $8,000
received for personal services if the individual is in the United
States primarily to:
- Acquire technical, professional, or business experience from
a person other than that resident of Portugal, or
- Study at an educational institution.
Romania
An individual who is a resident of Romania on the date of arrival
in the United States and who is temporarily in the United States
primarily to study at a university or other recognized educational
institution in the United States, obtain professional training, or
study or do research as a recipient of a grant, allowance, or award
from a governmental, religious, charitable, scientific, literary, or
educational organization is exempt from U.S. income tax on the
following amounts.
- Gifts from abroad for maintenance, education, study,
research, or training.
- The grant, allowance, or award.
- Income from personal services performed in the United States
of up to $2,000 each tax year.
An individual is entitled to the benefit of this exemption for a
maximum of 5 years.
An individual who is a resident of Romania on the date of arrival
in the United States and who is temporarily in the United States as an
employee of, or under contract with, a resident of Romania is exempt
from U.S. income tax for 1 year on up to $5,000 received for personal
services if the individual is in the United States primarily to:
- Acquire technical, professional, or business experience from
a person other than that resident of Romania or other than a person
related to that resident, or
- Study at an educational institution.
An individual who is a resident of Romania on the date of arrival
in the United States and who is temporarily in the United States for
not longer than 1 year as a participant in a program sponsored by the
U.S. Government primarily to train, research, or study is exempt from
U.S. income tax on up to $10,000 of income received for personal
services for the training, research, or study.
Russia
An individual who is a resident of Russia at the beginning of his
or her visit to the United States is exempt from U.S. tax on payments
from abroad for maintenance, education, study, research, or training
and on any grant, allowance, or other similar payments. To be entitled
to the exemption, the individual must be temporarily present in the
United States primarily to:
- Study at a university or other accredited educational
institution,
- Obtain training required to qualify him or her to practice a
profession or professional specialty, or,
- Study or do research as a recipient of a grant, allowance,
or other similar payments from a governmental, religious, charitable,
scientific, literary, or educational organization.
The individual is entitled to this exemption only for a period of
time necessary to complete the study, training, or research, but the
exemption for training or research may not extend for a period
exceeding 5 years.
These exemptions do not apply to income from research if it is
undertaken primarily for the private benefit of a specific person or
persons.
Slovak Republic
An individual who is a resident of the Slovak Republic at the
beginning of his or her visit to the United States and who is
temporarily present in the United States is exempt from U.S. income
tax on certain amounts for a period of up to 5 years. To be entitled
to the exemption, the individual must be in the United States for the
primary purpose of:
- Studying at a university or other accredited educational
institution in the United States,
- Obtaining training required to qualify him or her to
practice a profession or professional specialty, or
- Studying or doing research as a recipient of a grant,
allowance, or award from a governmental, religious, charitable,
scientific, literary, or educational organization.
If the individual meets any of these requirements, the
following amounts are exempt from U.S. tax.
- The payments from abroad, other than compensation for
personal services, for the purpose of maintenance, education, study,
research, or training.
- The grant, allowance, or award.
- The income from personal services performed in the United
States of up to $5,000 for the tax year.
An individual who is a Slovak resident at the beginning of the
visit to the United States and who is temporarily present in the
United States as an employee of, or under contract with, a Slovak
resident is exempt from U.S. income tax for a period of 12 consecutive
months on up to $8,000 received from personal services if the
individual is in the United States primarily to:
- Acquire technical, professional, or business experience from
a person other than the Slovak resident, or
- Study at a university or other accredited educational
institution in the United States.
An individual who is a Slovak resident at the time he or she
becomes temporarily present in the United States and who is
temporarily present in the United States for a period not longer than
1 year as a participant in a program sponsored by the U.S. government
for the primary purpose of training, research, or study, is exempt
from U.S. income tax on up to $10,000 of income from personal services
for that training, research, or study.
These exemptions do not apply to income from research undertaken
primarily for the private benefit of a specific person or persons.
South Africa
A student, apprentice, or business trainee who is a resident of
South Africa immediately before visiting the United States and is in
the United States for the purpose of full-time education or training
is exempt from U.S. income tax on amounts received from sources
outside the United States for the individual's maintenance, education,
or training.
Apprentices and business trainees are entitled to the benefit of
this exemption for a maximum period of one year.
Spain
An individual who is a resident of Spain at the beginning of the
visit to the United States and who is temporarily in the United States
primarily to study at a U.S. university or other accredited
educational institution, to obtain training to become qualified to
practice a profession or professional specialty, or to study or do
research as a recipient of a grant, allowance, or award from a
governmental, religious, charitable, scientific, literary, or
educational organization is exempt from U.S. income tax on the
following amounts.
- Payments from abroad (other than compensation for personal
services) for maintenance, education, study, research, or
training.
- The grant, allowance, or award.
- Income from personal services performed in the United States
of up to $5,000 for each tax year.
An individual is entitled to the benefit of this exemption for
a maximum of 5 years.
