Publication 901 (Rev. April 2000) · Publication 901 (Rev. April 2000) Cat. No. 46849F U.S. Tax Treaties. countries are negotiated and ratified. Pro- ... to pay a $1,000 penalty

ContentsImportant Changes ............................ 1

Important Reminders ......................... 1

Introduction ........................................ 2

Application of Treaties ...................... 2

Tax Exemptions Provided byTreaties ......................................... 2

Personal Services Income .............. 2Professors, Teachers, and

Researchers ............................. 13Students and Apprentices .............. 16Wages and Pensions Paid by a

Foreign Government ................ 24

Explanation of Tables ........................ 28Table 1 - Tax Rates on Income

Other Than Personal ServiceIncome ..................................... 29

Table 2 - Exempt Personal ServicesIncome ..................................... 32

Table 3 - List of Tax Treaties ......... 43

How To Get More Information .......... 44

Important ChangesNew tax treaties. The United States recentlyexchanged instruments of ratification for newincome tax treaties with Estonia, Latvia,Lithuania, and Venezuela. The effective dateof each treaty is January 1, 2000.

U.S.–Denmark income tax treaty. As thispublication was being prepared for print, theUnited States exchanged instruments of rat-ification for a new income tax treaty withDenmark. The treaty replaces an existingtreaty between the two countries that wassigned in 1948. The provisions for taxeswithheld at source are effective for amountspaid or credited on or after May 1, 2000. Forother taxes, the provisions are effective fortax years beginning on or after January 1,2001.

The existing treaty is effective before theabove dates. However, you can elect to applythe old treaty in entirety for one year followingthe date the new treaty would otherwise ap-ply. The old treaty is the one explained in thispublication. For information on the newtreaty, see Obtaining copies of treaties, on thenext page.

Important RemindersDisclosure of a treaty-based position thatreduces your tax. If you take the positionthat any U.S. tax is overruled or otherwisereduced by a U.S. treaty (a treaty-based po-sition), you generally must disclose that posi-tion on your affected return.

U.S.–U.S.S.R. income tax treaty. TheU.S.–U.S.S.R. income tax treaty remains ineffect for the following members of the Com-monwealth of Independent States: Armenia,Azerbaijan, Belarus, Georgia, Kyrgyzstan,Moldova, Tajikistan, Turkmenistan, Ukraine,and Uzbekistan. That treaty will remain ineffect until new treaties with these individual

Departmentof theTreasury

InternalRevenueService

Publication 901(Rev. April 2000)Cat. No. 46849F

U.S. TaxTreaties

countries are negotiated and ratified. Pro-visions of the U.S.–U.S.S.R. income tax treatyare discussed in this publication under Com-monwealth of Independent States.

U.S.–China income tax treaty. TheU.S.–China income tax treaty does not applyto Hong Kong.

IntroductionThis publication will tell you whether a taxtreaty between the United States and a par-ticular country offers a reduced rate of, orpossibly a complete exemption from, U.S. in-come tax for residents of that particularcountry.

Tables in the back of this publication showthe countries that have income tax treatieswith the United States, the tax rates on dif-ferent kinds of income, and the kinds of in-come that are exempt from tax.

CAUTION!

You should use this publication onlyfor quick reference. It is not a com-plete guide to all provisions of every

income tax treaty.

Useful ItemsYou may want to see:

Publication

� 519 U.S. Tax Guide for Aliens

� 597 Information on the UnitedStates–Canada Income TaxTreaty

� 686 Certification for Reduced TaxRates in Tax Treaty Countries

Form (and Instructions)

� 8833 Treaty-Based Return PositionDisclosure Under Section 6114or 7701(b)

See How To Get More Information nearthe end of this publication for informationabout getting these publications and forms.

Obtaining copies of treaties. You can getcomplete information about treaty provisionsfrom the taxing authority in the country fromwhich you receive income or from the treatyitself. The text of some of the treaties can beobtained from:

Department of TreasuryOffice of Public Liaison1500 Pennsylvania Ave. NW — Rm. 4418Washington, D.C. 20220

If you have specific questions about a treaty,you can get this information from most Inter-nal Revenue Service offices or from:

Internal Revenue ServiceAttn: OP:IN:D:CS950 L'Enfant Plaza South, S.W.Washington, DC 20024

Application of TreatiesThe United States has income tax treaties

with a number of foreign countries. Underthese treaties, residents (not necessarily cit-

izens) of foreign countries are taxed at a re-duced rate, or are exempt from U.S. incometaxes on certain items of income they receivefrom sources within the United States. Thesereduced rates and exemptions vary amongcountries and specific items of income.

If the treaty does not cover a particularkind of income, or if there is no treaty betweenyour country and the United States, you mustpay tax on the income in the same way andat the same rates shown in the instructionsfor Form 1040NR. Also see Publication 519.

Many of the individual states of the UnitedStates tax the income of their residents.Therefore, you should consult the tax author-ities of the state in which you live to find outif that state taxes the income of individualsand, if so, whether the tax applies to any ofyour income.

Tax treaties reduce the U.S. taxes of res-idents of foreign countries. With certain ex-ceptions, they do not reduce the U.S. taxesof U.S. citizens or residents. U.S. citizens andresidents are subject to U.S. income tax ontheir worldwide income.

Treaty provisions generally are reciprocal(apply to both treaty countries); therefore, aU.S. citizen or resident who receives incomefrom a treaty country may refer to the tablesin this publication to see if a tax treaty mightaffect the tax to be paid to that foreign coun-try. Foreign taxing authorities sometimes re-quire certification from the U.S. Governmentthat an applicant filed an income tax returnas a U.S. citizen or resident, as part of theproof of entitlement to the treaty benefits. Forinformation on this, see Publication 686.

Disclosure of a treaty-based position thatreduces your tax. If you take the positionthat any U.S. tax is overruled or otherwisereduced by a U.S. treaty (a treaty-based po-sition), you generally must disclose that posi-tion on Form 8833 and attach it to your return.If you are not required to file a return becauseof your treaty-based position, you must file areturn anyway to report your position. The fil-ing of Form 8833 does not apply to a reducedrate of withholding tax on noneffectively con-nected income, such as dividends, interest,rents or royalties, or to a reduced rate of taxon pay received for services performed as anemployee, including pensions, annuities, andsocial security. For more information, getPublication 519.

If you fail to file Form 8833, you may haveto pay a $1,000 penalty. Corporations aresubject to a $10,000 penalty for each failure.

Tax ExemptionsProvided by TreatiesIn addition to the tables in the back of thispublication, this publication contains dis-cussions of the exemptions from tax andcertain other effects of the tax treaties on thefollowing types of income.

1) Pay for certain personal services per-formed in the United States.

2) Pay of a professor, teacher, or re-searcher who teaches or performs re-search in the United States for a limitedtime.

3) Amounts received for maintenance andstudies by a foreign student or appren-tice who is here for study or experience.

4) Wages, salaries, and pensions paid bya foreign government.

Personal Services IncomePay for certain personal services performedin the United States is exempt from U.S. in-come tax if you are a resident of one of thecountries discussed below, if you are in theUnited States for a limited number of daysand if you meet certain other conditions. Forthis purpose, the word “day” means a dayduring any part of which you are physicallypresent in the United States.

Terms defined. Several terms appear inmany of the discussions that follow. The ex-act meanings of the terms are determined bythe particular tax treaty under discussion;thus, the meanings vary among treaties. Thedefinitions that follow are, therefore, generaldefinitions that may not give the exact mean-ing intended by a particular treaty.

The terms fixed base and permanentestablishment generally mean a fixed placeof business, such as an office, a factory, awarehouse, or a mining site, through whichan enterprise carries on its business.

The term borne by generally means hav-ing ultimate financial accounting responsibilityfor or providing the monetary resources foran expenditure or payment, even if anotherentity in another location actually made theexpenditure or payment.

AustraliaIncome that residents of Australia receive forperforming personal services as independentcontractors or self-employed individuals (in-dependent personal services) in the UnitedStates during the tax year is exempt from U.S.income tax if the residents:

1) Are in the United States for no more than183 days during the tax year, and

2) Do not have a fixed base regularlyavailable to them in the United States forthe purpose of performing the services.

If they have a fixed base available in theUnited States, they are taxed on the incomeattributable to the fixed base.

Pay that residents of Australia receive forlabor or personal services performed in theUnited States as employees (dependent per-sonal services), including services as a di-rector of a company, is exempt from U.S. in-come tax if:

1) The residents are in the United States forno more than 183 days during the taxyear,

2) The pay is paid by, or on behalf of, anemployer or company that is not a resi-dent of the United States, and

3) The pay is not deductible in determiningthe taxable income of the trade or busi-ness of the employer (or company) in theUnited States.

These exemptions do not apply to publicentertainers (such as theater, motion picture,radio, or television entertainers, musiciansand athletes) from Australia who earn morethan $10,000 in gross receipts, including re-imbursed expenses, from their entertainmentactivities in the United States during the taxyear.

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AustriaIncome that residents of Austria receive forpersonal services as independent contractorsor self-employed individuals (independentpersonal services) in the United States is ex-empt from U.S. income tax if they do not havea fixed base regularly available to them in theUnited States for performing the services. Ifthey have a fixed base available in the UnitedStates, they are taxed on the income attrib-utable to the fixed base.

Income that residents of Austria receivefor services performed in the United Statesas employees (dependent personal services)is exempt from U.S. income tax if the resi-dents meet the following requirements:

1) They are in the United States for nomore than 183 days in any 12-monthperiod beginning or ending in the taxyear,

2) Their income is paid by, or on behalf of,an employer who is not a U.S. resident,and

3) Their income is not borne by a perma-nent establishment or a fixed base thatthe employer has in the United States.

These exemptions do not apply to publicentertainers (such as theater, motion picture,radio, or television entertainers, musiciansand athletes) from Austria who earn morethan $20,000 in gross receipts, including re-imbursed expenses, from their entertainmentactivities in the United States during the taxyear.

Income received by a resident of Austriafor services performed as an employee andmember of the regular complement of a shipor aircraft operated in international traffic isexempt from U.S. income tax.

Former treaty. For 1999, you can elect toapply the old treaty in its entirety. The pro-visions for personal service are as follows.

Income that residents of Austria receivefor labor or personal services (includingpracticing liberal professions and performingservices as a director) performed in theUnited States is exempt from U.S. income taxif they are temporarily in the United States forno more than 183 days during the tax yearand the income is not more than $3,000.

Income, regardless of amount, receivedby residents of Austria who are temporarily inthe United States for no more than 183 daysduring the tax year is also exempt from U.S.income tax if it is received for labor or per-sonal services performed as an employee of,or under contract with, a natural person whois a resident of Austria or an Austrian corpo-ration, and it is borne by that person or cor-poration.

BarbadosIncome that residents of Barbados receive forperforming personal services as independentcontractors or self-employed individuals (in-dependent personal services) in the UnitedStates during the tax year is exempt from U.S.income tax if the residents:

1) Are in the United States for no more than89 days during the tax year,

2) Earn net income for independent ser-vices provided to U.S. residents that isnot more than $5,000 (there is no dollarlimit if the contractors are not U.S. resi-dents), and

3) Do not have a regular base available inthe United States for performing theservices.

If they have a regular base available in theUnited States but otherwise meet the condi-tions for exemption, they are taxed only onthe income attributable to the regular base.

Income that residents of Barbados receivefor personal services performed in the UnitedStates as employees (dependent personalservices) is exempt from U.S. tax if the resi-dents meet four requirements:

1) They are in the United States for nomore than 183 days during the calendaryear,

2) The income earned in the calendar yearin the United States is not more than$5,000,

3) Their income is paid by or for an em-ployer who is not a U.S. resident, and

4) The income is not borne by a permanentestablishment or regular base of theemployer in the United States.

Income of a Barbadian resident from em-ployment as a member of the regular com-plement of a ship or aircraft operated ininternational traffic is exempt from U.S. tax.

These exemptions do not apply toBarbadian resident public entertainers (suchas theater, motion picture, radio, or televisionartists, musicians, or athletes) who receivegross receipts of more than $250 per day or$4,000 in the tax year, not including reim-bursed expenses, from their entertainmentactivities in the United States. However, theexemptions do apply regardless of these lim-its on gross receipts if the entertainer's visitto the United States is substantially supportedby Barbadian public funds or if theentertainer's services are provided to anonprofit organization.

BelgiumIncome that residents of Belgium receive forperforming personal services as independentcontractors or self-employed individuals (in-dependent personal services) in the UnitedStates during the tax year is exempt from U.S.income tax if the residents:

1) Are present in the United States lessthan 183 days during the tax year, and

2) Do not maintain a fixed base in theUnited States for a period or periods thattotal more than 182 days during the taxyear.

If they do not meet condition (2), they aretaxed on the income attributed to the base.

The exemption for independent personalservices does not apply to individuals who arepublic entertainers (theater, motion picture,or television artists, musicians, or athletes), ifthey are in the United States for more than90 days during the tax year or if their pay forservices as public entertainers is more than$3,000.

Income that residents of Belgium receivefor labor or personal services performed inthe United States as employees (dependentpersonal services), including services as anofficer of a corporation, is exempt from U.S.income tax if the residents meet three re-quirements:

1) They are present in the United Statesless than 183 days during the tax year,

2) They are employees of a resident ofBelgium or of a permanent establish-ment in Belgium, and

3) Their income is not borne by a perma-nent establishment that the employerhas in the United States.

Income for services performed by an indi-vidual as an employee aboard a ship or anaircraft registered in Belgium and operatedby a resident of Belgium in international trafficis exempt from U.S. tax if the individual is amember of the regular complement of theship or aircraft.

These exemptions do not apply to feesreceived by a resident of Belgium for servicesperformed as a director of a U.S. corporationif the fees are treated as a distribution ofprofits and cannot be taken as a deductionby the corporation.

CanadaIncome that residents of Canada receive forpersonal services as independent contractorsor self-employed individuals (independentpersonal services) that they perform duringthe tax year in the United States (except aspublic entertainers) is exempt from U.S. taxif they do not have a fixed base regularlyavailable to them in the United States forperforming the services. If they have a fixedbase available in the United States, they aretaxed on the income attributable to the fixedbase.

Income that residents of Canada receivefor personal services performed as employ-ees (dependent personal services) in theUnited States (except as public entertainers)is exempt from U.S. tax if it is not more than$10,000 for the year. If it is more than$10,000 for the year, it is exempt only if:

1) The residents are present in the UnitedStates for no more than 183 days duringthe calendar year, and

2) The income is not borne by a U.S. resi-dent employer or by a permanent es-tablishment or fixed base of an employerin the United States.

These exemptions do not apply to publicentertainers (such as theater, motion picture,radio, or television artists, musicians, orathletes) from Canada who derive more than$15,000 in gross receipts, including reim-bursed expenses, from their entertainmentactivities in the United States during the cal-endar year. However, the exemptions do ap-ply, regardless of this $15,000 limit, toathletes participating in team sports inleagues with regularly scheduled games inboth Canada and the United States.

Pay received by a resident of Canada foremployment regularly done in more than onecountry on a ship, aircraft, motor vehicle, ortrain operated by a Canadian resident is ex-empt from U.S. tax.

China, People's Republic ofIncome that residents of the People's Re-public of China receive for personal servicesas independent contractors or self-employedindividuals (independent personal services)that they perform during the tax year in theUnited States (except as athletes or publicentertainers) is exempt from U.S. income taxif the residents:

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1) Are present in the United States for nomore than 183 days in the calendar year,and

2) Do not have a fixed base regularlyavailable in the United States for per-forming the services.

If they have a fixed base available in theUnited States, they are taxable on the incomeattributable to the fixed base.

Pay received by residents of the People'sRepublic of China for services performed asemployees (dependent personal services) inthe United States (except as athletes or publicentertainers) is exempt from U.S. tax if:

1) The residents are present in the UnitedStates for no more than 183 days in thecalendar year,

2) The pay is paid by or for an employerwho is not a U.S. resident, and

3) The pay is not borne by a permanentestablishment or fixed base that theemployer has in the United States.

These exemptions do not apply to direc-tors' fees for service on the board of directorsof a U.S. corporation.

These exemptions generally do not applyto income received as a public entertainer(such as a theater, motion picture, radio, ortelevision artist, musician, or athlete). How-ever, income of athletes or public entertainersfrom China participating in a cultural ex-change program agreed upon by the U.S. andChinese governments is exempt from U.S.tax.

Commonwealth ofIndependent StatesIncome that residents of a C.I.S. member re-ceive for performing personal services in theUnited States is exempt from U.S. income taxif those residents are in the United States forno more than 183 days during the tax year.

Pay received by an employee who is amember of the regular complement of a shipor aircraft operated in international traffic bya C.I.S. member or a resident of a C.I.S.member is exempt from U.S. tax.

CyprusIncome that residents of Cyprus receive forperforming personal services as independentcontractors or self-employed individuals (in-dependent personal services) in the UnitedStates during the tax year is exempt from U.S.income tax if the residents:

1) Are present in the United States for lessthan 183 days in the tax year, and

2) Do not have a fixed base regularlyavailable to them in the United States forperforming the services.

If they have a fixed base available in theUnited States, they are taxable on the incomeattributable to the fixed base.

Pay received by residents of Cyprus fromservices performed as employees (dependentpersonal services), including services as anofficer of a corporation, is exempt from U.S.income tax if:

1) The residents are in the United States forless than 183 days during the tax year,

2) The pay is paid by or for an employerwho is not a U.S. resident, and

3) The pay is not borne by a permanentestablishment, fixed base, or trade orbusiness that the employer has in theUnited States.

Pay received by a Cyprus resident forperforming personal services as an employeeand member of the regular complement of aship or aircraft operated in international trafficby a resident of Cyprus is exempt from U.S.tax.

These exemptions do not apply to Cyprusresident public entertainers (theater, motionpicture, radio, or television artists, musicians,or athletes) who receive gross receipts ofmore than $500 per day or $5,000 for the taxyear, not including reimbursed expenses,from their entertainment activities in theUnited States.

Directors' fees received by residents ofCyprus for service on the board of directorsof a U.S. corporation are exempt from U.S.income tax to the extent of a reasonable fixedamount payable to all directors for each dayof attendance at directors' meetings held inthe United States.

