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.
Previous | First | Next
Publication Index | 2002 Tax Help Archives | Tax Help Archives | Home