An individual who is a resident of Spain at the beginning of the
visit to the United States and is temporarily in the United States as
an employee of, or under contract with, a resident of Spain is exempt
from U.S. income tax for a period of 12 consecutive months on up to
$8,000 received for personal services if the individual is in the
United States primarily to:
- Acquire technical, professional, or business experience from
a person other than that Spanish resident, or
- Study at a university or other accredited educational
institution in the United States.
Both the $5,000 and $8,000 exemptions include any amount excluded
or exempted from tax under U.S. tax law.
These exemptions do not apply to income from research carried on
mainly for the private benefit of any person rather than in the public
interest.
Sweden
A student, apprentice, or business trainee who is a resident of
Sweden immediately before visiting the United States and is in the
United States for the purpose of full-time education or training is
exempt from U.S. tax on amounts received from sources outside the
United States for the individual's maintenance, education, and
training.
Switzerland
A student, apprentice, or business trainee who is a resident of
Switzerland immediately before visiting the United States and is in
the United States for the purpose of full-time education or training
is exempt from U.S. income tax on amounts received from sources
outside the United States for the individual's maintenance, education,
or training.
Thailand
An individual who is a resident of Thailand at the beginning of his
or her visit to the United States and who is temporarily present in
the United States is exempt from U.S. income tax on certain amounts
for a period of up to 5 years. To be entitled to the exemption, the
individual must be in the United States for the primary purpose of:
- Studying at a university or other recognized educational
institution in the United States,
- Obtaining training required to qualify him or her to
practice a profession or professional specialty, or
- Studying or doing research as a recipient of a grant,
allowance, or award from a governmental, religious, charitable,
scientific, literary, or educational organization.
If the individual meets any of these requirements, the
following amounts are exempt from U.S. tax.
- Gifts from abroad for the purpose of maintenance, education,
study, research, or training.
- The grant, allowance, or award.
- Income from personal services performed in the United States
of up to $3,000 for the tax year.
An individual who is a resident of Thailand at the beginning of the
visit to the United States and who is temporarily present in the
United States as an employee of, or under contract with, a resident of
Thailand is exempt from U.S. income tax for a period of 12 consecutive
months on up to $7,500 received from personal services if the
individual is in the United States primarily to:
- Acquire technical, professional, or business experience from
a person other than the Thai resident, or
- Study at a university or other recognized educational
institution in the United States.
An individual who is a resident of Thailand at the time he or she
becomes temporarily present in the United States and who is
temporarily present in the United States for a period not longer than
1 year as a participant in a program sponsored by the U.S. government
for the primary purpose of training, research, or study, is exempt
from U.S. income tax on up to $10,000 of income from personal services
for that training, research, or study.
Trinidad and Tobago
An individual who is a resident of Trinidad and Tobago on the date
of arrival in the United States and who is temporarily in the United
States primarily to study at a university or other accredited
educational institution in the United States, obtain professional
training, or study or do research as a recipient of a grant,
allowance, or award from a governmental, religious, charitable,
scientific, literary, or educational organization is exempt from U.S.
income tax on the following amounts.
- Gifts from abroad for maintenance, education, study,
research, or training.
- The grant, allowance, or award.
- Income from personal services performed in the United States
of up to $2,000 each tax year, or, if the individual is obtaining
training required to qualify to practice a profession or a
professional specialty, a maximum of $5,000 for any tax year.
An individual is entitled to the benefit of this exemption for a
maximum period of 5 tax years.
An individual who is a resident of Trinidad and Tobago on the date
of arrival in the United States and who is in the United States as an
employee of, or under contract with, a resident or corporation of
Trinidad and Tobago is exempt from U.S. income tax for 1 tax year on
up to $5,000 received for personal services if the individual is in
the United States primarily to:
- Study at an educational institution, or
- Acquire technical, professional, or business experience from
a person other than that resident or corporation of Trinidad and
Tobago.
Also exempt is a resident of Trinidad and Tobago who is present in
the United States for not longer than one year as a participant in a
program sponsored by the U.S. Government primarily to train, research,
or study. The individual is exempt from tax on income from personal
services performed in the United States and received for the training,
research, or study for up to a maximum of $10,000.
Tunisia
An individual who is a resident of Tunisia immediately before
visiting the United States and who is in the United States for
full-time study or training is exempt from U.S. income tax on the
following amounts.
- Payments from abroad for full-time study or training.
- A grant, allowance, or award from a governmental, religious,
charitable, scientific, literary, or educational organization to study
or engage in research.
- Income from personal services performed in the United States
of up to $4,000 in any tax year.
The individual is entitled to this exemption for a maximum of 5
years.
Turkey
A student, apprentice, or business trainee who is a resident of
Turkey immediately before visiting the United States and is in the
United States for the purpose of full-time education or training is
exempt from U.S. income tax on amounts received from sources outside
the United States for the individual's maintenance, education, or
training.
Ukraine
Note:
See the effective dates of the new treaty under Important
Changes at the beginning of this publication. For information on
the old provisions, see Commonwealth of Independent States.