Czech RepublicIncome that residents of the Czech Republicreceive for performing personal services asindependent contractors or self-employed in-dividuals (independent personal services) inthe United States is exempt from U.S. incometax if the residents:

1) Are present in the United States for nomore than 183 days in any 12-monthperiod, and


If they have a fixed base available, they aretaxed only on income attributable to the fixedbase.

Income that residents of the Czech Re-public receive for employment in the UnitedStates (dependent personal services) is ex-empt from U.S. income tax if the followingthree requirements are met:

1) The resident is present in the UnitedStates for no more than 183 days in any12-month period,

2) The income is paid by, or on behalf of,an employer who is not a U.S. resident,and

3) The income is not borne by a permanentestablishment or a fixed base that theemployer has in the United States.

These exemptions do not apply to incomeresidents of the Czech Republic receive aspublic entertainers (such as theater, motionpicture, radio, or television artists, or musi-cians) or sportsmen if their gross receipts,including reimbursed expenses, are morethan $20,000 during the tax year. Regardlessof these limits, income of Czech entertainersand sportsmen is exempt from U.S. incometax if their visit to the United States is sub-stantially supported by public funds of theCzech Republic, its political subdivisions, orlocal authorities, or the visit is made pursuantto a specific arrangement between the UnitedStates and the Czech Republic.

These exemptions do not apply to direc-tors' fees and similar payments received bya resident of the Czech Republic as a mem-

ber of the board of directors of a companythat is a resident of the United States.

Income from employment as a memberof the regular complement of a ship or aircraftoperated by a Czech enterprise in interna-tional traffic is exempt from U.S. income tax.

DenmarkIncome that residents of Denmark receive forlabor or personal services (including practic-ing liberal professions) performed in theUnited States is exempt from U.S. income taxif they are temporarily in the United States forno more than 90 days during the tax year andtheir pay is not more than $3,000.

All income for labor or personal servicesthat residents of Denmark perform as em-ployees of, or under contract with, a resident,corporation, or other entity of Denmark is ex-empt from U.S. income tax if they are in theUnited States for no more than 180 daysduring the tax year.

EgyptIncome that residents of Egypt receive forperforming personal services as independentcontractors or as self-employed individuals(independent personal services) in the UnitedStates during the tax year is exempt from U.S.income tax if they are in the United States forno more than 89 days during the tax year.

Income that residents of Egypt receive forlabor or personal services performed in theUnited States as employees (dependent per-sonal services), including income for servicesperformed by an officer of a corporation orcompany, is exempt from U.S. income tax ifthe residents meet four requirements:

1) They are in the United States for nomore than 89 days during the tax year,

2) They are employees of a resident of, ora permanent establishment in, Egypt,

3) Their income is not borne by a perma-nent establishment that the employerhas in the United States, and

4) Their income is subject to Egyptian tax.

Pay received by a resident of Egypt whois an employee and member of the regularcomplement of a ship or an aircraft operatedin international traffic by a resident of Egyptis exempt.

These exemptions do not apply toEgyptian resident public entertainers (theater,motion picture, radio, or television artists,musicians, or athletes), who earn income forservices as public entertainers (both inde-pendent and dependent personal services) ifthe gross amount of the income is more than$400 for each day they are in the UnitedStates performing the services.

EstoniaIncome that residents of Estonia receive forperforming personal services as independentcontractors or self-employed individuals (in-dependent personal services) in the UnitedStates is exempt from U.S. income tax if theresidents:

1) Are in the United States for no more than183 days in any 12-month period begin-ning or ending in the tax year, and


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If they have a fixed base available, they aretaxed on the income attributable to the fixedbase.

Income that residents of Estonia receivefor services performed in the United Statesas employees (dependent personal services)is exempt from U.S. income tax if the follow-ing requirements are met:

1) The resident is in the United States forno more than 183 days in any 12-monthperiod beginning or ending in the taxyear,



These exemptions do not apply to direc-tors' fees and similar payments received bya resident of Estonia as a member of theboard of directors or similar body of a com-pany that is a U.S. resident.

Income from employment as a memberof the regular complement of a ship or anaircraft operated by an Estonian enterprise ininternational traffic is exempt from U.S. in-come tax.

These exemptions do not apply to incomeresidents of Estonia receive as publicentertainers (such as theater, motion picture,radio, or television artists, or musicians) orsportsmen if their gross receipts, includingreimbursed expenses, are more than $20,000for their personal activities in the UnitedStates during the tax year. Regardless ofthese limits, income of Estonian entertainersor athletes is exempt from U.S. income tax iftheir visit to the United States is wholly ormainly supported by public funds of Estonia,its political subdivisions, or local authorities.

FinlandIncome that residents of Finland receive forperforming personal services as independentcontractors or self-employed individuals (in-dependent personal services) in the UnitedStates is exempt from U.S. income tax if theydo not have a fixed base regularly availableto them in the United States for performingthe services. If they have a fixed base avail-able in the United States, they are taxed onthe income attributable to the fixed base.

Income that residents of Finland receivefor labor or personal services performed inthe United States as employees (dependentpersonal services) is exempt from U.S. in-come tax if the residents meet three require-ments:

1) They are in the United States for nomore than 183 days during any12-month period,

2) Their income is paid by, or on behalf of,an employer who is not a resident of theUnited States, and

3) Their income is not borne by a perma-nent establishment, fixed base, or tradeor business that the employer has in theUnited States.

Income received for performing personalservices as an employee and member of theregular complement of a ship or aircraft op-erated in international traffic by a resident ofFinland is exempt from U.S. tax.

These exemptions do not apply to incomeresidents of Finland receive as publicentertainers or sportsmen if the gross income,including reimbursed expenses, is more than$20,000 for their personal activities in theUnited States during the calendar year.

FranceIncome that residents of France receive forperforming personal services as independentcontractors or self-employed individuals (in-dependent personal services) in the UnitedStates is exempt from U.S. income tax if theydo not have a fixed base regularly availableto them in the United States for performingthe services. If they have a fixed base avail-able in the United States, they are taxed onthe income attributable to the fixed base.

Income that residents of France receivefor labor or personal services performed inthe United States as employees (dependentpersonal services) is exempt from U.S. in-come tax if the residents meet three require-ments:

1) They are in the United States for nomore than 183 days in any 12–monthperiod,



Income for services performed by a resi-dent of France as an employee and memberof the regular complement of a ship or anaircraft operated in international traffic is ex-empt from tax in the United States.

These exemptions do not apply to publicentertainers (such as theater, motion picture,radio, or television artists, musicians), orsportsmen from France who earn more than$10,000 in gross receipts, including reim-bursed expenses, from their entertainmentactivities in the United States during the taxyear. Regardless of these limits, income ofFrench entertainers or sportsmen is exemptfrom U.S. tax if their visit is principally sup-ported by public funds of France.

These exemptions do not apply to direc-tors' fees and similar payments received bya resident of France as a member of theboard of directors of a company that is aresident of the United States.

GermanyIncome that residents of Germany receive forperforming personal services as independentcontractors or self-employed individuals (in-dependent personal services) in the UnitedStates is exempt from U.S. income tax if theincome is not attributable to a fixed baseregularly available in the United States.

Income that residents of Germany receivefor labor or personal services performed inthe United States as employees (dependentpersonal services) is exempt from U.S. tax ifthe residents meet three requirements:

1) They are in the United States for nomore than 183 days during the calendaryear,

2) The income is paid by, or on behalf of,an employer who is not a resident of theUnited States, and


Pay received by a resident of Germany forservices performed as an employee andmember of the regular complement of a shipor aircraft operated in international traffic isexempt from U.S. tax.

These exemptions do not apply to direc-tors' fees and other similar payments receivedby a resident of Germany for services per-formed in the United States as a member ofthe board of directors of a company residentin the United States.

These exemptions do not apply to incomeresidents of Germany receive as publicentertainers (such as theater, motion picture,radio or television artists, or musicians) orathletes if their gross receipts, including re-imbursed expenses, are more than $20,000during the calendar year. Regardless of theselimits, income of German entertainers orathletes is exempt from U.S. tax if their visitto the United States is substantially supportedby public funds of Germany, its political sub-divisions, or local authorities.

GreeceIncome that residents of Greece receive forlabor or personal services (including practic-ing liberal and artistic professions) is exemptfrom U.S. income tax if they are in the UnitedStates for no more than 183 days during thetax year and the pay is not more than$10,000. The pay, regardless of amount, isexempt from U.S. income tax if it is for laboror personal services performed as employeesof, or under contract with, a resident ofGreece or a Greek corporation or other entityof Greece, and if the residents are in theUnited States for no more than 183 daysduring the tax year.

HungaryIncome that residents of Hungary receive forperforming personal services as independentcontractors or self-employed individuals (in-dependent personal services) in the UnitedStates during the tax year is exempt from U.S.tax if the residents:


2) Do not have a fixed base regularlyavailable in the United States.


Income that residents of Hungary receivefor labor or personal services performed inthe United States as employees (dependentpersonal services) is exempt from U.S. in-come tax if the residents meet three require-ments:


2) Their income is paid by or on behalf ofan employer who is not a resident of theUnited States, and


Pay received by an employee who is amember of the regular complement of a ship

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or aircraft operated by a resident of Hungaryin international traffic is also exempt.

IcelandIncome that residents of Iceland receive forperforming personal services as independentcontractors or self-employed individuals (in-dependent personal services) in the UnitedStates during the tax year is exempt from U.S.income tax if the residents:

1) Are present in the United States for nomore than 182 days during the tax year,and

2) Do not maintain a fixed base in theUnited States for a period or periods to-taling more than 182 days during the taxyear.

If they do not meet condition (2), they aretaxed on the income that is attributable to thefixed base.

This exemption does not apply to resi-dents of Iceland who are public entertainers(theater, motion picture, or television artists,musicians, or athletes) if they are in theUnited States for more than 90 days duringthe tax year or their pay for services as publicentertainers is more than $100 per day.

Income that residents of Iceland receivefor labor or personal services performed inthe United States as employees (dependentpersonal services) is exempt from U.S. in-come tax if the employees meet three re-quirements:


2) They are employees of a resident ofIceland or of a permanent establishmentof a resident of a state other than Icelandif the permanent establishment is locatedin Iceland, and


Income for services performed by an em-ployee aboard a ship or an aircraft operatedby a resident of Iceland in international trafficor in fishing on the high seas is exempt fromU.S. tax if the individual is a member of theregular complement of the ship or aircraft.

IndiaIncome that residents of India receive forperforming personal services in the UnitedStates during the tax year as independentcontractors or self-employed individuals (in-dependent personal services) is exempt fromU.S. income tax if the residents:



If they have a fixed base available, theyare taxed only on income attributable to thefixed base.

Income that residents of India receive forpersonal services performed in the UnitedStates as employees (dependent personalservices) is exempt from U.S. income tax ifthe residents meet three requirements:

1) They are present in the United States forno more than 183 days during the taxyear,


3) The income is not borne by a permanentestablishment, fixed base, or trade orbusiness the employer has in the UnitedStates.

These exemptions do not apply to direc-tors' fees and similar payments received byan Indian resident as a member of the boardof directors of a company that is a U.S. resi-dent.

Pay received by a resident of India forservices performed as an employee aboarda ship or aircraft operated by an Indian en-terprise in international traffic is exempt fromU.S. tax.

These exemptions do not apply to incomeresidents of India receive as publicentertainers (such as theater, motion picture,radio, or television artists, or musicians) orathletes if their net income is more than$1,500 during the tax year for their enter-tainment activities in the United States. Re-gardless of this limit, the income of Indianentertainers and athletes is exempt from U.S.tax if their visit to the United States is whollyor substantially supported from the publicfunds of the Indian Government, its politicalsubdivisions, or local authorities.

IndonesiaIncome that residents of Indonesia receive forperforming personal services as individualcontractors or self-employed individuals (in-dependent personal services) in the UnitedStates during the tax year is exempt from U.S.income tax if the residents:

1) Are present in the United States for nomore than 119 days during any consec-utive 12-month period, and


If they have a fixed base available, theyare taxed only on the income attributable tothe fixed base.

Income that residents of Indonesia receivefor personal services performed in the UnitedStates as employees (dependent personalservices) is exempt from U.S. income tax ifthe residents meet three requirements:

1) They are present in the United Statesno more than 119 days during any con-secutive 12-month period,


3) The income is not borne or reimbursedby a permanent establishment the em-ployer has in the United States.

Pay received by an individual for servicesperformed as an employee aboard a ship oraircraft operated by an Indonesian resident ininternational traffic is exempt from U.S. tax ifthe individual is a member of the regularcomplement of the ship or aircraft.

These exemptions do not apply to incomeresidents of Indonesia receive as publicentertainers (such as theater, motion picture,radio, or television artists, or musicians) or

athletes if their gross receipts, including re-imbursed expenses, are more than $2,000during any consecutive 12-month period.Regardless of these limits, income ofIndonesian entertainers and athletes is ex-empt from U.S. tax if their visit to the UnitedStates is substantially supported or spon-sored by the Indonesian Government and theIndonesian competent authority certifies thatthe entertainers or athletes qualify for thisexemption.

IrelandIncome that residents of Ireland receive forpersonal services as independent contractorsor self-employed individuals (independentpersonal services) in the United States is ex-empt from U.S. income tax if they do not havea fixed base regularly available to them in theUnited States for performing the services. Ifthey have a fixed base available in the UnitedStates, they are taxed on the income attrib-utable to the fixed base.

Income that residents of Ireland receivefor services performed in the United Statesas employees (dependent personal services)is exempt from U.S. income tax if the resi-dents meet the following requirements:




These exemptions do not apply to direc-tors' fees and similar payments received bya resident of Ireland as a member of theboard of directors of a company that is aresident of the United States. However,amounts received for attending meetings inIreland are not subject to U.S. income tax.

Income received by a resident of Irelandfor services performed as an employee andmember of the regular complement of a shipor aircraft operated in international traffic isexempt from U.S. income tax.

These exemptions do not apply to publicentertainers (such as theater, motion picture,radio, or television entertainers, musiciansand athletes) from Ireland who earn morethan $20,000 in gross receipts, including re-imbursed expenses, from their entertainmentactivities in the United States during the taxyear.

IsraelIncome that residents of Israel receive forperforming personal services as independentcontractors or as self-employed individuals(independent personal services) in the UnitedStates during the tax year is exempt from U.S.income tax if they are in the United States forno more than 182 days during the tax year.

Income that residents of Israel receive forlabor or personal services performed in theUnited States as employees (dependent per-sonal services), including income for servicesperformed by an officer of a corporation orcompany, is exempt from U.S. income tax ifthe residents meet four requirements:


Page 6

2) They are employees of a resident of, ora permanent establishment in, Israel,

3) Their income is not borne by a perma-nent establishment that the employerhas in the United States, and

4) Their income is subject to Israeli tax.

Generally, pay received by an employeeof a resident of Israel for labor or personalservices performed as a member of the reg-ular complement of a ship or an aircraft op-erated in international traffic by a resident ofIsrael is exempt.

These exemptions do not apply to incomethat residents of Israel receive as publicentertainers (such as theater, motion picture,radio or television artists, musicians, orathletes), if the gross amount of the incomeis more than $400 for each day they are in theUnited States performing the services.

ItalyIncome that residents of Italy receive for per-forming personal services in the United Statesduring the tax year as independent contrac-tors or self-employed individuals (independ-ent personal services) is exempt from U.S.income tax if the residents:

1) Are present in the United States for nomore than 183 days in the tax year, and


If they have a fixed base available, they aretaxed only on the income attributable to thefixed base.

Income that residents of Italy receive forpersonal services performed in the UnitedStates as employees (dependent personalservices) is exempt from U.S. income tax if:

1) The residents are present in the UnitedStates for not more than 183 days duringthe tax year,

2) The income is paid by or for an employerwho is not a U.S. resident, and

3) The income is not borne by a permanentestablishment or fixed base that theemployer has in the United States.

Pay received by a resident of Italy fromemployment regularly exercised aboard aship or aircraft operated by an Italian enter-prise in international traffic is exempt fromU.S. tax.

These exemptions do not apply to direc-tors' fees and similar payments received byan Italian resident as a member of the boardof directors of a company that is a U.S. resi-dent.

These exemptions do not apply to incomeresidents of Italy receive as publicentertainers (such as theater, motion picture,radio, or television artists, musicians, orathletes) if they are present in the UnitedStates for more than 90 days during the taxyear or their gross receipts, including reim-bursed expenses, are more than $12,000during the tax year for their entertainmentactivities in the United States.

JamaicaIncome that residents of Jamaica receive forthe performance of personal services as in-dependent contractors or self-employed indi-viduals (independent personal services) in the

United States during the tax year is exemptfrom U.S. income tax if the residents:


2) Do not have a fixed base regularlyavailable to them in the United States forperforming their services, and

3) Earn net income for those services thatis not more than $5,000 during the taxyear if the income is from a U.S. con-tractor.

If they have a fixed base available in theUnited States, they are taxed only on the in-come that is attributable to the fixed base.There is no dollar limit for condition (3) if thecontractor is from a country other than theUnited States.

Income that residents of Jamaica receivefor personal services performed in the UnitedStates as employees (dependent personalservices) is exempt from U.S. income tax ifthe residents meet four requirements:


2) Their income is paid by or for an em-ployer who is not a resident of the UnitedStates,

3) Their income is not borne by a perma-nent establishment or a fixed base thatthe employer has in the United States,and

4) Their net income received for the ser-vices is not more than $5,000 during thetax year.

Pay received from employment as amember of the regular complement of a shipor an aircraft operated in international trafficby a Jamaican enterprise is exempt.

These exemptions do not apply to incomethat residents of Jamaica receive for per-forming services (both independent and de-pendent personal services) in the UnitedStates as entertainers, such as theater, mo-tion picture, radio, or television artists, musi-cians, or athletes, if the gross receipts (ex-cluding reimbursements for expenses) fromthe services are more than $400 a day or$5,000 for the tax year.

Directors' fees received by residents ofJamaica for services performed in the UnitedStates as members of boards of directors ofU.S. corporations are exempt from U.S. taxif the fees (excluding reimbursed expenses)are not more than $400 per day for each daythe directors are present in the United Statesto perform the services.

JapanIncome that residents of Japan receive forperforming personal services as independentcontractors or self-employed individuals (in-dependent personal services) in the UnitedStates during the tax year is exempt from U.S.income tax if the residents:


2) Do not maintain a fixed base in theUnited States for more than 183 daysduring the tax year.

If they do not meet condition (2), they aretaxed on only the income attributable to thefixed base.

This exemption does not apply to resi-dents of Japan who are public entertainers(theater, motion picture, or television artists,musicians, or athletes) if they are in theUnited States for more than 90 days duringthe tax year or their pay (excluding reim-bursed travel expenses) for services as publicentertainers is more than $3,000 during thetax year.

Income that residents of Japan receive forlabor or personal services performed in theUnited States as employees (dependent per-sonal services), including pay received by anofficer or a member of the board of directorsof a corporation, is exempt from U.S. incometax if the residents meet three requirements:


2) They are employees of a resident ofJapan or of a permanent establishmentof a resident of a state other than Japanif the permanent establishment is locatedin Japan, and


However, the exemption does not apply incertain cases in which the employee ownsstock of the employer or is a member of theemployer's board of directors.

Pay received from employment as amember of the regular complement of a shipor aircraft operated in international traffic bya resident of Japan is exempt.

KazakstanIncome that residents of Kazakstan receivefor performing personal services as inde-pendent contractors or self-employed individ-uals (independent personal services) in theUnited States is exempt from U.S. income taxif:

1) The residents are in the United States forno more than 183 days in any consec-utive 12-month period, and

2) The income is not attributable to a fixedbase in the United States which is regu-larly available to the residents.

If the residents have a fixed base available,they are taxed only on the income attributableto the fixed base.

Income that residents of Kazakstan re-ceive for employment in the United States(dependent personal services) is exempt fromU.S. income tax if the following three re-quirements are met:

1) The resident is in the United States forno more than 183 days in any 12-monthperiod,



Income from employment as a memberof the regular complement of a ship or aircraftoperated in international traffic is exempt fromU.S. tax.

These exemptions do not apply to direc-tors' fees and similar payments received bya resident of Kazakstan as a member of the

Page 7

board of directors or similar body of a com-pany that is a U.S. resident.

Korea, Republic ofIncome that residents of the Republic ofKorea receive for performing personal ser-vices as independent contractors or self-employed individuals (independent personalservices) in the United States during the taxyear is exempt from U.S. tax if the residents:


2) Earn income for those services that isnot more than $3,000 during the taxyear, and


If they maintain a fixed base in the UnitedStates for more than 182 days, they are taxedon the income attributable to the fixed base.

Income that residents of Korea receive forlabor or personal services performed in theUnited States as employees (dependent per-sonal services), including pay for servicesperformed as an officer of a corporation, isexempt from U.S. tax if the residents meetfour requirements:


2) They are employees of a resident ofKorea or of a permanent establishmentmaintained in Korea,

3) Their compensation is not borne by apermanent establishment that the em-ployer has in the United States, and

4) Their income for those services is notmore than $3,000.

Pay received by employees who aremembers of the regular complement of a shipor aircraft operated by a resident of Korea ininternational traffic is exempt.

LatviaIncome that residents of Latvia receive forperforming personal services as independentcontractors or self-employed individuals (in-dependent personal services) in the UnitedStates is exempt from U.S. income tax if theresidents:




Income that residents of Latvia receive forservices performed in the United States asemployees (dependent personal services) isexempt from U.S. income tax if the followingrequirements are met:




These exemptions do not apply to direc-tors' fees and similar payments received bya resident of Latvia as a member of the boardof directors or similar body of a company thatis a U.S. resident.

Income from employment as a memberof the regular complement of a ship or anaircraft operated by a Latvian enterprise ininternational traffic is exempt from U.S. in-come tax.

These exemptions do not apply to incomeresidents of Latvia receive as publicentertainers (such as theater, motion picture,radio, or television artists, or musicians) orsportsmen if their gross receipts, includingreimbursed expenses, are more than $20,000for their personal activities in the UnitedStates during the tax year. Regardless ofthese limits, income of Latvian entertainersor athletes is exempt from U.S. income tax iftheir visit to the United States is wholly ormainly supported by public funds of Latvia, itspolitical subdivisions, or local authorities.

LithuaniaIncome that residents of Lithuania receive forperforming personal services as independentcontractors or self-employed individuals (in-dependent personal services) in the UnitedStates is exempt from U.S. income tax if theresidents:




Income that residents of Lithuania receivefor services performed in the United Statesas employees (dependent personal services)is exempt from U.S. income tax if the follow-ing requirements are met:




These exemptions do not apply to direc-tors' fees and similar payments received bya resident of Lithuania as a member of theboard of directors or similar body of a com-pany that is a U.S. resident.

Income from employment as a memberof the regular complement of a ship or anaircraft operated by a Lithuanian enterprise ininternational traffic is exempt from U.S. in-come tax.

These exemptions do not apply to incomeresidents of Lithuania receive as publicentertainers (such as theater, motion picture,radio, or television artists, or musicians) orsportsmen if their gross receipts, includingreimbursed expenses, are more than $20,000for their personal activities in the United

States during the tax year. Regardless ofthese limits, income of Lithuanian entertainersor athletes is exempt from U.S. income tax iftheir visit to the United States is wholly ormainly supported by public funds of Lithuania,its political subdivisions, or local authorities.

LuxembourgIncome (other than corporate directors' fees)that residents of Luxembourg receive for laboror personal services performed in the UnitedStates during the tax year is exempt from U.S.income tax if the residents are in the UnitedStates for no more than 180 days during thetax year and the income is not more than$3,000.

All income (other than corporate directors'fees) that residents of Luxembourg receive forlabor or personal services performed in theUnited States as an employee is exempt fromU.S. income tax if:

1) The residents are in the United States forno more than 180 days during the taxyear, and

2) The income is borne by an employer thatis a resident or corporation ofLuxembourg, or a permanent establish-ment of a U.S. enterprise inLuxembourg.

MexicoIncome that residents of Mexico receive forperforming personal services as independentcontractors or self-employed individuals (in-dependent personal services) in the UnitedStates is exempt from U.S. income tax if theresidents:

1) Are in the United States for no more than183 days in a 12-month period, and

2) Do not have a fixed base that they reg-ularly use for performing the services.


Income that residents of Mexico receivefor employment in the United States (de-pendent personal services) is exempt fromU.S. tax if the following three requirementsare met:

1) The resident is present in the UnitedStates for no more than 183 days in a12-month period,



These exemptions do not apply to direc-tor's fees and similar payments received bya resident of Mexico for services performedoutside Mexico as a director or overseer of acompany that is a U.S. resident.

These exemptions do not apply to incomeresidents of Mexico receive as publicentertainers (such as theater, motion picture,radio, or television artists, or musicians) orathletes if the income, including reimbursedexpenses, is more than $3,000 during the taxyear for their entertainment activities in theUnited States. This includes income from ac-tivities performed in the United States relatingto the entertainer or athlete's reputation, such

Page 8

as endorsements of commercial products.Regardless of this limit, the income ofMexican entertainers and athletes is exemptfrom U.S. tax if their visit to the United Statesis substantially supported by public funds ofMexico, its political subdivisions, or local au-thorities.

MoroccoIncome that residents of Morocco receive forperforming personal services as independentcontractors or as self-employed persons (in-dependent personal services) in the UnitedStates during the tax year is exempt from U.S.income tax if the residents:


2) Do not maintain a fixed base in theUnited States for more than 89 daysduring the tax year, and

3) Earn total income for those services thatis not more than $5,000.

If they have a fixed base in the United Statesfor more than 89 days, they are taxed onlyon the income attributable to the fixed base.

Income that residents of Morocco receivefor labor or personal services performed inthe United States as employees (dependentpersonal services) is exempt from U.S. in-come tax if the residents meet three require-ments:

1) They are in the United States for lessthan 183 days during the tax year,

2) They are employees of a resident ofMorocco or of a permanent establish-ment of a resident of a country otherthan Morocco if the permanent estab-lishment is located in Morocco, and


Compensation received for services per-formed by a member of the board of directorsof a corporation does not qualify for this ex-emption.

Income received by an individual for per-forming labor or personal services as an em-ployee aboard a ship or an aircraft operatedin international traffic by a Moroccan residentis exempt from U.S. income tax if the individ-ual is a member of the regular complementof the ship or aircraft.

These exemptions do not apply to incomereceived for services (both independent anddependent personal services) performed inthe United States by professionalentertainers, including theater, film, radio, andtelevision performers, musicians, andathletes, unless the services are performedby, or for the account of, a Moroccan nonprofitorganization.

NetherlandsIncome that residents of the Netherlands re-ceive for performing personal services as in-dependent contractors or self-employed indi-viduals (independent personal services) in theUnited States is exempt from U.S. income taxif the income is not attributable to a fixed basein the United States that is regularly availablefor performing the services.

Income that residents of the Netherlandsreceive for employment in the United States(dependent personal services) is exempt from

U.S. income tax if the following three re-quirements are met:

1) The resident is in the United States forno more than 183 days during the taxyear,


3) The income is not borne by a permanentestablishment or fixed base the em-ployer has in the United States.

Income received by a Netherlands resi-dent for employment as a member of theregular complement of a ship or aircraft op-erated in international traffic is exempt fromU.S. tax.

These exemptions do not apply to direc-tors' fees and other similar payments receivedby a resident of the Netherlands for servicesperformed outside the Netherlands as amember of the board of directors of a com-pany resident in the United States.

These exemptions do not apply to incomeresidents of the Netherlands receive as publicentertainers (such as theater, motion picture,radio, or television artists, or musicians) orathletes if the gross income, including reim-bursed expenses, is more than $10,000.

New ZealandIncome that residents of New Zealand receivefor performing personal services as inde-pendent contractors or self-employed individ-uals (independent personal services) in theUnited States in any tax year is exempt fromU.S. income tax if the residents:

1) Are present in the United States for nomore than 183 days during any consec-utive 12-month period, and



Income that residents of New Zealand re-ceive for labor or personal services performedin the United States as employees (depend-ent personal services) is exempt from U.S.income tax if the residents meet these re-quirements:

1) They are present in the United States forno more than 183 days in any consec-utive 12-month period,

2) Their income is paid by or on behalf ofan employer that is not a resident of theUnited States, and

3) Their income is not borne by a perma-nent establishment or fixed base of theemployer in the United States.

Pay received by a New Zealand residentas an employee and member of the regularcomplement of a ship or aircraft operated ininternational traffic is exempt from U.S. tax.

The exemption from U.S. tax on incomefrom both independent and dependent per-sonal services does not apply to publicentertainers (artists, athletes, etc.) from NewZealand who earn more than $10,000 ingross receipts, including reimbursed ex-penses, from their entertainment activities inthe United States during the tax year.

NorwayIncome that residents of Norway receive forperforming personal services as independentcontractors or self-employed individuals (in-dependent personal services) in the UnitedStates during the tax year is exempt from U.S.income tax if the residents:



If they do not meet requirement (2), they aretaxed only on the income attributable to thefixed base.

This exemption does not apply to resi-dents of Norway who are public entertainers(theater, motion picture, or television artists,musicians, or athletes) if they are in theUnited States for more than 90 days duringthe tax year or their pay for services as publicentertainers is more than $10,000 during thetax year.

Income that residents of Norway receivefor labor or personal services performed inthe United States as employees (dependentpersonal services) is exempt from U.S. in-come tax if the residents meet three require-ments:

1) They are in the United States less than183 days during the tax year,

2) They are employees of a resident ofNorway or of a permanent establishmentof a resident of a state other thanNorway if the permanent establishmentis situated in Norway, and


However, the exemption does not applyto a resident of Norway who performs ser-vices as an employee aboard a ship or anaircraft operated by a United States residentin international traffic or in fishing on the highseas if the resident of Norway is a memberof the regular complement of the ship or air-craft.

PakistanResidents of Pakistan who perform personalservices (including professional services) foror on behalf of a resident of Pakistan while inthe United States for no more than 183 daysduring the tax year are exempt from U.S. in-come tax on the income from the services ifthey are subject to Pakistani tax.

PhilippinesIncome that residents of the Philippines re-ceive for performing personal services as in-dependent contractors or as self-employedindividuals (independent personal services) inthe United States during the tax year is ex-empt from U.S. income tax if the residents:


2) Earn gross income for those servicesthat is not more than $10,000 for the taxyear if the income is from U.S. contrac-tors, and

Page 9

3) Do not have a fixed base regularlyavailable to them in the United States forperforming their services.

If they have a fixed base available in theUnited States, they are taxed only on the in-come attributable to the fixed base. There isno dollar limit for condition (2) if the contractoris a resident of a country other than theUnited States.

Income that residents of the Philippinesreceive for personal services performed in theUnited States as employees (dependent per-sonal services) is exempt from U.S. incometax if the residents meet three requirements:


2) They are employees of a resident of thePhilippines or of a permanent establish-ment maintained in the Philippines, and


Pay received by an employee of a residentof the Philippines for personal services per-formed as a member of the regular comple-ment of a ship or an aircraft operated ininternational traffic by a resident of thePhilippines is exempt.

These exemptions do not apply to incomeresidents of the Philippines receive for per-forming services (both independent and de-pendent personal services) in the UnitedStates as entertainers, such as theater, mo-tion picture, radio, or television artists, musi-cians, or athletes, if the income is more than$100 a day or $3,000 for the tax year. Re-gardless of these limits, income of Philippineentertainers is exempt from U.S. tax if theirvisit to the United States is substantially sup-ported or sponsored by the Philippine Gov-ernment and the entertainers are certified asqualified for this exemption by the Philippinecompetent authority.

PolandIncome that residents of Poland receive forperforming personal services as independentcontractors or self-employed individuals (in-dependent personal services) in the UnitedStates is exempt from U.S. income tax if theyare in the United States for no more than 182days during the tax year.

Income that residents of Poland receivefor labor or personal services performed asemployees (dependent personal services),including services performed by an officer ofa corporation or company, in the UnitedStates during the tax year is exempt from U.S.income tax if the residents meet three re-quirements:


2) Their income is paid by or on behalf ofan employer who is not a U.S. resident,and


Pay received by employees who aremembers of the regular complement of a shipor aircraft operated by a resident of Poland ininternational traffic is exempt.

PortugalIncome that residents of Portugal receive forperforming personal services as independentcontractors or self-employed individuals (in-dependent personal services) in the UnitedStates is exempt from U.S. income tax if theresidents:

1) Are in the United States for no more than182 days in any 12-month period, and

2) Do not have a fixed base regularlyavailable to them in the United States forperforming the activities.


Income that residents of Portugal receivefor employment in the United States (de-pendent personal services) is exempt fromU.S. income tax if the following three re-quirements are met:




Income received by a resident of Portugalfor employment as a member of the regularcomplement of a ship or aircraft operated ininternational traffic is exempt from U.S. tax.

These exemptions do not apply to incomeresidents of Portugal receive as publicentertainers (such as theater, motion picture,radio, or television artists, or musicians) orathletes if that income, including reimbursedexpenses, is more than $10,000. The incomeof Portuguese entertainers and athletes isexempt from U.S. tax if their visit to the UnitedStates is substantially supported by publicfunds of Portugal or its political or adminis-trative subdivisions.

These exemptions do not apply to direc-tors' fees and similar payments received bya resident of Portugal for services performedoutside of Portugal as a member of the boardof directors of a company that is a residentof the United States.

RomaniaIncome that residents of Romania receive forperforming personal services as independentcontractors or self-employed individuals (in-dependent personal services) in the UnitedStates during the tax year is exempt from U.S.income tax if the residents:


2) Do not maintain a permanent establish-ment in the United States with which theincome is effectively connected.

Income that residents of Romania receivefor labor or personal services performed asemployees (dependent personal services),including services performed by an officer ofa corporation or company, in the UnitedStates during the tax year is exempt from U.S.income tax if the residents meet these re-quirements:


2) They are employees of a resident ofRomania or of a permanent establish-ment maintained in Romania by a resi-dent of the United States, and


These exemptions do not apply toentertainers, such as theater, motion picture,radio, or television artists, musicians, orathletes, who are present in the United Statesfor more than 90 days during the tax year (90days or more if the entertainers are employ-ees) or who earn gross income asentertainers in the United States of more than$3,000 during the tax year ($3,000 or more ifthey are employees). However, the ex-emptions do apply, without regard to the 90day, $3,000 requirement, if the entertainersare present in the United States by specificarrangements between the United States andRomania.

Pay received by employees who aremembers of the regular complement of a shipor aircraft operated by a resident of Romaniain international traffic is exempt.

RussiaIncome that residents of Russia receive forperforming personal services as independentcontractors or self-employed individuals (in-dependent personal services) in the UnitedStates is exempt from U.S. income tax if:

1) The residents are in the United States forno more than 183 days during the cal-endar year, or

2) The income is not attributable to a fixedbase in the United States which is regu-larly available to the residents.

If the residents have a fixed base available,they are taxed only on the income attributableto the fixed base.

Income that residents of Russia receivefor employment in the United States (de-pendent personal services) is exempt fromU.S. income tax if the following three re-quirements are met:

1) The resident is in the United States forno more than 183 days during the cal-endar year,



However, income from employment directlyconnected with a place of business that is nota permanent establishment is exempt if theresident is present in the United States notlonger than 12 consecutive months. For thispurpose, a place of business means a con-struction site, assembly or installation project,or drilling operation.

Income from employment as a memberof the regular complement of a ship or aircraftoperated in international traffic is exempt fromU.S. tax.

Income from technical services directlyconnected with the application of a right orproperty giving rise to a royalty is exempt if

Page 10

those services are provided as part of a con-tract granting the use of the right or property.

These exemptions do not apply to direc-tors' fees and similar payments received bya resident of Russia as a member of theboard of directors or similar body of a com-pany that is a U.S. resident.

Slovak RepublicIncome that residents of the Slovak Republicreceive for performing personal services asindependent contractors or self-employed in-dividuals (independent personal services) inthe United States is exempt from U.S. incometax if the residents:

1) Are present in the United States for nomore than 183 days in any 12-monthperiod, and

2) Do not have a fixed base regularlyavailable to them in the United States forperforming the activities.