An individual who is a resident of Ukraine at the beginning of his
or her visit to the United States is exempt from U.S. tax on payments
from abroad for maintenance, education, study, research, or training
and on any grant, allowance, or other similar payments. To be entitled
to the exemption, the individual must be temporarily present in the
United States primarily to:
- Study at a university or other accredited educational
institution,
- Obtain training required to qualify him or her to practice a
profession or professional specialty, or,
- Study or do research as a recipient of a grant, allowance,
or other similar payments from a governmental, religious, charitable,
scientific, literary, or educational organization.
The individual is entitled to this exemption only for a period of
time necessary to complete the study, training, or research, but the
exemption for training or research may not extend for a period
exceeding 5 years.
These exemptions do not apply to income from research if it is
undertaken primarily for the private benefit of a specific person or
persons.
United Kingdom
A student or business apprentice who is a resident of the United
Kingdom at the time of arrival in the United States and who is
receiving full-time education or training in the United States is
exempt from U.S. income tax on payments received from abroad for
maintenance, education, or training.
Venezuela
An individual who is a resident of Venezuela on the date of arrival
in the United States and who is temporarily in the United States
primarily to study at a university or other recognized educational
institution in the United States, obtain professional training, or
study or do research as a recipient of a grant, allowance, or award
from a governmental, religious, charitable, scientific, literary, or
educational organization is exempt from U.S. income tax on the
following amounts.
- Payments from abroad, other than compensation for personal
services, for maintenance, education, study, research, or
training.
- The grant, allowance, or award.
- Income from personal services performed in the United States
of up to $5,000 for each tax year.
An individual is generally entitled to the benefit of this
exemption for a maximum of 5 years from the date of arrival in the
United States. This exemption will also apply to any additional period
of time that a full-time student needs to complete the educational
requirements as a candidate for a postgraduate or professional degree
from a recognized educational institution.
An individual who is a resident of Venezuela on the date of arrival
in the United States and who is in the United States as an employee
of, or under contract with, a resident of Venezuela is exempt from
U.S. income tax for a period of 12 months on up to $8,000 received for
personal services if the individual is in the United States primarily
to:
- Acquire technical, professional, or business experience from
a person other than that resident of Venezuela, or
- Study at an educational institution.
These provisions do not apply to income from research carried on
mainly for the private benefit of any person rather than in the public
interest.
Wages and Pensions
Paid by a Foreign
Government
Wages, salaries, pensions, and annuities paid by the governments of
the following countries to their residents who are present in the
United States as nonresident aliens generally are exempt from U.S.
income tax. The conditions under which the income is exempt are stated
for each of the countries listed.
Exemption under U.S. tax law.
Employees of foreign countries who do not qualify under a tax
treaty provision and employees of international organizations should
see if they can qualify for exemption under U.S. tax law.
If you work for a foreign government in the United States, your
foreign government salary is exempt from U.S. tax if you perform
services similar to those performed by U.S. government employees in
that foreign country and that foreign government grants an equivalent
exemption. If you work for an international organization in the United
States, your salary from that source is exempt from U.S. tax. See
chapter 10 of Publication 519
for more information.
Australia
Salaries, wages, and similar income, including pensions, paid by
Australia, its political subdivisions, agencies, or authorities to its
citizens (other than U.S. citizens) for performing governmental
functions as an employee of any of the above entities are exempt from
U.S. income tax.
Austria
Wages, salaries, similar income, and pensions and annuities paid
from public funds of Austria, its political subdivisions, or its local
authorities, to citizens of Austria for performing governmental
functions as an employee are exempt from U.S. tax.
However, this exemption does not apply to payments for services
performed in connection with a trade or business carried on by Austria
or its political subdivisions or local authorities.
Barbados
Income, including a pension, paid from the public funds of
Barbados, or its political subdivisions or local authorities, to a
citizen of Barbados for performing governmental functions is exempt
from U.S. income tax.
However, this exemption does not apply to payments for services in
connection with a business carried on by Barbados or its political
subdivisions or local authorities.
Belgium
Wages, salaries, similar income, and pensions and annuities paid
by, or from public funds of, Belgium, its political subdivisions, or
its local authorities, to citizens of Belgium (or to citizens of
countries other than the United States or Belgium who come to the
United States and are employed by Belgium or its political
subdivisions or local authorities) for performing governmental
functions are exempt from U.S. tax.
However, this exemption does not apply to payments for services
performed in connection with a trade or business carried on by Belgium
or its political subdivisions or local authorities.
Canada
Wages, salaries, and similar income (other than pensions) paid by
Canada or by a Canadian political subdivision or local authority to a
citizen of Canada for performing governmental functions are exempt
from U.S. income tax. This exemption does not apply, however, to
payments for services performed in connection with a trade or business
carried on by Canada or its political subdivisions or local
authorities.
Also see Publication 597,
Information on the United
States--Canada Income Tax Treaty.
China, People's Republic of
Income, other than a pension, paid by the People's Republic of
China or its political subdivisions or local authorities to an
individual for services performed for the paying governmental body is
exempt from U.S. income tax. However, the exemption does not apply to
payments for services performed in the United States by a resident of
the United States who either:
- Is a U.S. citizen, or
- Did not become a U.S. resident only to perform the
services.