Income that residents of the Slovak Re-public receive for employment in the UnitedStates (dependent personal services) is ex-empt from U.S. income tax if the followingthree requirements are met:

1) The resident is present in the UnitedStates for no more than 183 days in any12-month period,



These exemptions do not apply to incomeresidents of the Slovak Republic receive aspublic entertainers (such as theater, motionpicture, radio, or television artists, or musi-cians) or sportsmen if their gross receipts,including reimbursed expenses, are morethan $20,000 during the tax year. Regardlessof these limits, income of Slovak entertainersand sportsmen is exempt from U.S. incometax if their visit to the United States is sub-stantially supported by public funds of theSlovak Republic, its political subdivisions, orlocal authorities, or the visit is made pursuantto a specific arrangement between the UnitedStates and the Slovak Republic.

These exemptions do not apply to direc-tors' fees and similar payments received bya resident of the Slovak Republic for servicesperformed in the United States as a memberof the board of directors of a company that isa resident of the United States.

Income from employment as a memberof the regular complement of a ship or aircraftoperated by a Slovak enterprise in interna-tional traffic is exempt from U.S. income tax.

South AfricaIncome that residents of South Africa receivefor performing personal services as inde-pendent contractors or self-employed individ-uals (independent personal services) in theUnited States is exempt from U.S. income taxif the residents:




Income that residents of South Africa re-ceive for services performed in the UnitedStates as employees (dependent personalservices) is exempt from U.S. income tax ifthe following requirements are met:




These exemptions do not apply to direc-tors' fees and similar payments received bya resident of South Africa for services per-formed in the United States as a member ofthe board of directors of a company residentin the United States.

These exemptions do not apply to incomeresidents of South Africa receive as publicentertainers (such as theater, motion picture,radio or television artists, or musicians) orathletes if their gross receipts, including re-imbursed expenses, are more than $7,500during the tax year. Regardless of these lim-its, income of South African entertainers orathletes is exempt from U.S. income tax iftheir visit to the United States is wholly ormainly supported by public funds of SouthAfrica, its political subdivisions, or local au-thorities.

Income received by a resident of SouthAfrica for services performed as an employeeand member of the complement of a ship oraircraft operated in international traffic is ex-empt from U.S. income tax.

SpainIncome that residents of Spain receive as in-dependent contractors or self-employed indi-viduals (independent personal services) in theUnited States is exempt from U.S. income taxif the residents do not have a fixed baseavailable to them in the United States forperforming the services. If they have a fixedbase, they are taxed only on the income at-tributable to the fixed base.

Income that residents of Spain receive forpersonal services performed in the UnitedStates as employees (dependent personalservices) is exempt from U.S. income tax if:

1) The residents are present in the UnitedStates no more than 183 days in any12-month period,


3) The income is not borne by a permanentestablishment or fixed base the em-ployer has in the United States.

Pay received by employees who aremembers of a regular complement of a shipor aircraft operated in international traffic bya Spanish enterprise may be taxed by Spain.

These exemptions do not apply to publicentertainers (such as theater, motion picture,radio, or television artists, or musicians) orathletes from Spain who earn more than$10,000 in income, including reimbursed ex-penses, from their entertainment activities inthe United States during the tax year. Re-gardless of these limits, Spanish entertainersand athletes are exempt from U.S. tax if theirvisit to the United States is substantially sup-ported by public funds of Spain, a politicalsubdivision, or local authority.

SwedenIncome that residents of Sweden receive forperforming personal services as independentcontractors or self-employed individuals (in-dependent personal services) in the UnitedStates during the tax year is exempt from U.S.income tax if they do not have a fixed baseregularly available to them in the UnitedStates for performing the services. If theyhave a fixed base available in the UnitedStates, they are taxed on the income attrib-utable to the fixed base.

Income that residents of Sweden receivefor labor or personal services performed inthe United States as employees (dependentpersonal services) is exempt from U.S. in-come tax if the residents meet three require-ments:

1) They are in the United States for nomore than 183 days during any consec-utive 12-month period,



Income received by a resident of Swedenfor employment as a member of the regularcomplement of a ship or aircraft operated ininternational traffic is exempt from U.S. tax.

These exemptions do not apply to incomeresidents of Sweden receive as publicentertainers (such as theater, motion picture,radio, or television artists, or musicians) orathletes if the gross income, including reim-bursed expenses, is more than $6,000 for any12-month period.

These exemptions do not apply to direc-tors' fees received by a resident of Swedenfor services performed outside of Sweden asa member of the board of directors of acompany that is a resident of the UnitedStates.

SwitzerlandIncome that residents of Switzerland receivefor personal services as independent con-tractors or self-employed individuals (inde-pendent personal services) that they performduring the tax year in the United States isexempt from U.S. income tax if they do nothave a fixed base regularly available to themin the United States for performing the ser-vices. If they have a fixed base available inthe United States, they are taxed on the in-come attributable to the fixed base.

Income that residents of Switzerland re-ceive for services performed in the UnitedStates as employees (dependent personalservices) is exempt from U.S. income tax ifthe residents meet the following require-ments:

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These exemptions do not apply to direc-tors' fees and similar payments received bya resident of Switzerland for services per-formed in the United States as a member ofthe board of directors of a company residentin the United States.

These exemptions do not apply to publicentertainers (such as theater, motion picture,radio, or television entertainers, musiciansand athletes) from Switzerland who earnmore than $10,000 in gross receipts, includ-ing reimbursed expenses, from their enter-tainment activities in the United States duringthe tax year.

Income received by a resident ofSwitzerland for services performed as anemployee and member of the regular com-plement of a ship or aircraft operated ininternational traffic is exempt from U.S. in-come tax.

ThailandIncome that residents of Thailand receive forperforming personal services as independentcontractors or as self-employed individuals(independent personal services) in the UnitedStates during the tax year is exempt from U.S.income tax if the residents:


2) Do not have a fixed base regularlyavailable to them in the United States forperforming their services.

If they have a fixed base available in theUnited States, they are taxed only on the in-come attributable to the fixed base.

This exemption does not apply if a resi-dent of Thailand earns more than $10,000 forindependent personal services and that in-come is paid by a U.S. resident or borne bya permanent establishment or fixed base inthe United States.

Income that residents of Thailand receivefor services performed in the United Statesas employees (dependent personal services)is exempt from U.S. income tax if the follow-ing requirements are met:




These exemptions do not apply to direc-tors' fees and similar payments received bya resident of Thailand for services performedoutside of Thailand as a member of the boardof directors of a company that is a residentof the United States.

These exemptions do not apply to incomeresidents of Thailand receive for performingservices in the United States as entertainers(such as theater, motion picture, radio, ortelevision artists, musicians) and athletes, ifthe income is more than $100 a day or $3,000for the tax year. Regardless of these limits,income of Thai entertainers is exempt fromU.S. tax if their visit to the United States issubstantially supported by public funds ofThailand or its poilitical subdivisions or localauthorities.

Pay received by employees of a ship oraircraft operated in international traffic by aThai enterprise may be taxed by Thailand.

Trinidad and TobagoIncome (including reimbursed travel ex-penses) that residents of Trinidad andTobago receive during the tax year for per-sonal services performed in the United Statesis exempt from U.S. income tax if the indi-viduals are in the United States for no morethan 183 days during the tax year and either:

1) The residents are employees of a resi-dent of a country other than the UnitedStates or are employees of a permanentestablishment of a U.S. resident outsidethe United States and the income is notdeducted in figuring the profits of a per-manent establishment in the UnitedStates, or

2) The income is not more than $3,000(excluding reimbursed travel expenses).

These exemptions do not apply to theprofessional earnings of public entertainerssuch as actors, musicians, and professionalathletes or to any person providing their ser-vices if the pay is more than $100 per day(excluding reimbursed travel expenses).

Pay received by members of the regularcomplement of a ship or aircraft operated ininternational traffic by a resident of Trinidadand Tobago is exempt from U.S. tax.

TunisiaIncome that residents of Tunisia receive forperforming personal services as independentcontractors or self-employed individuals (in-dependent personal services) in the UnitedStates are exempt from U.S. income tax if:


2) They do not have a fixed base regularlyavailable in the United States for per-forming the services, and

3) The gross income for the tax year fromU.S. residents for services performed inthe United States is no more than$7,500.

If they do not meet condition (2), they aretaxed on the income that is attributable to thefixed base.

Income that residents of Tunisia receivefor personal services performed in the UnitedStates as employees (dependent personalservices) is exempt from U.S. income tax if:

1) The residents are in the U.S. for no morethan 183 days during the tax year,


3) Their income is not borne by a perma-nent establishment or fixed base theemployer has in the United States.

Pay received by employees who aremembers of the regular complement of a shipor aircraft operated by an enterprise in inter-national traffic is exempt from U.S. tax if theplace of management of the enterprise is inTunisia.

These exemptions do not apply to incomeresidents of Tunisia receive as publicentertainers (such as theater, motion picture,radio, or television artists and musicians) orathletes if their gross receipts, including re-imbursed expenses, are more than $7,500during the tax year.

These exemptions do not apply to feesreceived by a resident of Tunisia for servicesperformed as a director of a U.S. corporationif the fees are treated as a distribution ofprofits and cannot be taken as a deductionby the corporation.

TurkeyIncome that residents of Turkey receive forperforming personal services as independentcontractors or self-employed individuals (in-dependent personal services) in the UnitedStates is exempt from U.S. income tax if theresidents:

1) Are in the United States for purposes ofperforming the services or activities forno more than 183 days in any 12-monthperiod, and



Income that residents of Turkey receivefor services performed in the United Statesas employees (dependent personal services)is exempt from U.S. income tax if the follow-ing requirements are met:




These exemptions do not apply to direc-tors' fees and similar payments received bya resident of Turkey for services provided inthe United States as a member of the boardof directors of a company that is a residentof the United States.

These exemptions do not apply to incomeresidents of Turkey receive as publicentertainers (such as theater, motion picture,radio, or television artists, or musicians) orathletes if their gross receipts are more than$3,000 during the tax year for their enter-tainment activities in the United States. If theirvisit to the United States is substantially sup-ported by a Turkish non-profit organizationor from the public funds of Turkey, its politicalsubdivisions, or local authorities, the incomeis taxed as independent personal services ordependent personal services.

These exemptions do not apply to a resi-dent of Turkey who performs services as a

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member of the regular complement of a shipor an aircraft operated by a United Statesresident in international traffic.

United KingdomIncome that residents of the United Kingdomreceive for performing personal services asindependent contractors or self-employed in-dividuals (independent personal services) inthe United States during the tax year is ex-empt from U.S. tax if the residents:


2) Do not have a fixed base regularlyavailable in the United States.

Income that residents of the UnitedKingdom receive for labor or personal ser-vices performed in the United States as em-ployees (dependent personal services) is ex-empt from U.S. tax if the employees meetthree requirements:

1) They are in the United States for nomore than 183 days,

2) Their income is paid by or on behalf ofan employer who is not a resident of theUnited States, and


Income for services performed by an em-ployee and member of the regular comple-ment of a ship or aircraft operated in interna-tional traffic is taxed by the country of whichthe employer operating the ship or aircraft isa resident.

These exemptions do not apply to incomereceived for services performed in the UnitedStates as an entertainer, musician, or athleteif the income, including reimbursed expenses,is more than $15,000 in any tax year.

VenezuelaIncome that residents of Venezuela receivefor personal services as independent con-tractors or self-employed individuals (inde-pendent personal services) in the UnitedStates is exempt from U.S. income tax if theydo not have a fixed base regularly availableto them in the United States for performingthe services. If they have a fixed base avail-able, they are taxed on the income attribut-able to the fixed base.

Income that residents of Venezuela re-ceive for services performed in the UnitedStates as employees (dependent personalservices) is exempt from U.S. income tax ifthe residents meet the following require-ments:




These exemptions do not apply to direc-tors' fees and similar payments received bya resident of Venezuela for services per-formed in the United States as a member of

the board of directors of a company residentin the United States.

Pay received by a resident of Venezuelafor services performed as an employee of aship or an aircraft operated in internationaltraffic is exempt from U.S. income tax.

These exemptions do not apply to incomeresidents of Venezuela receive as publicentertainers (such as theater, motion picture,radio, or television artists, or musicians) orsportsmen if their gross income, including re-imbursed expenses, is more than $6,000 fortheir personal activities in the United Statesduring the tax year. Regardless of these lim-its, income of Venezuelan entertainers orathletes is exempt from U.S. income tax iftheir visit to the United States is wholly ormainly supported by public funds ofVenezuela, its political subdivisions, or localauthorities.

Professors, Teachers,and ResearchersPay of professors and teachers who are res-idents of the following countries is generallyexempt from U.S. income tax for 2 or 3 yearsif they temporarily visit the United States toteach or do research. The exemption appliesto pay earned by the visiting professor orteacher during the applicable period. For mostof the following countries, the applicable pe-riod begins on the date of arrival in the UnitedStates for the purpose of teaching or engag-ing in research. Furthermore, for most of thefollowing countries, the exemption applieseven if the stay in the United States extendsbeyond the applicable period.

The exemption generally applies to payreceived during a second teaching assign-ment if both are completed within the speci-fied time, even if the second assignment wasnot arranged until after arrival in the UnitedStates on the first assignment. For each of thecountries listed, the conditions are stated un-der which the pay of a professor or teacherfrom that country is exempt from U.S. incometax.

If you do not meet the requirements forexemption as a teacher or if you are a resi-dent of a treaty country that does not have aspecial provision for teachers, you may qual-ify under a personal services income pro-vision discussed earlier.

AustriaThere is no special provision for professorsor teachers.

Former treaty. For 1999, you can elect toapply the old treaty in its entirety. The pro-vision for teaching is as follows.

A professor or teacher who is a residentof Austria and temporarily visits the UnitedStates to teach at a university, college,school, or other educational institution for notlonger than 2 years is exempt from U.S. in-come tax on the income for teaching duringthat period.

BelgiumAn individual who is a resident of Belgium onthe date of arrival in the United States andwho is temporarily in the United States at theinvitation of the U.S. Government, a univer-sity, or other recognized educational institu-tion in the United States primarily to teach orengage in research, or both, at a universityor other accredited educational institution is

exempt from U.S. income tax on income forthe teaching or research for a maximum of 2years from the date of arrival in the UnitedStates.

This exemption does not apply to incomefrom research carried on mainly for the pri-vate benefit of any person rather than in thepublic interest.

China, People's Republic ofAn individual who is a resident of the People'sRepublic of China and who is temporarily inthe United States primarily to teach, lecture,or conduct research at a university or otheraccredited educational institution or scientificresearch institution is exempt from U.S. in-come tax on income for the teaching, lectur-ing, or research for a total of not more than3 years.


Commonwealth ofIndependent StatesAn individual who is a resident of a C.I.S.member on the date of arrival in the UnitedStates and who is temporarily in the UnitedStates at the invitation of the U.S. Govern-ment or an educational or scientific researchinstitution in the United States primarily toteach, engage in research, or participate inscientific, technical, or professional confer-ences is exempt from U.S. income tax on in-come for teaching, research, or participationin these conferences for a maximum periodof 2 years.

This exemption does not apply to incomefrom research carried on mainly for the ben-efit of a private person, including a commer-cial enterprise of the United States or a for-eign trade organization of a C.I.S. member.

The exemption does, however, apply if theresearch is conducted through an intergov-ernmental agreement on cooperation.

This exemption also applies to journalistsand correspondents who are temporarily inthe United States for periods not longer than2 years and who receive their compensationfrom abroad. It is not necessary that thejournalists or correspondents be invited by theU.S. Government or other appropriate insti-tution, nor does it matter that they are em-ployed by a private person, including com-mercial enterprises and foreign tradeorganizations.

Czech RepublicAn individual is exempt from U.S. income taxon income for teaching or research for up to2 years if he or she:

1) Is a resident of the Czech Republic im-mediately before visiting the UnitedStates, and

2) Is in the United States primarily to teachor conduct research at a university, col-lege, school, or other accredited educa-tional or research institution.

A Czech resident is entitled to these ben-efits only once. However, the exemptiondoes not apply if:

1) The resident claimed during the imme-diate preceding period the benefits de-scribed later under Students and Ap-prentices, or

Page 13

2) The income is from research undertakenprimarily for the private benefit of a spe-cific person or persons.

DenmarkA professor or teacher who is a resident ofDenmark and temporarily visits the UnitedStates to teach at a university, college,school, or other educational institution for aperiod not longer than 2 years is exempt fromU.S. income tax on income for teaching dur-ing that period.

EgyptAn individual who is a resident of Egypt on thedate of arrival in the United States and whois temporarily in the United States primarilyto teach or engage in research, or both, at auniversity or other recognized educational in-stitution is exempt from U.S. income tax onincome from the teaching or research for amaximum of 2 years from the date of arrivalin the United States. The individual must havebeen invited to the United States for a periodnot expected to be longer than 2 years by theU.S. government or a state or local govern-ment, or by a university or other recognizededucational institution in the United States.


FranceAn individual who is a resident of France onthe date of arrival in the United States andwho is temporarily in the United States at theinvitation of the U.S. Government, a univer-sity, or other recognized educational or re-search institution in the United States prima-rily to teach or engage in research, or both,at a university or other educational or re-search institution is exempt from U.S. incometax on income from teaching or research fora maximum of 2 years from the date of arrivalin the United States.

An individual may claim this benefit onlyonce. Also, this benefit and the benefits de-scribed later under Students and Apprentices,can be claimed for no more than 5 years.


GermanyA professor or teacher who is a resident ofGermany and who is in the United States fornot more than 2 years to engage in advancedstudy or research or teaching at an accreditededucational institution or institution engagedin research for the public benefit is exemptfrom U.S. tax on income received for suchstudy, research, or teaching. If the individual'svisit to the United States exceeds 2 years, theexemption is lost for the entire visit unless thecompetent authorities of Germany and theUnited States agree otherwise.

The exemption does not apply to incomefrom research carried on mainly for the pri-vate benefit of any person rather than in thepublic interest.

GreeceA professor or teacher who is a resident ofGreece and who is temporarily in the UnitedStates to teach at a university, college, orother educational institution for a maximum

of 3 years is exempt from U.S. income tax onthe income received for teaching during thatperiod.