Pensions paid by the People's Republic of China for services
performed for China are exempt from U.S. income tax unless the
recipient is both a citizen and a resident of the United States.
These exemptions do not apply to income or pensions for services
performed in connection with a business carried on by the People's
Republic of China or its subdivisions or local authorities.
Commonwealth of
Independent States
Wages, salaries, and similar income paid by the C.I.S. or a member
of the C.I.S. to its citizens for personal services performed as an
employee of a governmental agency or institution of the C.I.S. or a
member of the C.I.S. (excluding local government employees) in the
discharge of governmental functions are exempt from U.S. income tax.
For this purpose, persons engaged in commercial activities are not
considered engaged in the discharge of governmental functions.
Cyprus
Wages, salaries, and similar income, including pensions, annuities,
and similar benefits, paid from public funds of Cyprus to a citizen of
Cyprus for labor or personal services performed as an employee of
Cyprus in the discharge of governmental functions are exempt from U.S.
income tax.
Czech Republic
Income, including a pension, paid from the public funds of the
Czech Republic, its political subdivisions, or local authorities to a
Czech citizen for services performed in the discharge of governmental
functions is exempt from U.S. income tax. This exemption does not
apply to income paid for services performed in connection with a
business carried on by the Czech Republic, its political subdivisions,
or local authorities.
Denmark
Note:
See the effective dates of the new treaty under Important
Changes at the beginning of this publication.
New treaty.
Income, other than a pension, paid from public funds of Denmark,
its political subdivisions, or local authorities to an individual for
services performed for the paying governmental body in the discharge
of governmental functions is exempt from U.S. income tax. However, the
exemption does not apply if the services are performed in the United
States by a resident of the United States who either:
- Is a U.S. citizen, or
- Did not become a U.S. resident only to perform the
services.
Pensions paid from the public funds of Denmark, its political
subdivisions, or local authorities for services performed for Denmark
are exempt from U.S. income tax unless the recipient is either a
resident or citizen of the United States.
These exemptions do not apply to income or pensions for services
performed in connection with a trade or business carried on by
Denmark, its political subdivisions, or local authorities.
Former treaty.
Wages, salaries, and similar income and pensions paid by Denmark,
or any public authority in Denmark, to individuals living in the
United States are exempt from U.S. income tax. This exemption does not
apply to citizens of the United States or alien residents of the
United States.
Egypt
Wages, salaries, and similar income, including pensions, annuities,
and similar benefits, paid from public funds of the Arab Republic of
Egypt to a citizen of Egypt (or to a citizen of another country who
comes to the United States specifically to work for the Government of
Egypt) for labor or personal services performed as an employee of the
national Government of Egypt, or any of its agencies, in the discharge
of governmental functions are exempt from U.S. income tax.
This exemption does not apply to U.S. citizens or to alien
residents of the United States. The exemption also does not apply to
payments for services performed in connection with a trade or business
carried on by Egypt or any of its agencies.
Estonia
Income, other than a pension, paid by or from public funds of
Estonia, its political subdivisions, or local authorities to an
individual for services performed as an employee for the paying
governmental body in the discharge of governmental functions is exempt
from U.S. income tax. However, the exemption does not apply if the
services are performed in the United States by a resident of the
United States who either:
- Is a U.S. citizen, or
- Did not become a U.S. resident only to perform the
services.
Pensions paid by or from the public funds of Estonia, its political
subdivisions, or local authorities for services performed for Estonia
are exempt from U.S. income tax unless the recipient is both a
resident and citizen of the United States.
Finland
Income, other than a pension, paid by Finland, its political
subdivisions, statutory bodies, or local authorities to an individual
for services performed for the paying governmental body is exempt from
U.S. income tax. However, the exemption does not apply to payments for
services performed in the United States by a U.S. resident who either:
- Is a U.S. citizen, or
- Did not become a U.S. resident only to perform the
services.
Pensions paid by Finland for services performed for Finland are
exempt from U.S. income tax unless the recipient is a resident and
citizen of the United States.
These exemptions do not apply to income or pensions for services
performed in connection with a trade or business carried on by Finland
or its political subdivisions, statutory bodies, or local authorities.
France
Income, including pensions, paid by the French Government or a
local authority thereof to an individual in the United States for
services performed for France (or for a local authority of France) in
the discharge of governmental functions is exempt from U.S. tax. This
exemption does not apply to a person who is both a resident and
citizen of the United States and not a French national.
This exemption does not apply to any income or pensions paid
because of services (or past services) performed in connection with a
business carried on by the French Government (or a local authority
thereof).
Germany
Wages, salaries, and similar income and pensions paid by Germany,
its Laender, or municipalities, or their public pension funds are
exempt from U.S. income tax if paid to individuals other than U.S.
citizens and other than individuals admitted to the United States for
permanent residence.
Greece
Wages, salaries, and similar income and pensions paid by Greece or
its subdivisions to individuals living in the United States for
services rendered to Greece or its subdivisions are exempt from U.S.
income tax. This exemption does not apply to citizens of the United
States or alien residents of the United States.