HungaryAn individual who is a resident of Hungary onthe date of arrival in the United States andwho is temporarily in the United States pri-marily to teach or engage in research, or both,at a university or other recognized educa-tional institution is exempt from U.S. incometax on income for the teaching or research fora maximum of 2 years from the date of arrivalin the United States. The individual must havebeen invited to the United States for a periodnot expected to be longer than 2 years by theU.S. Government or a state or local govern-ment, or by a university or other recognizededucational institution in the United States.


IcelandAn individual who is a resident of Iceland onthe date of arrival in the United States andwho is temporarily in the United States at theinvitation of the U.S. Government, a univer-sity, or other recognized educational institu-tion in the United States primarily to teach orengage in research, or both, at a universityor other educational institution is exempt fromU.S. income tax on income for the teachingor research for a maximum of 2 years fromthe date of arrival in the United States.


IndiaAn individual is exempt from U.S. tax on in-come received for teaching or research if heor she:

1) Is a resident of India immediately beforevisiting the United States, and

2) Is in the United States to teach or en-gage in research at an accredited uni-versity or other recognized educationalinstitution in the United States for a pe-riod not longer than 2 years.

If the individual's visit to the United Statesexceeds 2 years, the exemption is lost for theentire visit.


IndonesiaAn individual is exempt from U.S. tax on in-come for teaching or research for a maximumof 2 years from the date of arrival in theUnited States if he or she:

1) Is a resident of Indonesia immediatelybefore visiting the United States, and

2) Is in the United States at the invitationof a university, school, or other recog-nized educational institution to teach orengage in research, or both, at that ed-ucational institution.

A resident of Indonesia is entitled to thisexemption only once. But this exemption doesnot apply to income from research carried onmainly for the private benefit of any person.

IsraelAn individual who is a resident of Israel on thedate of arrival in the United States and whois temporarily in the United States primarilyto teach or engage in research, or both, at auniversity or other recognized educational in-stitution is exempt from U.S. income tax onincome from the teaching or research for amaximum of 2 years from the date of arrivalin the United States. The individual must havebeen invited to the United States for a periodnot expected to be longer than 2 years by theU.S. Government or a state or local govern-ment, or by a university or other recognizededucational institution in the United States.

This exemption does not apply to incomefrom research carried on mainly for the pri-vate benefit of any person rather than in thepublic interest. The exemption does not applyif, during the immediately preceding period,the benefits described in Article 24(1) of thetreaty, pertaining to students, were claimed.

ItalyA professor or teacher who is a resident ofItaly on the date of arrival in the United Statesand who temporarily visits the United Statesto teach or conduct research at a university,college, school, or other educational institu-tion, or at a medical facility primarily fundedfrom government sources, is exempt fromU.S. income tax for up to 2 years on pay fromthis teaching or research.


JamaicaAn individual who is a resident of Jamaica onthe date of arrival in the United States andwho temporarily visits the United States toteach or engage in research at a university,college, or other recognized educational in-stitution is exempt from U.S. income tax onthe income received for the teaching or re-search for not more than 2 years from thedate of arrival in the United States. A residentof Jamaica is entitled to this exemption onlyonce.


JapanAn individual who is a resident of Japan onthe date of arrival in the United States andwho is temporarily in the United States at theinvitation of the U.S. Government, a univer-sity, or other accredited educational institutionlocated in the United States primarily to teachor engage in research, or both, at a universityor other educational institution is exempt fromU.S. income tax on income for the teachingor research for a maximum of 2 years fromthe date of arrival in the United States.


Page 14

Korea, Republic ofAn individual who is a resident of the Republicof Korea on the date of arrival in the UnitedStates and who is temporarily in the UnitedStates primarily to teach or engage in re-search, or both, at a university or other rec-ognized educational institution is exempt fromU.S. income tax on income for the teachingor research for a maximum of 2 years fromthe date of arrival in the United States. Theindividual must have been invited to theUnited States for a period not expected to belonger than 2 years by the U.S. Governmentor a state or local government, or by a uni-versity or other recognized educational insti-tution in the United States.


LuxembourgA resident of Luxembourg who is temporarilyin the United States at the invitation of a U.S.university, college, school, or other recog-nized educational institution only to teach orengage in research, or both, at that educa-tional institution is exempt from U.S. incometax on income for the teaching or research fornot more than 2 years from the date of arrivalin the United States.

This exemption does not apply to pay forresearch carried on for the benefit of anyperson other than the educational institutionthat extended the invitation.

NetherlandsAn individual is exempt from U.S. income taxon income received for teaching or researchfor a maximum of 2 years from the date ofarrival if he or she:

1) Is a resident of the Netherlands imme-diately before visiting the United States,and

2) Is in the United States to teach or en-gage in research at a university, college,or other recognized educational institu-tion for not more than 2 years.

If the individual's visit to the United Statesis longer than 2 years, the exemption is lostfor the entire visit unless the competent au-thorities of the Netherlands and the UnitedStates agree otherwise.

The exemption does not apply to incomefrom research carried on primarily for the pri-vate benefit of any person rather than in thepublic interest. Nor does the exemption applyif the resident claimed during the immediatepreceding period the benefits described laterunder Students and Apprentices.

NorwayAn individual who is a resident of Norway onthe date of arrival in the United States andwho is temporarily in the United States at theinvitation of the U.S. Government, a univer-sity, or other recognized educational institu-tion in the United States primarily to teach orengage in research, or both, at a universityor other recognized educational institution isexempt from U.S. income tax on income forthe teaching or research for a maximum pe-riod of 2 years from the date of arrival in theUnited States.


PakistanA professor or teacher who is a resident ofPakistan and who temporarily visits theUnited States to teach at a university, college,school, or other educational institution for notlonger than 2 years is exempt from U.S. in-come tax on the income received for teachingfor that period.

PhilippinesAn individual who is a resident of thePhilippines on the date of arrival in the UnitedStates and who is temporarily in the UnitedStates primarily to teach or engage in re-search, or both, at a university or other rec-ognized educational institution is exempt fromU.S. income tax on income from the teachingor research for not more than 2 years from thedate of arrival in the United States. The indi-vidual must have been invited to the UnitedStates for a period not expected to be longerthan 2 years by the U.S. Government or astate or local government, or by a universityor other recognized educational institution inthe United States.


PolandAn individual who is a resident of Poland onthe date of arrival in the United States andwho is temporarily in the United States at theinvitation of the U.S. Government, a univer-sity, or other recognized educational institu-tion in the United States primarily to teach orengage in research, or both, at a universityor other recognized educational institution isexempt from U.S. income tax on income forthe teaching or research for a maximum of 2years from the date of arrival in the UnitedStates.


PortugalAn individual who is a resident of Portugal onthe date of arrival in the United States andwho is temporarily in the United States at theinvitation of the U.S. Government, a univer-sity, other accredited educational institution,or recognized research institution in theUnited States, or under an official culturalexchange program, only to teach or engagein research, or both, at a university or edu-cational institution is exempt from U.S. in-come tax on income from teaching or re-search for a maximum of 2 years from thedate of arrival in the United States. An indi-vidual is entitled to these benefits only once.However, these benefits, and the benefitsdescribed later under Students and Appren-tices cannot be claimed either simultaneouslyor consecutively.


RomaniaAn individual who is a resident of Romaniaon the date of arrival in the United States andwho is temporarily in the United States at theinvitation of the U.S. Government, a univer-sity, or other recognized educational institu-tion in the United States primarily to teach orengage in research, or both, at a universityor other recognized educational institution isexempt from U.S. income tax on income forthe teaching or research for a maximum of 2years from the date of arrival in the UnitedStates.


Slovak RepublicAn individual is exempt from U.S. income taxon income for teaching or research for up to2 years if he or she:

1) Is a resident of the Slovak Republic im-mediately before visiting the UnitedStates, and

2) Is in the United States primarily to teachor conduct research at a university, col-lege, school, or other accredited educa-tional or research institution.

A Slovak resident is entitled to thesebenefits only once. However, the exemptiondoes not apply if:

1) The resident claimed during the imme-diate preceding period the benefits de-scribed later under Students and Ap-prentices, or

2) The income is from research undertakenprimarily for the private benefit of a spe-cific person or persons.

ThailandAn individual who is a resident of Thailandon the date of arrival in the United States andwho is in the United States for not longer than2 years primarily to teach or engage in re-search at a university, college, school, orother recognized educational institution isexempt from U.S. income tax on income forthe teaching or research. The exemptionfrom tax applies only if the visit does not ex-ceed two years from the date the individualfirst visits the United States for the purposeof engaging in teaching or research.

This exemption does not apply to incomefrom research carried on mainly for the pri-vate benefit of any person rather than in thepublic interest. This exemption does not applyif, during the immediately preceding period,the benefits described in treaty Article 22(1),pertaining to students, were claimed.

Trinidad and TobagoAn individual who is a resident of Trinidad andTobago on the date of arrival in the UnitedStates and who is temporarily in the UnitedStates at the invitation of the U.S. Govern-ment, a university, or other accredited edu-cational institution in the United States pri-marily to teach or engage in research, or both,at a university or other accredited educationalinstitution is exempt from U.S. income tax onthe income received for the teaching or re-search for a maximum of 2 years from thedate of arrival in the United States.

Page 15

This exemption does not apply to incomefrom research carried on mainly for the pri-vate benefit of any person rather than in thepublic interest. Nor does the exemption applyto income if an agreement exists between theGovernments of Trinidad and Tobago and theUnited States for providing the services ofthese individuals.

TurkeyAn individual who was a resident of Turkeyimmediately before visiting the United Stateswho is in the United States for not longer than2 years for the purpose of teaching or en-gaging in scientific research is exempt fromU.S. income tax on payments received fromoutside the United States for teaching or re-search.

United KingdomA professor or teacher who is a resident of theUnited Kingdom on the date of arrival in theUnited States and who is in the United Statesfor not longer than 2 years primarily to teachor engage in research at a university, college,or other recognized educational institution isexempt from U.S. income tax on income forthe teaching or research. If the individual's2-year period is exceeded, the exemption islost for the entire visit, including the 2-yearperiod.


VenezuelaAn individual who is a resident of Venezuelaon the date of arrival in the United States andwho temporarily visits the United States toteach or engage in research at a recognizededucational or research institution is exemptfrom U.S. income tax on the income receivedfor the teaching or research for not more than2 years from the date of arrival in the UnitedStates. This benefit can be claimed for nomore than 5 years.


Students and ApprenticesResidents of the following countries who arein the United States to study or acquire tech-nical experience are exempt from U.S. in-come tax, under certain conditions, onamounts received from abroad for theirmaintenance and studies.

This exemption does not apply to the sal-ary paid by a foreign corporation to one of itsexecutives, a citizen and resident of a foreigncountry who is temporarily in the UnitedStates to study a particular industry for anemployer. That amount is a continuation ofsalary and is not received to study or acquireexperience.

For each country listed there is a state-ment of the conditions under which the ex-emption applies to students and apprenticesfrom that country.

Amounts received from the National Insti-tutes of Health (NIH) under provisions of theVisiting Fellows Program are generallytreated as a grant, allowance, or award forpurposes of whether an exemption is pro-vided by treaty. Amounts received from NIH

under the Visiting Associate Program andVisiting Scientist Program are not exemptfrom U.S. tax as a grant, allowance, or award.

AustraliaA resident of Australia or an individual whowas a resident of Australia immediately be-fore visiting the United States who is tempo-rarily here for full-time education is exemptfrom U.S. income tax on payments receivedfrom outside the United States for the indi-vidual's maintenance or education.

AustriaA student, apprentice, or business traineewho is a resident of Austria immediately be-fore visiting the United States and is in theUnited States for the purpose of full-time ed-ucation at a recognized educational institutionor full-time training is exempt from U.S. in-come tax on amounts received from sourcesoutside the United States for the individual'smaintenance, education, or training.

Apprentices and business trainees areentitled to the benefit of this exemption for amaximum period of 3 years.

Former treaty. For 1999, you can elect toapply the old treaty in its entirety. The pro-visions for students and apprentices are asfollows.

A resident of Austria who is temporarily inthe United States only as a student at a uni-versity, college, school, or other educationalinstitution is exempt from U.S. income tax onamounts received from abroad for study andmaintenance. An apprentice (includingVolontaere and Praktikanten) who is a resi-dent of Austria and is temporarily in theUnited States only to acquire business ortechnical experience is also exempt from U.S.income tax on amounts received from abroadfor study and maintenance.

A resident of Austria who receives a grant,allowance, or award from a nonprofit reli-gious, scientific, literary, or educational or-ganization is exempt from U.S. income taxon the payments from that organization. Payfor personal services is not exempt.

A resident of Austria who is an employeeof an Austrian enterprise, or an organizationof the kind mentioned in the preceding para-graph, is exempt from U.S. income tax on payfrom abroad paid by that enterprise or or-ganization if:

1) The individual is temporarily in theUnited States for no more than one yearonly to acquire technical, professional,or business experience from any personother than the enterprise or organizationby which employed, and

2) The annual income for services, wher-ever performed, is not more than$10,000.

BarbadosA student or business apprentice who is aresident of Barbados on the date of arrival inthe United States and is here for full-timeeducation or training is exempt from U.S. in-come tax on payments received from outsidethe United States for the individual's mainte-nance, education, or training.

Nevertheless, an individual who qualifiesfor this exemption may instead choose to betreated as a resident alien of the UnitedStates for all U.S. income tax purposes. Once

made, this choice applies for the entire periodthat the individual remains qualified for ex-emption and may not be revoked without thepermission of the U.S. competent authority.

BelgiumAn individual who is a resident of Belgium onthe date of arrival in the United States andwho is temporarily in the United States pri-marily to study at a university or other recog-nized educational institution in the UnitedStates, obtain professional training, or studyor do research as a recipient of a grant, al-lowance, or award from a governmental, reli-gious, charitable, scientific, literary, or edu-cational organization is exempt from U.S.income tax on the following amounts:

1) Gifts from abroad for maintenance, edu-cation, study, research, or training,

2) The grant, allowance, or award, and

3) Income from personal services per-formed in the United States of up to$2,000 for each tax year.

An individual is entitled to the benefit ofthis exemption for a maximum of 5 years.

An individual who is a resident of Belgiumon the date of arrival in the United States andwho is in the United States as an employeeof, or under contract with, a resident ofBelgium is exempt from U.S. income tax fora period of 12 consecutive months on up to$5,000 received for personal services if theindividual is in the United States primarily to:

1) Acquire technical, professional, or busi-ness experience from a person otherthan that resident of Belgium or otherthan a person related to that resident,or

2) Study at an educational institution.

An individual who is a resident of Belgiumon the date of arrival in the United States andwho is temporarily present in the UnitedStates for not longer than one year as a par-ticipant in a program sponsored by the U.S.Government primarily to train, research, orstudy is exempt from U.S. income tax on in-come received for personal services for thetraining, research, or study in the amount of$10,000.

CanadaA full-time student, trainee, or business ap-prentice who is or was a Canadian residentimmediately before visiting the United Statesis exempt from U.S. income tax on amountsreceived from sources outside the UnitedStates for maintenance, education, or train-ing.

Also see Publication 597, Information onthe United States—Canada Income TaxTreaty.

China, People's Republic ofA student, business apprentice, or traineewho is a resident of the People's Republic ofChina on the date of arrival in the UnitedStates and who is present in the UnitedStates solely to obtain training, education, orspecial technical experience is exempt fromU.S. income tax on the following amounts:

1) Payments received from abroad formaintenance, education, study, re-search, or training,

Page 16

2) Grants or awards from a government,scientific, educational, or other tax-exempt organization, and


An individual is entitled to this exemptiononly for the time reasonably necessary tocomplete the education or training.

Commonwealth ofIndependent StatesAn individual who is a resident of a C.I.S.member and who is temporarily in the UnitedStates primarily to study at an educational orscientific research institution or to obtaintraining for qualification in a profession orspecialty is exempt from U.S. income tax onamounts received as stipends, scholarships,or other substitute allowances necessary toprovide ordinary living expenses. An individ-ual is entitled to the benefit of this exemptionfor 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 UnitedStates primarily to acquire technical, profes-sional, or commercial experience or performtechnical services and who is an employeeof, or under contract with, a resident of aC.I.S. member is exempt from U.S. incometax on the amounts received from that resi-dent. Also exempt is an amount received fromU.S. sources, of not more than $10,000, thatis necessary to provide for ordinary living ex-penses. The exemption contained in thisparagraph is limited to one year.

An individual who is a resident of a C.I.S.member and who is temporarily present in theUnited States under an exchange programprovided for by an agreement between gov-ernments on cooperation in various fields ofscience and technology is exempt from U.S.income tax on all income received in con-nection with the exchange program for a pe-riod not longer than one year.

CyprusAn individual who is a resident of Cyprus onthe date of arrival in the United States andwho is temporarily here primarily to study ata university or other recognized educationalinstitution in the United States, obtain profes-sional training, or study or do research as arecipient of a grant, allowance, or award froma governmental, religious, charitable, scien-tific, literary, or educational organization isexempt from U.S. income tax on the followingamounts:

1) Gifts from abroad for maintenance, edu-cation, or training,



An individual is entitled to this exemptionfor up to 5 tax years and for an additionalperiod as is necessary to complete, as a full-time student, educational requirements for apostgraduate or professional degree from arecognized educational institution.

An individual who is a resident of Cypruson the date of arrival in the United States andwho is temporarily here as an employee of,or under contract with, a resident of Cyprusis exempt from U.S. income tax for not more

than one year on income from personal ser-vices for a maximum of $7,500 if the individ-ual is in the United States primarily to either:

1) Acquire technical, professional, or busi-ness experience from a person otherthan a resident of Cyprus or other thana person related to that resident, or

2) Study at a university or other recognizededucational institution.

An individual who is a resident of Cypruson the date of arrival in the United States andwho is temporarily here for a period of notmore than one year as a participant in a pro-gram sponsored by the U.S. Governmentprimarily to train, research, or study is exemptfrom U.S. income tax on income for personalservices for the training, research, or study.This exemption is limited to $10,000.

Czech RepublicAn individual who is a resident of the CzechRepublic at the beginning of his or her visit tothe United States and who is temporarilypresent in the United States is exempt fromU.S. income tax on certain amounts for aperiod of up to 5 years. To be entitled to theexemption, the individual must be in theUnited States for the primary purpose of:

1) Studying at a university or other accred-ited educational institution in the UnitedStates,

2) Obtaining training required to qualify himor her to practice a profession or pro-fessional specialty, or

3) Studying or doing research as a recipientof a grant, allowance, or award from agovernmental, religious, charitable, sci-entific, literary, or educational organiza-tion.

If the individual meets any of these require-ments, the following amounts are exemptfrom U.S. tax:

1) The payments from abroad, other thancompensation for personal services, forthe purpose of maintenance, education,study, research, or training,


3) The income from personal services per-formed in the United States of up to$5,000 for the tax year.

An individual who is a Czech resident atthe beginning of the visit to the United Statesand who is temporarily present in the UnitedStates as an employee of, or under contractwith, a Czech resident is exempt from U.S.income tax for a period of 12 consecutivemonths on up to $8,000 received for personalservices if the individual is in the UnitedStates primarily to:

1) Acquire technical, professional, or busi-ness experience from a person otherthan the Czech resident, or

2) Study at a university or other accreditededucational institution in the UnitedStates.

An individual who is a Czech resident atthe time he or she becomes temporarilypresent in the United States and who is tem-porarily present in the United States for aperiod not longer than 1 year as a participantin a program sponsored by the U.S. govern-

ment for the primary purpose of training, re-search, or study, is exempt from U.S. incometax on up to $10,000 of income from personalservices for that training, research, or study.

These exemptions do not apply to incomefrom research undertaken primarily for theprivate benefit of a specific person or per-sons.

DenmarkA student or apprentice who is a citizen ofDenmark and lives in the United States onlyto study or acquire business experience isexempt from U.S. income tax on amounts(other than the student's own income) re-ceived from abroad for maintenance andstudies.

EgyptAn individual who is a resident of Egypt on thedate of arrival in the United States and whois temporarily in the United States primarilyto study at a university or other recognizededucational institution in the United States,obtain professional training, or study or doresearch as a recipient of a grant, allowance,or award from a governmental, religious,charitable, scientific, literary, or educationalorganization is exempt from U.S. income taxon the following amounts:



3) Income from personal services per-formed in the United States of up to$3,000 each tax year.

An individual is entitled to the benefit ofthis exemption for a maximum of 5 tax yearsand for any additional period of time neededto complete, as a full-time student, educa-tional requirements as a candidate for apostgraduate or professional degree from arecognized educational institution.

An individual who is a resident of Egypton the date of arrival in the United States andwho is temporarily in the United States as anemployee of, or under contract with, a resi-dent of Egypt is exempt from U.S. income taxfor a period of 12 consecutive months on upto $7,500 received for personal services if theindividual is in the United States primarily to:

1) Acquire technical, professional, or busi-ness experience from a person otherthan that resident of Egypt or other thana person related to that resident, or

2) Study at a university or other educationalinstitution.

An individual who is a resident of Egypton the date of arrival in the United States andwho is temporarily in the United States for nomore than one year as a participant in a pro-gram sponsored by the U.S. Governmentprimarily to train, research, or study is exemptfrom U.S. income tax on income received forpersonal services for the training, research,or study for a maximum of $10,000.

Estonia An individual who is a resident of Estonia onthe date of arrival in the United States andwho is temporarily in the United States pri-marily to study at a university or other ac-credited educational institution in the UnitedStates, obtain professional training, or studyor do research as a recipient of a grant, al-

Page 17

lowance, or award from a governmental, reli-gious, charitable, scientific, literary, or edu-cational organization is exempt from U.S.income tax on the following amounts:

1) Payments from abroad, other than com-pensation for personal services, formaintenance, education, study, re-search, or training,




An individual who is a resident of Estoniaon the date of arrival in the United States andwho is in the United States as an employeeof, or under contract with, a resident ofEstonia is exempt from U.S. income tax for aperiod of 12 consecutive months on up to$8,000 received for personal services if theindividual is in the United States primarily to:

1) Acquire technical, professional, or busi-ness experience from a person otherthan that resident of Estonia, or


An individual who is a resident of Estoniaon the date of arrival in the United States andwho is temporarily present in the UnitedStates for not longer than 1 year as a partic-ipant in a program sponsored by the U.S.Government primarily to train, research, orstudy is exempt from U.S. income tax on in-come received for personal services for thetraining, research, or study in the amount of$10,000.

These provisions do not apply to incomefrom research carried on mainly for the pri-vate benefit of any person rather than in thepublic interest.

FinlandA full-time student, trainee, or business ap-prentice who is a resident of Finland imme-diately before visiting the United States isexempt from U.S. income tax on amountsreceived from sources outside the UnitedStates for maintenance, education, or train-ing.

FranceAn individual who is a resident of France onthe date of arrival in the United States andwho is temporarily in the United States pri-marily to study at a university or other recog-nized educational institution in the UnitedStates, obtain professional training, or study,or do research as a recipient of a grant, al-lowance, or award from a not-for-profit gov-ernmental, religious, charitable, scientific, ar-tistic, cultural, or educational organization isexempt from U.S. income tax on the followingamounts:




An individual is entitled to this benefit andthe benefit described earlier under Profes-

sors, Teachers, and Researchers for a maxi-mum of 5 tax years.


An individual who is a resident of Franceon the date of arrival in the United States andwho is in the United States as an employeeof, or under contract with, a resident of Franceis exempt from U.S. income tax for a periodof 12 consecutive months on up to $8,000received for personal services if the individualis in the United States primarily to:

1) Acquire technical, professional, or busi-ness experience from a person otherthan that resident of France, or


GermanyA student or business apprentice (includingVolontaere and Praktikanten) who is or wasimmediately before visiting the United Statesa resident of Germany and who is present inthe United States for full-time education ortraining is exempt from U.S. income tax onamounts from sources outside the UnitedStates for maintenance, education, or train-ing.

An individual who is or was immediatelybefore visiting the United States a residentof Germany is exempt from U.S. tax onamounts received as a grant, allowance, oraward from a nonprofit religious, charitable,scientific, literary, or educational organization.

Individuals described in the previous twoparagraphs are also exempt from U.S. tax oncompensation for dependent personal ser-vices of up to $5,000 per year if:

1) They are present in the United States fornot more than 4 years, and

2) The services are performed for the pur-pose of supplementing funds availableotherwise for maintenance, education,or training.

If the individual's visit exceeds 4 years, theexemption is lost for the entire visit unless thecompetent authorities of Germany and theUnited States agree otherwise.

An individual who is a resident ofGermany and who is employed by a Germanenterprise or by a nonprofit religious, charita-ble, scientific, literary, or educational organ-ization is exempt from U.S. tax on compen-sation paid by the employer from outside theUnited States if:

1) The individual is temporarily in theUnited States for not more than one yearto acquire technical, professional, orbusiness experience from any personother than his or her employer, and

2) The compensation is not more than$10,000.

If the compensation is more than $10,000,none of the income is exempt.

GreeceA student or business apprentice who is aresident of Greece and is temporarily in theUnited States only to study or acquire busi-ness experience is exempt from U.S. incometax on amounts received from sources out-side the United States for maintenance orstudies.

HungaryAn individual who is a resident of Hungaryimmediately before arrival in the UnitedStates and is here for full-time education ortraining is exempt from U.S. income tax onpayments received from outside the UnitedStates for the individual's maintenance, edu-cation, or training.

The full-time student or trainee may in-stead choose to be treated as a resident alienof the United States for U.S. income taxpurposes. Once made, the choice applies forthe entire period that the individual remainsqualified for exemption as a full-time studentor trainee and may not be changed unlesspermission is obtained from the U.S. compe-tent authority.

IcelandAn individual who is a resident of Iceland onthe date of arrival in the United States andwho is temporarily in the United States pri-marily to study at a university or other recog-nized educational institution in the UnitedStates, obtain professional training, or studyor do research as a recipient of a grant, al-lowance, or award from a governmental, reli-gious, charitable, scientific, literary, or edu-cational organization is exempt from U.S.income tax on the following amounts:





An individual who is a resident of Icelandon the date of arrival in the United States andwho is temporarily in the United States as anemployee of, or under contract with, a resi-dent of Iceland is exempt from U.S. incometax for a period of 12 consecutive months onup to $5,000 received for personal servicesif the individual is in the United States prima-rily to:

1) Acquire technical, professional, or busi-ness experience from a person otherthan that resident of Iceland or otherthan a person related to that person, or


An individual who is a resident of Icelandon the date of arrival in the United States andwho is temporarily present in the UnitedStates for not longer than one year as a par-ticipant in a program sponsored by the U.S.Government primarily to train, research, orstudy is exempt from U.S. income tax on in-come received for personal services for thetraining, research, or study for a maximum of$10,000.

IndiaAn individual who is a resident of India im-mediately before visiting the United Statesand who is temporarily in the United Statesprimarily for studying or training is exemptfrom U.S. income tax on payments fromabroad for maintenance, study, or training.The exemption does not apply to paymentsborne by a permanent establishment in theUnited States or paid by a U.S. citizen orresident, the U.S. Government, or any of its

Page 18

agencies, instrumentalities, political subdivi-sions, or local authorities.

Under the treaty, if the payments are notexempt under the rule described above, anindividual described in the previous para-graph may be eligible to deduct exemptionsfor his or her spouse and dependents and thestandard deduction. The individual must fileForm 1040NR or Form 1040NR–EZ to claimthese amounts. For information on how toclaim these amounts, see chapter 5 in Publi-cation 519.

The individual is entitled to these benefitsonly for a period of time considered reason-able or customarily required to completestudying or training.

IndonesiaAn individual who is a resident of Indonesiaimmediately before visiting the United Statesand who is temporarily in the United Statesis exempt from U.S. income tax on certainamounts for a period of up to 5 years. To beentitled to the exemption, the individual mustbe temporarily in the United States for full-time study at a U.S. university, school, orother recognized educational institution, or forfull-time study, research, or training as a re-cipient of a grant, allowance, or award fromeither the U.S. or Indonesian Government, ascientific, educational, religious, or charitableorganization, or under a technical assistanceprogram entered into by either the U.S. orIndonesian Government. If the individualmeets any of these requirements, the follow-ing amounts are exempt from tax:

1) All payments from abroad for mainte-nance, education, study, research, ortraining,



An individual who is a resident ofIndonesia immediately before visiting theUnited States and is temporarily in the UnitedStates only as a business or technical ap-prentice is exempt from U.S. income tax fora period of 12 consecutive months on up to$7,500 received for personal services.

IrelandA student, apprentice, or business traineewho is a resident of Ireland immediately be-fore visiting the United States and is in theUnited States for the purpose of full-time ed-ucation at a recognized educational institutionor full-time training is exempt from U.S. in-come tax on amounts received from sourcesoutside the United States for the individual'smaintenance, education, or training.

Apprentices and business trainees areentitled to the benefit of this exemption for amaximum period of 1 year.

IsraelAn individual who is a resident of Israel on thedate of arrival in the United States and whois temporarily in the United States primarilyto study at a university or other recognizededucational institution in the United States,obtain professional training, or study or doresearch as a recipient of a grant, allowance,or award from a governmental, religious,charitable, scientific, literary, or educationalorganization is exempt from U.S. income taxon the following amounts:




An individual is entitled to the benefit ofthis exemption for a maximum of 5 tax years.

An individual who is a resident of Israelon the date of arrival in the United States andwho is temporarily in the United States as anemployee of, or under contract with, a resi-dent of Israel is exempt from U.S. income taxfor a period of 12 consecutive months on upto $7,500 received for personal services if theindividual is in the United States primarily to:

1) Acquire technical, professional, or busi-ness experience from a person otherthan that resident of Israel or other thana person related to that resident, or

2) Study at a university or other educationalinstitution.

An individual who is a resident of Israelon the date of arrival in the United States andwho is temporarily in the United States for nomore than one year as a participant in a pro-gram sponsored by the U.S. Governmentprimarily to train, research, or study is exemptfrom U.S. income tax on income received forpersonal services for the training, research,or study for a maximum of $10,000.

ItalyA student or business apprentice (trainee)who is a resident of Italy on the date of arrivalin the United States and who is temporarilyin the United States only for education ortraining is exempt from U.S. income tax onamounts received from outside the UnitedStates for maintenance, education, and train-ing.

JamaicaA student who is a resident of Jamaica on thedate of arrival in the United States and is herefor full-time education or training is exemptfrom U.S. income tax on payments receivedfrom outside the United States for the stu-dent's maintenance, education, or training.

An individual who is a resident of Jamaicaon the date of arrival in the United States andwho is temporarily in the United States as anemployee of, or under contract with, a resi-dent of Jamaica is exempt from U.S. incometax for a period of 12 consecutive months onup to $7,500 of net income from personalservices if the individual is in the UnitedStates primarily to:

1) Acquire technical, professional, or busi-ness experience from a person otherthan that resident of Jamaica or otherthan a person related to that resident,or

2) Study at a university or other recognizededucational institution.

An individual who qualifies for one of theexemptions discussed above may insteadchoose to be treated as a resident alien of theUnited States for all U.S. income tax pur-poses. Once made, the choice applies for theentire period that the individual remainsqualified for exemption and may not be re-voked unless permission is obtained from theU.S. competent authority.

JapanAn individual who is a resident of Japan onthe date of arrival in the United States andwho is temporarily in the United States pri-marily to study at a university or other ac-credited educational institution in the UnitedStates, obtain professional training, or studyor do research as a recipient of a grant, al-lowance, or award from a governmental, reli-gious, charitable, scientific, literary, or edu-cational organization is exempt from U.S.income tax on the following amounts:





An individual who is a resident of Japanon the date of arrival in the United States andwho is in the United States as an employeeof, or under contract with, a resident of Japanis exempt from U.S. income tax for a periodof 12 consecutive months on up to $5,000received for personal services if the individualis in the United States primarily to:

1) Acquire technical, professional, or busi-ness experience from a person otherthan that resident of Japan, or


An individual who is a resident of Japanon the date of arrival in the United States andwho is temporarily present in the UnitedStates for not longer than one year as a par-ticipant in a program sponsored by the U.S.Government primarily to train, research, orstudy is exempt from U.S. income tax on in-come received for personal services for thetraining, research, or study in the amount of$10,000.

KazakstanAn individual who is a resident of Kazakstanat the beginning of his or her visit to theUnited States is exempt from U.S. tax onpayments from abroad for maintenance, ed-ucation, study, research, or training and onany grant, allowance, or other similar pay-ments. To be entitled to the exemption, theindividual must be temporarily present in theUnited States primarily to:

1) Study at a university or other accreditededucational institution,

2) Obtain training required to qualify himor her to practice a profession or pro-fessional specialty, or,

3) Study or do research as a recipient of agrant, allowance, or other similar pay-ments from a governmental, religious,charitable, scientific, literary, or educa-tional organization.

The individual is entitled to this exemptiononly for a period of time necessary to com-plete the study, training, or research, but theexemption for training or research may notextend for a period exceeding 5 years .

These exemptions do not apply to incomefrom research if it is undertaken primarily for

Page 19

the private benefit of a specific person orpersons.

Korea, Republic ofAn individual who is a resident of the Republicof Korea on the date of arrival in the UnitedStates and who is temporarily in the UnitedStates primarily to study at a university orother recognized educational institution in theUnited States, obtain professional training, orstudy or do research as a recipient of a grant,allowance, or award from a governmental,religious, charitable, scientific, literary, or ed-ucational organization is exempt from U.S.income tax on the following amounts:

1) Amounts from abroad for maintenance,education, study, research, or training,




An individual who is a resident of Koreaon the date of arrival in the United States andwho is temporarily in the United States as anemployee of, or under contract with, a resi-dent of Korea is exempt from U.S. income taxfor one year on up to $5,000 received forpersonal services if the individual is in theUnited States primarily to:

1) Acquire technical, professional, or busi-ness experience from a person otherthan that resident of Korea or other thana person related to that resident, or


An individual who is a resident of Koreaon the date of arrival in the United States andwho is temporarily present in the UnitedStates for not longer than one year as a par-ticipant in a program sponsored by the U.S.Government primarily to train, research, orstudy is exempt from U.S. income tax on in-come received for personal services for thetraining, research, or study for a maximum of$10,000.

Latvia An individual who is a resident of Latvia onthe date of arrival in the United States andwho is temporarily in the United States pri-marily to study at a university or other ac-credited educational institution in the UnitedStates, obtain professional training, or studyor do research as a recipient of a grant, al-lowance, or award from a governmental, reli-gious, charitable, scientific, literary, or edu-cational organization is exempt from U.S.income tax on the following amounts:





An individual who is a resident of Latviaon the date of arrival in the United States and

who is in the United States as an employeeof, or under contract with, a resident of Latviais exempt from U.S. income tax for a periodof 12 consecutive months on up to $8,000received for personal services if the individualis in the United States primarily to:

1) Acquire technical, professional, or busi-ness experience from a person otherthan that resident of Latvia, or


An individual who is a resident of Latviaon the date of arrival in the United States andwho is temporarily present in the UnitedStates for not longer than one year as a par-ticipant in a program sponsored by the U.S.Government primarily to train, research, orstudy is exempt from U.S. income tax on in-come received for personal services for thetraining, research, or study in the amount of$10,000.


Lithuania An individual who is a resident of Lithuaniaon the date of arrival in the United States andwho is temporarily in the United States pri-marily to study at a university or other ac-credited educational institution in the UnitedStates, obtain professional training, or studyor do research as a recipient of a grant, al-lowance, or award from a governmental, reli-gious, charitable, scientific, literary, or edu-cational organization is exempt from U.S.income tax on the following amounts:





An individual who is a resident of Lithuaniaon the date of arrival in the United States andwho is in the United States as an employeeof, or under contract with, a resident ofLithuania is exempt from U.S. income tax fora period of 12 consecutive months on up to$8,000 received for personal services if theindividual is in the United States primarily to:

1) Acquire technical, professional, or busi-ness experience from a person otherthan that resident of Lithuania, or


An individual who is a resident of Lithuaniaon the date of arrival in the United States andwho is temporarily present in the UnitedStates for not longer than one year as a par-ticipant in a program sponsored by the U.S.Government primarily to train, research, orstudy is exempt from U.S. income tax on in-come received for personal services for thetraining, research, or study in the amount of$10,000.