Hungary
Income (other than a pension) paid by the Republic of Hungary or
its political subdivisions for labor or personal services performed
for the paying governmental body is exempt from U.S. tax. However, the
exemption does not apply to payments for services performed in the
United States by a resident of the United States who either:
- Is a U.S. citizen, or
- Did not become a resident of the United States only to
perform the services.
Pensions paid by Hungary for services performed for Hungary are
exempt from U.S. income tax unless the recipient is both a citizen and
a resident of the United States.
These exemptions do not apply to income or pensions for services
performed in connection with a trade or business carried on by Hungary
or its subdivisions.
Iceland
Wages, salaries, and similar income, including pensions and similar
benefits, paid by or from public funds of the Republic of Iceland, a
political subdivision, or a local authority to a citizen of Iceland
(other than a U.S. citizen or one admitted to the United States for
permanent residence) for labor or personal services performed for
Iceland or its political subdivisions or local authorities in the
discharge of governmental functions are exempt from U.S. tax.
India
Income, other than a pension, paid by India, its political
subdivisions, or local authorities to an individual for services
performed for the paying governmental body is exempt from U.S. income
tax. However, the exemption does not apply if the services are
performed in the United States by a U.S. resident who either:
- Is a U.S. citizen, or
- Did not become a U.S. resident only to perform the
services.
Pensions paid by India for services performed for India are exempt
from U.S. tax unless the individual is both a resident and citizen of
the United States.
These exemptions do not apply to income or pensions for services
performed in connection with a business carried on by India, its
subdivisions, or local authorities.
Indonesia
Income, other than a pension, paid by Indonesia, its political
subdivisions, or local authorities to an individual for services
performed for the paying governmental body is exempt from U.S. income
tax. However, the exemption does not apply if the services are
performed in the United States by a U.S. resident who either:
- Is a U.S. citizen, or
- Did not become a U.S. resident only to perform the
services.
Pensions paid by Indonesia for services performed for Indonesia are
exempt from U.S. tax.
These exemptions do not apply to income or pensions for services
performed in connection with a trade or business carried on by
Indonesia, its subdivisions, or local authorities.
Ireland
Income, other than a pension, paid by Ireland or its political
subdivisions or local authorities to an individual for services
performed for the paying governmental body is exempt from U.S. income
tax. However, the exemption does not apply to payments for services
performed in the United States by a resident of the United States who
either:
- Is a U.S. citizen, or
- Did not become a U.S. resident only to perform the
services.
Pensions paid by Ireland for services performed for Ireland are
exempt from U.S. income tax unless the recipient is both a resident
and citizen of the United States.
These exemptions do not apply to income or pensions for services
performed in connection with a business carried on by Ireland or its
subdivisions or local authorities.
Israel
Wages, salaries, and similar income, including pensions and similar
benefits, paid from public funds by the national government of Israel
or its agencies, for services performed in the discharge of
governmental functions, are exempt from U.S. income tax. This
exemption does not apply to citizens of the United States or alien
residents of the United States.
Italy
Income, other than a pension, paid by Italy or by an Italian
political or administrative subdivision or local authority to an
individual for services performed for the paying governmental body is
exempt from U.S. income tax. However, the exemption does not apply to
payments for services performed in the United States by a resident of
the United States who either:
- Is a U.S. citizen, or
- Did not become a U.S. resident only to perform the
services.
The spouse and dependent children of an individual, however,
are not subject to the second restriction if that individual is
receiving exempt income for governmental services performed for Italy
and that individual does not come under either of the restrictions.
Pensions paid by Italy for services performed for Italy are exempt
from U.S. income tax unless the recipient is both a citizen and a
resident of the United States.
These exemptions do not apply to income or pensions for services
performed in connection with a trade or business carried on by Italy
or its subdivisions or local authorities.
Jamaica
Income, other than a pension, paid by the Government of Jamaica or
its political subdivisions or local authorities for personal services
performed for the paying governmental body is exempt from U.S. income
tax.
This exemption does not apply to payments for services performed in
the United States by an individual who is a citizen and resident of
the United States.
Pensions paid by Jamaica for services performed for Jamaica
generally are exempt from U.S. income tax. However, if the recipient
of the pension is a citizen and resident of the United States and
was a U.S. citizen at the time the services were performed, the
pension is taxable in the United States.
These exemptions do not apply to income or pensions for services
performed in connection with a trade or business carried on by Jamaica
or its subdivisions or local authorities.
Japan
Salaries, wages, and similar income, including pensions and similar
benefits, paid by Japan or out of funds to which Japan or any of its
local authorities contributes to an individual who is a national of
Japan (other than a U.S. citizen or one admitted to the United States
for permanent residence) for labor or personal services performed as
an employee of the Government of Japan or any of its local authorities
are exempt from U.S. income tax.
Kazakstan
Income, other than a pension, paid by Kazakstan, or its
subdivisions or local authorities to an individual for government
services is exempt from U.S. tax. However, the exemption does not
apply if the services are performed in the United States by a U.S.
resident who either:
- Is a U.S. citizen, or
- Did not become a U.S. resident solely for the purpose of
performing the services.