LuxembourgCertain residents of Luxembourg are exemptfrom U.S. income tax on income receivedfrom abroad for employment or amounts re-ceived from abroad for their maintenance,education, or training if they are temporarilyin the United States. To qualify for this ex-emption they must be temporarily in theUnited States only as:

1) Students at a university, college, school,or other recognized educational institu-tion, or

2) Business apprentices for not more thanone year, or

3) Recipients of a grant, allowance, oraward from a religious, charitable, sci-entific, literary, or educational organiza-tion primarily to study or research.

Certain other residents of Luxembourgwho are temporarily in the United States forno more than one year are exempt from U.S.income tax for that period on pay, includingpay from an employer abroad, of not morethan $5,000. To qualify for this exemptionthey must be employees of, or under contractwith, a Luxembourg enterprise or aLuxembourg religious, charitable, scientific,literary, or educational organization and be inthe United States only to acquire technical,professional, or business experience from aperson other than that enterprise or organ-ization.

Residents of Luxembourg are also exemptfrom U.S. income tax on certain income if theyare in the United States for no more than oneyear only for training, research, or study un-der an arrangement with the U.S. Govern-ment. The income that is exempt in this caseis that received for services directly related tothis training, research, or study and includespay from their employer abroad. The amountexempt may not be more than $10,000.

MexicoA student or business apprentice who is aresident of Mexico immediately before visitingthe United States and is in the United Statessolely for the purpose of education or trainingis exempt from U.S. tax on amounts receivedfrom sources outside the United States for theindividual's maintenance, education, or train-ing.

MoroccoAn individual who is a resident of Moroccoon the date of arrival in the United States andwho is temporarily in the United States pri-marily to study at a university or other recog-nized educational institution in the UnitedStates, obtain professional training, or studyor do research as a recipient of a grant, al-lowance, or award from a governmental, reli-gious, charitable, scientific, literary, or edu-cational organization is exempt from U.S.income tax on the following amounts:





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NetherlandsAn individual who immediately before visitingthe United States is a resident of theNetherlands and who is present in the UnitedStates primarily for full-time study at a recog-nized university, college, or school or secur-ing training as a business apprentice is ex-empt from U.S. income tax on the followingamounts:

1) Payments from abroad for maintenance,education, or training, and


The individual is entitled to this exemptiononly for a period of time considered reason-able or customarily required to completestudying or training.

An individual who immediately before vis-iting the United States is a resident of theNetherlands and is temporarily present in theUnited States for a period not exceeding 3years for the purpose of study, research, ortraining solely as a recipient of a grant, al-lowance, or award from a scientific, educa-tional, religious, or charitable organization orunder a technical assistance program enteredinto by either the Netherlands or the UnitedStates, or its political subdivisions or localauthorities is exempt from U.S. income taxon the following amounts:

1) The amount of the grant, allowance, oraward, and

2) Income of up to $2,000 for personalservices performed in the United Statesfor any tax year if the services are con-nected with, or incidental to, the study,research, or training.

An individual is not entitled to these ex-emptions if, during the immediately precedingperiod, the individual claimed the exemptiondiscussed earlier under Professors, Teach-ers, and Researchers.

New ZealandA resident of New Zealand or an individualwho was a resident of New Zealand imme-diately before visiting the United States whois in the United States for full-time educationis exempt from U.S. income tax on amountsreceived from abroad for maintenance or ed-ucation.

NorwayAn individual who is a resident of Norway onthe date of arrival in the United States andwho is temporarily in the United States pri-marily to study at a university or other recog-nized educational institution in the UnitedStates, obtain professional training, or studyor do research as a recipient of a grant, al-lowance, or award from a governmental, reli-gious, charitable, scientific, literary, or edu-cational organization is exempt from U.S.income tax on the following amounts:



3) Income from personal services per-formed in the United States up to $2,000each tax year.

An individual is entitled to the benefit ofthis exemption for a maximum of 5 tax years.

An individual who is a resident of Norwayon the date of arrival in the United States andwho is in the United States as an employeeof, or under contract with, a resident ofNorway is exempt from U.S. income tax fora period of 12 consecutive months on up to$5,000 received for personal services if theindividual is in the United States primarily to:

1) Acquire technical, professional, or busi-ness experience from a person otherthan that resident of Norway or otherthan a person related to that resident ofNorway, or


Also exempt is a resident of Norway whois present in the United States for not longerthan 1 year as a participant in a programsponsored by the Government of the UnitedStates primarily to train, research, or study.The individual is exempt from tax on incomefrom personal services performed in theUnited States and received for the training,research, or study, for a maximum of$10,000.

PakistanResidents of Pakistan temporarily in theUnited States are exempt from U.S. incometax on certain income they may receive. Tobe entitled to this exemption, they must be inthe United States only as students at a rec-ognized university, college, or school, or asrecipients of grants, allowances, or awardsfrom religious, charitable, scientific, or edu-cational organizations of Pakistan primarily tostudy or research. The income exempt inthese cases is any payment from abroad formaintenance, education, or training, and anypay for personal services of not more than$5,000 for any tax year.

Other residents of Pakistan who are tem-porarily in the United States for no more thanone year are exempt from U.S. income taxon pay of not more than $6,000 received forthat period, including pay from the enterpriseor organization of which they are employeesor with which they are under contract. Toqualify for this exemption, they must be em-ployees of, or under contract with, a Pakistanienterprise or religious, charitable, scientific,or educational organization and be in theUnited States only to acquire technical, pro-fessional, or business experience from aperson other than that enterprise or organ-ization.

Also exempt from U.S. income tax oncertain income are residents of Pakistantemporarily in the United States under an ar-rangement with the U.S. Government, or anyof its agencies or instrumentalities, only forstudy, training, or orientation. They are ex-empt from tax on income of not more than$10,000 for services directly related to theirtraining, study, or orientation, including in-come from their employer abroad.

PhilippinesAn individual who is a resident of thePhilippines on the date of arrival in the UnitedStates and who is temporarily in the UnitedStates primarily to study at a university orother recognized educational institution in theUnited States, obtain professional training, orstudy or do research as a recipient of a grant,allowance, or award from a governmental,religious, charitable, scientific, literary, or ed-ucational organization is exempt from U.S.income tax on the following amounts:





An individual who is a resident of thePhilippines on the date of arrival in the UnitedStates and who is temporarily in the UnitedStates as an employee of, or under contractwith, a resident of the Philippines is exemptfrom U.S. income tax for a period of 12 con-secutive months on up to $7,500 received forpersonal services if the individual is in theUnited States primarily to:

1) Acquire technical, professional, or busi-ness experience from a person otherthan that resident of the Philippines orother than a person related to that resi-dent, or


An individual who is a resident of thePhilippines on the date of arrival in the UnitedStates, and who is temporarily in the UnitedStates (for no more than one year as a par-ticipant in a program sponsored by the U.S.Government) primarily to train, research, orstudy, is exempt from U.S. income tax on in-come received for personal services for thetraining, research, or study, up to a maximumof $10,000.

PolandAn individual who is a resident of Poland onthe date of arrival in the United States andwho is temporarily in the United States pri-marily to study at a university or other recog-nized educational institution in the UnitedStates, obtain professional training, or studyor do research as a recipient of a grant, al-lowance, or award from a governmental, reli-gious, charitable, scientific, literary, or edu-cational organization is exempt from U.S.income tax on the following amounts:


2) The grant, allowance, or award,

3) Any other payments received fromPoland, except income from performingpersonal services, and



An individual who is a resident of Polandon the date of arrival in the United States andwho is temporarily in the United States as anemployee of, or under contract with, a resi-dent of Poland is exempt from U.S. incometax for one year on up to $5,000 received forpersonal services if the individual is in theUnited States primarily to:

1) Acquire technical, professional, or busi-ness experience from a person otherthan that resident of Poland or other thana person related to that resident, or


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An individual who is a resident of Polandon the date of arrival in the United States andwho is temporarily in the United States for notlonger than one year as a participant in aprogram sponsored by the U.S. Governmentprimarily to train, research, or study is exemptfrom U.S. income tax on up to $10,000 of in-come received for personal services for thetraining, research, or study.

PortugalAn individual who is a resident of Portugal onthe date of arrival in the United States andwho is temporarily in the United States pri-marily to study at a university or other ac-credited educational institution in the UnitedStates, obtain professional training, or study,or do research as a recipient of a grant, al-lowance, or award from a governmental, reli-gious, charitable, scientific, literary, or edu-cational organization is exempt from U.S.income tax on the following amounts:

1) Payments from abroad for maintenance,education, study, research, or training,



An individual is entitled to the benefit ofthis exemption for a maximum of 5 tax yearsfrom the date of arrival in the United States.The benefits provided here and the benefitsdescribed earlier under Professors, Teachers,and Researchers cannot be claimed simul-taneously or consecutively.

An individual who is a resident of Portugalon the date of arrival in the United States andwho is in the United States as an employeeof, or under contract with, a resident ofPortugal is exempt from U.S. income tax fora period of 12 consecutive months on up to$8,000 received for personal services if theindividual is in the United States primarily to:

1) Acquire technical, professional, or busi-ness experience from a person otherthan that resident of Portugal, or


RomaniaAn individual who is a resident of Romaniaon the date of arrival in the United States andwho is temporarily in the United States pri-marily to study at a university or other recog-nized educational institution in the UnitedStates, obtain professional training, or studyor do research as a recipient of a grant, al-lowance, or award from a governmental, reli-gious, charitable, scientific, literary, or edu-cational organization is exempt from U.S.income tax on the following amounts:





An individual who is a resident of Romaniaon the date of arrival in the United States andwho is temporarily in the United States as anemployee of, or under contract with, a resi-dent of Romania is exempt from U.S. income

tax for 1 year on up to $5,000 received forpersonal services if the individual is in theUnited States primarily to:

1) Acquire technical, professional, or busi-ness experience from a person otherthan that resident of Romania or otherthan a person related to that resident,or


An individual who is a resident of Romaniaon the date of arrival in the United States andwho is temporarily in the United States for notlonger than 1 year as a participant in a pro-gram sponsored by the U.S. Governmentprimarily to train, research, or study is exemptfrom U.S. income tax on up to $10,000 of in-come received for personal services for thetraining, research, or study.

RussiaAn individual who is a resident of Russia atthe beginning of his or her visit to the UnitedStates is exempt from U.S. tax on paymentsfrom abroad for maintenance, education,study, research, or training and on any grant,allowance, or other similar payments. To beentitled to the exemption, the individual mustbe temporarily present in the United Statesprimarily to:

1) Study at a university or other accreditededucational institution,

2) Obtain training required to qualify himor her to practice a profession or pro-fessional specialty, or,

3) Study or do research as a recipient of agrant, allowance, or other similar pay-ments from a governmental, religious,charitable, scientific, literary, or educa-tional organization.

The individual is entitled to this exemptiononly for a period of time necessary to com-plete the study, training, or research, but theexemption for training or research may notextend for a period exceeding 5 years.

These exemptions do not apply to incomefrom research if it is undertaken primarily forthe private benefit of a specific person orpersons.

Slovak RepublicAn individual who is a resident of the SlovakRepublic at the beginning of his or her visit tothe United States and who is temporarilypresent in the United States is exempt fromU.S. income tax on certain amounts for aperiod of up to 5 years. To be entitled to theexemption, the individual must be in theUnited States for the primary purpose of:

1) Studying at a university or other accred-ited educational institution in the UnitedStates,




1) The payments from abroad, other thancompensation for personal services, forthe purpose of maintenance, education,study, research, or training,


3) The income from personal services per-formed in the United States of up to$5,000 for the tax year.

An individual who is a Slovak resident atthe beginning of the visit to the United Statesand who is temporarily present in the UnitedStates as an employee of, or under contractwith, a Slovak resident is exempt from U.S.income tax for a period of 12 consecutivemonths on up to $8,000 received from per-sonal services if the individual is in the UnitedStates primarily to:

1) Acquire technical, professional, or busi-ness experience from a person otherthan the Slovak resident, or


An individual who is a Slovak resident atthe time he or she becomes temporarilypresent in the United States and who is tem-porarily present in the United States for aperiod not longer than 1 year as a participantin a program sponsored by the U.S. govern-ment for the primary purpose of training, re-search, or study, is exempt from U.S. incometax on up to $10,000 of income from personalservices for that training, research, or study.

These exemptions do not apply to incomefrom research undertaken primarily for theprivate benefit of a specific person or per-sons.

South AfricaA student, apprentice, or business traineewho is a resident of South Africa immediatelybefore visiting the United States and is in theUnited States for the purpose of full-time ed-ucation or training is exempt from U.S. in-come tax on amounts received from sourcesoutside the United States for the individual'smaintenance, education, or training.

Apprentices and business trainees areentitled to the benefit of this exemption for amaximum period of one year.

SpainAn individual who is a resident of Spain at thebeginning of the visit to the United States andwho is temporarily in the United States pri-marily to study at a U.S. university or otheraccredited educational institution, to obtaintraining to become qualified to practice aprofession or professional specialty, or tostudy or do research as a recipient of a grant,allowance, or award from a governmental,religious, charitable, scientific, literary, or ed-ucational organization is exempt from U.S.income tax on the following amounts:

1) Payments from abroad (other than com-pensation for personal services) formaintenance, education, study, re-search, or training,



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An individual is entitled to the benefit of thisexemption for a maximum of 5 years.

An individual who is a resident of Spainat the beginning of the visit to the UnitedStates and is temporarily in the United Statesas an employee of, or under contract with, aresident of Spain is exempt from U.S. incometax for a period of 12 consecutive months onup to $8,000 received for personal servicesif the individual is in the United States prima-rily to:

1) Acquire technical, professional, or busi-ness experience from a person otherthan that Spanish resident, or


Both the $5,000 and $8,000 exemptionsinclude any amount excluded or exemptedfrom tax under U.S. tax law.

These exemptions do not apply to incomefrom research carried on mainly for the pri-vate benefit of any person rather than in thepublic interest.

SwedenA student, apprentice, or business traineewho is a resident of Sweden immediately be-fore visiting the United States and is in theUnited States for the purpose of full-time ed-ucation or training is exempt from U.S. tax onamounts received from sources outside theUnited States for the individual's mainte-nance, education, and training.

SwitzerlandA student, apprentice, or business traineewho is a resident of Switzerland immediatelybefore visiting the United States and is in theUnited States for the purpose of full-time ed-ucation or training is exempt from U.S. in-come tax on amounts received from sourcesoutside the United States for the individual'smaintenance, education, or training.

ThailandAn individual who is a resident of Thailand atthe beginning of his or her visit to the UnitedStates and who is temporarily present in theUnited States is exempt from U.S. income taxon certain amounts for a period of up to 5years. To be entitled to the exemption, theindividual must be in the United States for theprimary purpose of:

1) Studying at a university or other recog-nized educational institution in the UnitedStates,




1) Gifts from abroad for the purpose ofmaintenance, education, study, re-search, or training,


3) Income from personal services per-formed in the United States of up to$3,000 for the tax year.

An individual who is a resident of Thailandat the beginning of the visit to the UnitedStates and who is temporarily present in theUnited States as an employee of, or undercontract with, a resident of Thailand is exemptfrom U.S. income tax for a period of 12 con-secutive months on up to $7,500 receivedfrom personal services if the individual is inthe United States primarily to:

1) Acquire technical, professional, or busi-ness experience from a person otherthan the Thai resident, or

2) Study at a university or other recognizededucational institution in the UnitedStates.

An individual who is a resident of Thailandat the time he or she becomes temporarilypresent in the United States and who is tem-porarily present in the United States for aperiod not longer than 1 year as a participantin a program sponsored by the U.S. govern-ment for the primary purpose of training, re-search, or study, is exempt from U.S. incometax on up to $10,000 of income from personalservices for that training, research, or study.

Trinidad and TobagoAn individual who is a resident of Trinidad andTobago on the date of arrival in the UnitedStates and who is temporarily in the UnitedStates primarily to study at a university orother accredited educational institution in theUnited States, obtain professional training, orstudy or do research as a recipient of a grant,allowance, or award from a governmental,religious, charitable, scientific, literary, or ed-ucational organization is exempt from U.S.income tax on the following amounts:



3) Income from personal services per-formed in the United States of up to$2,000 each tax year, or, if the individualis obtaining training required to qualify topractice a profession or a professionalspecialty, a maximum of $5,000 for anytax year.

An individual is entitled to the benefit ofthis exemption for a maximum period of 5 taxyears.

An individual who is a resident of Trinidadand Tobago on the date of arrival in theUnited States and who is in the United Statesas an employee of, or under contract with, aresident or corporation of Trinidad andTobago is exempt from U.S. income tax for1 tax year on up to $5,000 received for per-sonal services if the individual is in the UnitedStates primarily to:

1) Study at an educational institution, or

2) Acquire technical, professional, or busi-ness experience from a person otherthan that resident or corporation ofTrinidad and Tobago.

Also exempt is a resident of Trinidad andTobago who is present in the United Statesfor not longer than one year as a participantin a program sponsored by the U.S. Govern-ment primarily to train, research, or study.

The individual is exempt from tax on incomefrom personal services performed in theUnited States and received for the training,research, or study for up to a maximum of$10,000.

TunisiaAn individual who is a resident of Tunisia im-mediately before visiting the United Statesand who is in the United States for full-timestudy or training is exempt from U.S. incometax on the following amounts:

1) Payments from abroad for full-time studyor training,

2) A grant, allowance, or award from agovernmental, religious, charitable, sci-entific, literary, or educational organiza-tion to study or engage in research, and

3) Income from personal services per-formed in the United States of up to$4,000 in any tax year.

The individual is entitled to this exemptionfor a maximum of 5 years.

TurkeyA student, apprentice, or business traineewho is a resident of Turkey immediately be-fore visiting the United States and is in theUnited States for the purpose of full-time ed-ucation or training is exempt from U.S. in-come tax on amounts received from sourcesoutside the United States for the individual'smaintenance, education, or training.

United KingdomA student or business apprentice who is aresident of the United Kingdom at the time ofarrival in the United States and who is re-ceiving full-time education or training in theUnited States is exempt from U.S. income taxon payments received from abroad for main-tenance, education, or training.