These exemptions do not apply to income for services performed
in connection with a business.
Pensions paid by Kazakstan, or its subdivisions or local
authorities for services performed for Kazakstan is exempt from U.S.
tax unless the individual is both a resident and citizen of the United
States.
Korea, Republic of
Wages, salaries, and similar income, including pensions and similar
benefits, paid from public funds of the Republic of Korea to a citizen
of Korea (other than a U.S. citizen or an individual admitted to the
United States for permanent residence) for services performed as an
employee of Korea discharging government functions are exempt from
U.S. income tax.
Latvia
Income, other than a pension, paid by or from public funds of
Latvia, its political subdivisions, or local authorities to an
individual for services performed as an employee for the paying
governmental body in the discharge of governmental functions is exempt
from U.S. income tax. However, the exemption does not apply if the
services are performed in the United States by a resident of the
United States who either:
- Is a U.S. citizen, or
- Did not become a U.S. resident only to perform the
services.
Pensions paid by or from the public funds of Latvia, its political
subdivisions, or local authorities for services performed for Latvia
are exempt from U.S. income tax unless the recipient is both a
resident and citizen of the United States.
Lithuania
Income, other than a pension, paid by or from public funds of
Lithuania, its political subdivisions, or local authorities to an
individual for services performed as an employee for the paying
governmental body in the discharge of governmental functions is exempt
from U.S. income tax. However, the exemption does not apply if the
services are performed in the United States by a resident of the
United States who either:
- Is a U.S. citizen, or
- Did not become a U.S. resident only to perform the
services.
Pensions paid by or from the public funds of Lithuania, its
political subdivisions, or local authorities for services performed
for Lithuania are exempt from U.S. income tax unless the recipient is
both a resident and citizen of the United States.
Luxembourg
Note:
See the effective dates of the new treaty under Important
Changes at the beginning of this publication.
New treaty.
Income, other than a pension, paid by Luxembourg, its political
subdivisions, or local authorities to an individual for services
performed for the paying governmental body is exempt from U.S. income
tax. However, the exemption does not apply if the services are
performed in the United States by a resident of the United States who
either:
- Is a U.S. citizen, or
- Did not become a U.S. resident only to perform the
services.
Pensions paid by Luxembourg, its political subdivisions, or local
authorities for services performed for Luxembourg are exempt from U.S.
income tax unless the recipient is both a resident and citizen of the
United States.
These exemptions do not apply to income or pensions for services
performed in connection with a trade or business carried on by
Luxembourg, its political subdivisions, or local authorities.
Former treaty.
Wages, salaries, and similar income, and pensions, annuities, and
similar benefits paid by Luxembourg, its political subdivisions, or
its compulsory social security funds for services performed for
Luxembourg or its political subdivisions in discharge of governmental
functions are exempt from U.S. income tax. These amounts are exempt
only if they are paid to individuals other than U.S. citizens or
individuals admitted to the United States for permanent residence.
Mexico
Income, other than a pension, paid by Mexico, its political
subdivisions, or local authorities to an individual for services
performed for the paying governmental body is exempt from U.S. income
tax. However, the exemption does not apply if the services are
performed in the United States by a U.S. resident who either:
- Is a U.S. national, or
- Did not become a resident of the United States solely for
purposes of performing the services.
Pensions paid by Mexico, its political subdivisions, or local
authorities for services performed for the paying governmental body
are exempt from U.S. income tax unless the individual is both a
resident and national of the United States.
These exemptions do not apply to income or pensions connected with
commercial or industrial activities carried on by Mexico, its
political subdivisions, or local authorities.
Morocco
Wages, salaries, and similar income, including pensions and similar
benefits, paid from public funds of the Kingdom of Morocco to a
citizen of Morocco (other than a U.S. citizen or an individual
admitted to the United States for permanent residence) for labor or
personal services performed for Morocco or for any of its political
subdivisions or local authorities in the discharge of governmental
functions are exempt from U.S. income tax.
Netherlands
Income, other than a pension, paid by the Netherlands, its
political subdivisions, or local authorities to an individual for
services performed for the paying governmental body is exempt from
U.S. income tax. However, the exemption does not apply if the services
are rendered in the United States and the individual is a U.S.
resident who either:
- Is a U.S. national, or
- Did not become a U.S. resident solely for the purpose of
performing the services.
Pensions paid by the Netherlands for services performed for the
Netherlands are exempt from U.S. income tax unless the individual is
both a resident and national of the United States.
These exemptions do not apply to income or pensions for services
performed in connection with a business carried on by the Netherlands,
its political subdivisions, or local authorities.
New Zealand
Income (other than pensions) paid by the Government of New Zealand,
its political subdivisions, or local authorities for services
performed in the discharge of governmental functions is exempt from
U.S. income tax. However, the income is not exempt if the services are
performed in the United States by a U.S. citizen resident in the
United States or by a resident of the United States who did not become
a resident only to perform the services.
Pensions paid by New Zealand in consideration for past governmental
services are exempt from U.S. income tax unless paid to U.S. citizens
resident in the United States.
These exemptions do not apply to payments for services performed in
connection with any trade or business carried on for profit by the
Government of New Zealand (or its subdivisions or local authorities).
Norway
Wages, salaries, and similar income, including pensions and similar
benefits paid by or from public funds of Norway or its political
subdivisions or local authorities to a citizen of Norway for labor or
personal services performed for Norway or any of its political
subdivisions or local authorities in the discharge of governmental
functions are exempt from U.S. income tax.
Pakistan
Income, including pensions and annuities, paid to certain
individuals by or on behalf of the Government of Pakistan or the
Government of a Province in Pakistan or one of its local authorities
for services performed in the discharge of functions of that
Government or local authority is exempt from U.S. income tax. To be
exempt from tax, these payments must be made to citizens of Pakistan
who do not have immigrant status in the United States. This exemption
does not apply to payments for services performed in connection with
any trade or business carried on for profit.
Philippines
Wages, salaries, and similar income, including pensions, annuities,
and similar benefits, paid from public funds of the Republic of the
Philippines to a citizen of the Philippines (or to a citizen of
another country other than the United States who comes to the United
States specifically to work for the Government of the Philippines) for
labor or personal services performed as an employee of the national
Government of the Philippines or any of its agencies in the discharge
of governmental functions are exempt from U.S. income tax.
Poland
Wages, salaries, and similar income, including pensions, annuities,
and similar benefits, paid from public funds of Poland to a citizen of
Poland (other than a U.S. citizen or one admitted to the United States
for permanent residence) for labor or personal services performed as
an employee of the national Government of Poland in the discharge of
governmental functions are exempt from U.S. income tax.
Portugal
Income, other than a pension, paid by Portugal, its political or
administrative subdivisions, or local authorities to an individual for
services performed for the paying governmental body is exempt from
U.S. income tax. However, the exemption does not apply to payments for
services performed in the United States by a U.S. resident who either:
- Is a U.S. national, or
- Did not become a U.S. resident only to perform the
services.
Pensions paid by Portugal for services performed for Portugal are
exempt from U.S. income tax unless the recipient is a resident and
national of the United States.
These exemptions do not apply to income or pensions for services
performed in connection with a business carried on by Portugal or its
political or administrative subdivisions, or local authorities.
Romania
Wages, salaries, and similar income, including pensions, annuities,
and similar benefits, paid from public funds of Romania to a citizen
of Romania (other than a U.S. citizen or one admitted to the United
States for permanent residence) for labor or personal services
performed as an employee of the national Government of Romania in the
discharge of governmental functions are exempt from U.S. income tax.
Russia
Income, other than a pension, paid by Russia, its republics, or
local authorities to an individual for government services is exempt
from U.S. tax. However, the exemption does not apply if the services
are performed in the United States by a U.S. resident who either:
- Is a U.S. citizen, or
- Did not become a U.S. resident solely for the purpose of
performing the services.
Pensions paid by Russia, its republics, or local authorities for
services performed for Russia is exempt from U.S. tax unless the
individual is both a resident and citizen of the United States.
These exemptions do not apply to income or pensions for services
performed in connection with a business.
Slovak Republic
Income, including a pension, paid from the public funds of the
Slovak Republic, its political subdivisions, or local authorities to a
Slovak citizen for services performed in the discharge of governmental
functions is exempt from U.S. income tax. This exemption does not
apply to income paid for services performed in connection with a
business carried on by the Slovak Republic, its political
subdivisions, or local authorities.
South Africa
Income, other than a pension, paid by South Africa or its political
subdivisions or local authorities to an individual for services
performed for the paying governmental body is exempt from U.S. income
tax. However, the exemption does not apply to payments for services
performed in the United States by a resident of the United States who
either:
- Is a U.S. citizen, or
- Did not become a U.S. resident only to perform the
services.
Pensions paid by South Africa for services performed for South
Africa are exempt from U.S. income tax unless the recipient is both a
resident and citizen of the United States.
These exemptions do not apply to income or pensions for services
performed in connection with a business carried on by South Africa or
its subdivisions or local authorities.
Spain
Income, other than a pension, paid by Spain, its political
subdivisions, or local authorities to an individual for services
performed for the paying governmental body is exempt from U.S. income
tax. However, the exemption does not apply to payments for services
performed in the United States by a resident of the United States who
either:
- Is a U.S. citizen, or
- Did not become a U.S. resident only to perform the
services.
Pensions paid by Spain, its political subdivisions, or local
authorities for services performed for Spain are exempt from U.S. tax
unless the individual is a citizen and resident of the United States.
These exemptions do not apply to income or pensions for services
performed in connection with a trade or business carried on by Spain,
its subdivisions, or local authorities.
Sweden
Income, other than a pension, paid by Sweden, its political
subdivisions, or local authorities to an individual for services
performed for the paying governmental body is exempt from U.S. income
tax. However, the exemption does not apply if the services are
performed in the United States by a U.S. resident who either:
- Is a U.S. citizen, or
- Did not become a U.S. resident solely for the purpose of
performing the services.
Pensions paid by Sweden, its political subdivisions, or local
authorities for services performed for Sweden are exempt from U.S. tax
unless the individual is both a resident and citizen of the United
States.
These exemptions do not apply to income or pensions for services
performed in connection with a business carried on by Sweden, its
political subdivisions, or local authorities.
Switzerland
Income, other than a pension, paid by Switzerland or its political
subdivisions or local authorities to an individual for services
performed for the paying governmental body is exempt from U.S. income
tax. However, the exemption does not apply to payments for services
performed in the United States by a resident of the United States who
either:
- Is a U.S. citizen, or
- Did not become a U.S. resident only to perform the
services.
Pensions paid by Switzerland for services performed for Switzerland
are exempt from U.S. income tax unless the recipient is both a
resident and citizen of the United States.
These exemptions do not apply to income or pensions for services
performed in connection with a business carried on by Switzerland or
its subdivisions or local authorities.
Thailand
Income, other than a pension, paid by Thailand or its political
subdivisions or local authorities to an individual for services
performed for the paying governmental body is exempt from U.S. income
tax. However, the exemption does not apply to payments for services
performed in the United States by a resident of the United States who
either:
- Is a U.S. citizen, or
- Did not become a U.S. resident only to perform the
services.
Pensions paid by Thailand for services performed for Thailand are
exempt from U.S. income tax unless the recipient is both a resident
and citizen of the United States.
These exemptions do not apply to income or pensions for services
performed in connection with a business carried on by Thailand or its
subdivisions or local authorities.
Trinidad and Tobago
Wages, salaries and similar income and pensions, annuities, and
similar benefits paid by or from the public funds of the Government of
Trinidad and Tobago to a national of that country for services
performed for Trinidad and Tobago in the discharge of governmental
functions are exempt from U.S. tax.
Tunisia
Income, other than a pension, paid by Tunisia, its political
subdivisions, or local authorities to a Tunisian citizen for personal
services performed in the discharge of governmental functions is
exempt from U.S. income tax.
Pensions paid by Tunisia, its political subdivisions, or local
authorities for services performed for Tunisia are exempt from U.S.
income tax unless the recipient is a U.S. citizen.
These exemptions do not apply to income or pensions for services
performed in connection with a trade or business carried on by
Tunisia, its political subdivisions, or local authorities.
Turkey
Income, other than a pension, paid by Turkey or its political
subdivisions or local authorities to an individual for services
performed for the paying governmental body is exempt from U.S. income
tax. However, the exemption does not apply to payments for services
performed in the United States by a resident of the United States who
either:
- Is a U.S. citizen, or
- Did not become a U.S. resident only to perform the
services.
Pensions paid by Turkey for services performed for Turkey are
exempt from U.S. income tax unless the recipient is both a resident
and citizen of the United States.
These exemptions do not apply to income or pensions for services
performed in connection with a business carried on by Turkey or its
subdivisions or local authorities.
Ukraine
Note:
See the effective dates of the new treaty under Important
Changes at the beginning of this publication. For information on
the old provisions, see Commonwealth of Independent States.
Income, other than a pension, paid from public funds of Ukraine,
its political subdivisions, or local authorities to an individual for
services performed in the discharge of governmental functions is
exempt from U.S. income tax. However, the exemption does not apply if
the services are performed in the United States by a resident of the
United States who either:
- Is a U.S. citizen, or
- Did not become a U.S. resident only to perform the
services.
Pensions paid by, or by funds created by, Ukraine, its political
subdivisions, or local authorities for services performed for Ukraine
are exempt from U.S. income tax unless the recipient is both a
resident and citizen of the United States.
These exemptions do not apply to income or pensions for services
performed in connection with a trade or business carried on by
Ukraine, its political subdivisions, or local authorities.
United Kingdom
Income, other than a pension, paid by the United Kingdom to
employees for services performed for the United Kingdom is exempt from
U.S. income tax. The exemption does not extend to employees of a
political subdivision or local authority of the United Kingdom. The
exemption does not apply if the services are performed in the United
States and the recipient is both a citizen and a resident of the
United States.
Pensions paid by the United Kingdom or its political subdivisions
or local authorities to individuals for services performed in the
discharge of governmental functions are exempt from U.S. income tax,
unless the recipient is both a citizen and a resident of the United
States.
These exemptions do not apply to payments or pensions for services
performed in connection with a business carried on by or on behalf of
the United Kingdom.
Venezuela
Income, other than a pension, paid by Venezuela, its political
subdivisions, or local authorities to an individual for services
performed for the paying governmental body is exempt from U.S. income
tax. However, the exemption does not apply to payments for services
performed in the United States by a resident of the United States who
either:
- Is a U.S. citizen, or
- Did not become a U.S. resident only to perform the
services.
Pensions paid by Venezuela, its political subdivisions, or local
authorities for services performed for Venezuela are exempt from U.S.
income tax unless the recipient is both a resident and citizen of the
United States.
These exemptions do not apply to payments or pensions for services
performed in connection with a business carried on by Venezuela, its
political subdivisions, or local authorities.
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