Venezuela An individual who is a resident of Venezuelaon the date of arrival in the United States andwho is temporarily in the United States pri-marily to study at a university or other recog-nized educational institution in the UnitedStates, obtain professional training, or studyor do research as a recipient of a grant, al-lowance, or award from a governmental, reli-gious, charitable, scientific, literary, or edu-cational organization is exempt from U.S.income tax on the following amounts:




An individual is generally entitled to thebenefit of this exemption for a maximum of 5years from the date of arrival in the UnitedStates. This exemption will also apply to anyadditional period of time that a full-time stu-dent needs to complete the educational re-quirements as a candidate for a postgraduateor professional degree from a recognizededucational institution.

An individual who is a resident ofVenezuela on the date of arrival in the United

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States and who is in the United States as anemployee of, or under contract with, a resi-dent of Venezuela is exempt from U.S. in-come tax for a period of 12 months on up to$8,000 received for personal services if theindividual is in the United States primarily to:

1) Acquire technical, professional, or busi-ness experience from a person otherthan that resident of Venezuela, or



Wages and PensionsPaid by a ForeignGovernmentWages, salaries, pensions, and annuities paidby the governments of the following countriesto their residents who are present in theUnited States as nonresident aliens generallyare exempt from U.S. income tax. The con-ditions under which the income is exempt arestated for each of the countries listed.

Exemption under U.S. tax law. Employeesof foreign countries who do not qualify undera tax treaty provision and employees ofinternational organizations should see if theycan qualify for exemption under U.S. tax law.

If you work for a foreign government in theUnited States, your foreign government salaryis exempt from U.S. tax if you perform ser-vices similar to those performed by U.S.government employees in that foreign countryand that foreign government grants anequivalent exemption. If you work for aninternational organization in the UnitedStates, your salary from that source is exemptfrom U.S. tax. See chapter 10 of Publication519 for more information.

AustraliaSalaries, wages, and similar income, includ-ing pensions, paid by Australia, its politicalsubdivisions, agencies, or authorities to itscitizens (other than U.S. citizens) for per-forming governmental functions as an em-ployee of any of the above entities are exemptfrom U.S. income tax.

AustriaWages, salaries, similar income, and pen-sions and annuities paid from public funds ofAustria, its political subdivisions, or its localauthorities, to citizens of Austria for perform-ing governmental functions as an employeeare exempt from U.S. tax.

However, this exemption does not applyto payments for services performed in con-nection with a trade or business carried onby Austria or its political subdivisions or localauthorities.

Former treaty. For 1999, you can elect toapply the old treaty in its entirety. The pro-visions for wages and pensions paid by aforeign government are as follows.

Wages, salaries, and similar income andpensions paid by Austria, Bundeslaender,districts or municipalities or other public cor-porations or a public pension fund to an indi-vidual (other than a citizen of the United

States or an individual admitted to the UnitedStates for permanent residence) are exemptfrom U.S. income tax.

BarbadosIncome, including a pension, paid from thepublic funds of Barbados, or its political sub-divisions or local authorities, to a citizen ofBarbados for performing governmental func-tions is exempt from U.S. income tax.

However, this exemption does not applyto payments for services in connection witha business carried on by Barbados or its pol-itical subdivisions or local authorities.

BelgiumWages, salaries, similar income, and pen-sions and annuities paid by, or from publicfunds of, Belgium, its political subdivisions,or its local authorities, to citizens of Belgium(or to citizens of countries other than theUnited States or Belgium who come to theUnited States and are employed by Belgiumor its political subdivisions or local authorities)for performing governmental functions areexempt from U.S. tax.

However, this exemption does not applyto payments for services performed in con-nection with a trade or business carried onby Belgium or its political subdivisions or localauthorities.

CanadaWages, salaries, and similar income (otherthan pensions) paid by Canada or by aCanadian political subdivision or local au-thority to a citizen of Canada for performinggovernmental functions are exempt from U.S.income tax. This exemption does not apply,however, to payments for services performedin connection with a trade or business carriedon by Canada or its political subdivisions orlocal authorities.

Also see Publication 597, Information onthe United States—Canada Income TaxTreaty.

China, People's Republic ofIncome, other than a pension, paid by thePeople's Republic of China or its politicalsubdivisions or local authorities to an individ-ual for services performed for the payinggovernmental body is exempt from U.S. in-come tax. However, the exemption does notapply to payments for services performed inthe United States by a resident of the UnitedStates who either:

1) Is a U.S. citizen, or

2) Did not become a U.S. resident only toperform the services.

Pensions paid by the People's Republicof China for services performed for China areexempt from U.S. income tax unless the re-cipient is both a citizen and a resident of theUnited States.

These exemptions do not apply to incomeor pensions for services performed in con-nection with a business carried on by thePeople's Republic of China or its subdivisionsor local authorities.

Commonwealth ofIndependent StatesWages, salaries, and similar income paid bythe C.I.S. or a member of the C.I.S. to its cit-izens for personal services performed as an

employee of a governmental agency or insti-tution of the C.I.S. or a member of the C.I.S.(excluding local government employees) inthe discharge of governmental functions areexempt from U.S. income tax. For this pur-pose, persons engaged in commercial activ-ities are not considered engaged in the dis-charge of governmental functions.

CyprusWages, salaries, and similar income, includ-ing pensions, annuities, and similar benefits,paid from public funds of Cyprus to a citizenof Cyprus for labor or personal services per-formed as an employee of Cyprus in the dis-charge of governmental functions are exemptfrom U.S. income tax.

Czech RepublicIncome, including a pension, paid from thepublic funds of the Czech Republic, its poli-tical subdivisions, or local authorities to aCzech citizen for services performed in thedischarge of governmental functions is ex-empt from U.S. income tax. This exemptiondoes not apply to income paid for servicesperformed in connection with a business car-ried on by the Czech Republic, its politicalsubdivisions, or local authorities.

DenmarkWages, salaries, and similar income andpensions paid by Denmark, or any public au-thority in Denmark, to individuals living in theUnited States are exempt from U.S. incometax. This exemption does not apply to citizensof the United States or alien residents of theUnited States.

EgyptWages, salaries, and similar income, includ-ing pensions, annuities, and similar benefits,paid from public funds of the Arab Republicof Egypt to a citizen of Egypt (or to a citizenof another country who comes to the UnitedStates specifically to work for the Governmentof Egypt) for labor or personal services per-formed as an employee of the national Gov-ernment of Egypt, or any of its agencies, inthe discharge of governmental functions areexempt from U.S. income tax.

This exemption does not apply to U.S.citizens or to alien residents of the UnitedStates. The exemption also does not apply topayments for services performed in con-nection with a trade or business carried onby Egypt or any of its agencies.

Estonia Income, other than a pension, paid by or frompublic funds of Estonia, its political subdivi-sions, or local authorities to an individual forservices performed as an employee for thepaying governmental body in the dischargeof governmental functions is exempt fromU.S. income tax. However, the exemptiondoes not apply if the services are performedin the United States by a resident of theUnited States who either:



Pensions paid by or from the public fundsof Estonia, its political subdivisions, or localauthorities for services performed for Estoniaare exempt from U.S. income tax unless the

Page 24

recipient is both a resident and citizen of theUnited States.

FinlandIncome, other than a pension, paid byFinland, its political subdivisions, statutorybodies, or local authorities to an individual forservices performed for the paying govern-mental body is exempt from U.S. income tax.However, the exemption does not apply topayments for services performed in theUnited States by a U.S. resident who either:



Pensions paid by Finland for servicesperformed for Finland are exempt from U.S.income tax unless the recipient is a residentand citizen of the United States.

These exemptions do not apply to incomeor pensions for services performed in con-nection with a trade or business carried onby Finland or its political subdivisions, statu-tory bodies, or local authorities.

FranceIncome, including pensions, paid by theFrench Government or a local authoritythereof to an individual in the United Statesfor services performed for France (or for alocal authority of France) in the discharge ofgovernmental functions is exempt from U.S.tax. This exemption does not apply to a per-son who is both a resident and citizen of theUnited States and not a French national.

This exemption does not apply to any in-come or pensions paid because of services(or past services) performed in connectionwith a business carried on by the FrenchGovernment (or a local authority thereof).

GermanyWages, salaries, and similar income andpensions paid by Germany, its Laender, ormunicipalities, or their public pension fundsare exempt from U.S. income tax if paid toindividuals other than U.S. citizens and otherthan individuals admitted to the United Statesfor permanent residence.

GreeceWages, salaries, and similar income andpensions paid by Greece or its subdivisionsto individuals living in the United States forservices rendered to Greece or its subdivi-sions are exempt from U.S. income tax. Thisexemption does not apply to citizens of theUnited States or alien residents of the UnitedStates.

HungaryIncome (other than a pension) paid by theRepublic of Hungary or its political subdivi-sions for labor or personal services performedfor the paying governmental body is exemptfrom U.S. tax. However, the exemption doesnot apply to payments for services performedin the United States by a resident of theUnited States who either:


2) Did not become a resident of the UnitedStates only to perform the services.

Pensions paid by Hungary for servicesperformed for Hungary are exempt from U.S.income tax unless the recipient is both a citi-zen and a resident of the United States.

These exemptions do not apply to incomeor pensions for services performed in con-nection with a trade or business carried onby Hungary or its subdivisions.

IcelandWages, salaries, and similar income, includ-ing pensions and similar benefits, paid by orfrom public funds of the Republic of Iceland,a political subdivision, or a local authority toa citizen of Iceland (other than a U.S. citizenor one admitted to the United States for per-manent residence) for labor or personal ser-vices performed for Iceland or its politicalsubdivisions or local authorities in the dis-charge of governmental functions are exemptfrom U.S. tax.

IndiaIncome, other than a pension, paid by India,its political subdivisions, or local authorities toan individual for services performed for thepaying governmental body is exempt fromU.S. income tax. However, the exemptiondoes not apply if the services are performedin the United States by a U.S. resident whoeither:



Pensions paid by India for services per-formed for India are exempt from U.S. taxunless the individual is both a resident andcitizen of the United States.

These exemptions do not apply to incomeor pensions for services performed in con-nection with a business carried on by India,its subdivisions, or local authorities.

IndonesiaIncome, other than a pension, paid byIndonesia, its political subdivisions, or localauthorities to an individual for services per-formed for the paying governmental body isexempt from U.S. income tax. However, theexemption does not apply if the services areperformed in the United States by a U.S.resident who either:



Pensions paid by Indonesia for servicesperformed for Indonesia are exempt from U.S.tax.

These exemptions do not apply to incomeor pensions for services performed in con-nection with a trade or business carried onby Indonesia, its subdivisions, or local au-thorities.

IrelandIncome, other than a pension, paid by Irelandor its political subdivisions or local authoritiesto an individual for services performed for thepaying governmental body is exempt fromU.S. income tax. However, the exemptiondoes not apply to payments for services per-formed in the United States by a resident ofthe United States who either:



Pensions paid by Ireland for services per-formed for Ireland are exempt from U.S. in-come tax unless the recipient is both a resi-dent and citizen of the United States.

These exemptions do not apply to incomeor pensions for services performed in con-nection with a business carried on by Irelandor its subdivisions or local authorities.

IsraelWages, salaries, and similar income, includ-ing pensions and similar benefits, paid frompublic funds by the national government ofIsrael or its agencies, for services performedin the discharge of governmental functions,are exempt from U.S. income tax. This ex-emption does not apply to citizens of theUnited States or alien residents of the UnitedStates.

ItalyIncome, other than a pension, paid by Italyor by an Italian political or administrativesubdivision or local authority to an individualfor services performed for the paying gov-ernmental body is exempt from U.S. incometax. However, the exemption does not applyto payments for services performed in theUnited States by a resident of the UnitedStates who either:



The spouse and dependent children of anindividual, however, are not subject to thesecond restriction if that individual is receivingexempt income for governmental servicesperformed for Italy and that individual doesnot come under either of the restrictions.

Pensions paid by Italy for services per-formed for Italy are exempt from U.S. incometax unless the recipient is both a citizen anda resident of the United States.

These exemptions do not apply to incomeor pensions for services performed in con-nection with a trade or business carried onby Italy or its subdivisions or local authorities.

JamaicaIncome, other than a pension, paid by theGovernment of Jamaica or its political subdi-visions or local authorities for personal ser-vices performed for the paying governmentalbody is exempt from U.S. income tax.

This exemption does not apply to pay-ments for services performed in the UnitedStates by an individual who is a citizen andresident of the United States.

Pensions paid by Jamaica for servicesperformed for Jamaica generally are exemptfrom U.S. income tax. However, if the recipi-ent of the pension is a citizen and residentof the United States and was a U.S. citizenat the time the services were performed, thepension is taxable in the United States.

These exemptions do not apply to incomeor pensions for services performed in con-nection with a trade or business carried onby Jamaica or its subdivisions or local au-thorities.

Page 25

JapanSalaries, wages, and similar income, includ-ing pensions and similar benefits, paid byJapan or out of funds to which Japan or anyof its local authorities contributes to an indi-vidual who is a national of Japan (other thana U.S. citizen or one admitted to the UnitedStates for permanent residence) for labor orpersonal services performed as an employeeof the Government of Japan or any of its localauthorities are exempt from U.S. income tax.

KazakstanIncome, other than a pension, paid byKazakstan, or its subdivisions or local au-thorities to an individual for government ser-vices is exempt from U.S. tax. However, theexemption does not apply if the services areperformed in the United States by a U.S.resident who either:


2) Did not become a U.S. resident solely forthe purpose of performing the services.

These exemptions do not apply to income forservices performed in connection with abusiness.

Pensions paid by Kazakstan, or its subdi-visions or local authorities for services per-formed for Kazakstan is exempt from U.S. taxunless the individual is both a resident andcitizen of the United States.

Korea, Republic ofWages, salaries, and similar income, includ-ing pensions and similar benefits, paid frompublic funds of the Republic of Korea to acitizen of Korea (other than a U.S. citizen oran individual admitted to the United States forpermanent residence) for services performedas an employee of Korea discharging gov-ernment functions are exempt from U.S. in-come tax.

Latvia Income, other than a pension, paid by or frompublic funds of Latvia, its political subdivi-sions, or local authorities to an individual forservices performed as an employee for thepaying governmental body in the dischargeof governmental functions is exempt fromU.S. income tax. However, the exemptiondoes not apply if the services are performedin the United States by a resident of theUnited States who either:



Pensions paid by or from the public fundsof Latvia, its political subdivisions, or localauthorities for services performed for Latviaare exempt from U.S. income tax unless therecipient is both a resident and citizen of theUnited States.

Lithuania Income, other than a pension, paid by or frompublic funds of Lithuania, its political subdivi-sions, or local authorities to an individual forservices performed as an employee for thepaying governmental body in the dischargeof governmental functions is exempt fromU.S. income tax. However, the exemption

does not apply if the services are performedin the United States by a resident of theUnited States who either:



Pensions paid by or from the public fundsof Lithuania, its political subdivisions, or localauthorities for services performed forLithuania are exempt from U.S. income taxunless the recipient is both a resident andcitizen of the United States.

LuxembourgWages, salaries, and similar income, andpensions, annuities, and similar benefits paidby Luxembourg, its political subdivisions, orits compulsory social security funds for ser-vices performed for Luxembourg or its poli-tical subdivisions in discharge of governmen-tal functions are exempt from U.S. incometax. These amounts are exempt only if theyare paid to individuals other than U.S. citizensor individuals admitted to the United Statesfor permanent residence.

MexicoIncome, other than a pension, paid byMexico, its political subdivisions, or local au-thorities to an individual for services per-formed for the paying governmental body isexempt from U.S. income tax. However, theexemption does not apply if the services areperformed in the United States by a U.S.resident who either:

1) Is a U.S. national, or

2) Did not become a resident of the UnitedStates solely for purposes of performingthe services.

Pensions paid by Mexico, its politicalsubdivisions, or local authorities for servicesperformed for the paying governmental bodyare exempt from U.S. income tax unless theindividual is both a resident and national ofthe United States.

These exemptions do not apply to incomeor pensions connected with commercial orindustrial activities carried on by Mexico, itspolitical subdivisions, or local authorities.

MoroccoWages, salaries, and similar income, includ-ing pensions and similar benefits, paid frompublic funds of the Kingdom of Morocco to acitizen of Morocco (other than a U.S. citizenor an individual admitted to the United Statesfor permanent residence) for labor or personalservices performed for Morocco or for any ofits political subdivisions or local authorities inthe discharge of governmental functions areexempt from U.S. income tax.

NetherlandsIncome, other than a pension, paid by theNetherlands, its political subdivisions, or localauthorities to an individual for services per-formed for the paying governmental body isexempt from U.S. income tax. However, theexemption does not apply if the services arerendered in the United States and the indi-vidual is a U.S. resident who either:



Pensions paid by the Netherlands for ser-vices performed for the Netherlands are ex-empt from U.S. income tax unless the indi-vidual is both a resident and national of theUnited States.

These exemptions do not apply to incomeor pensions for services performed in con-nection with a business carried on by theNetherlands, its political subdivisions, or localauthorities.

New ZealandIncome (other than pensions) paid by theGovernment of New Zealand, its politicalsubdivisions, or local authorities for servicesperformed in the discharge of governmentalfunctions is exempt from U.S. income tax.However, the income is not exempt if theservices are performed in the United Statesby a U.S. citizen resident in the United Statesor by a resident of the United States who didnot become a resident only to perform theservices.

Pensions paid by New Zealand in consid-eration for past governmental services areexempt from U.S. income tax unless paid toU.S. citizens resident in the United States.

These exemptions do not apply to pay-ments for services performed in connectionwith any trade or business carried on for profitby the Government of New Zealand (or itssubdivisions or local authorities).

NorwayWages, salaries, and similar income, includ-ing pensions and similar benefits paid by orfrom public funds of Norway or its politicalsubdivisions or local authorities to a citizenof Norway for labor or personal services per-formed for Norway or any of its political sub-divisions or local authorities in the dischargeof governmental functions are exempt fromU.S. income tax.

PakistanIncome, including pensions and annuities,paid to certain individuals by or on behalf ofthe Government of Pakistan or the Govern-ment of a Province in Pakistan or one of itslocal authorities for services performed in thedischarge of functions of that Government orlocal authority is exempt from U.S. incometax. To be exempt from tax, these paymentsmust be made to citizens of Pakistan who donot have immigrant status in the UnitedStates. This exemption does not apply topayments for services performed in con-nection with any trade or business carried onfor profit.

PhilippinesWages, salaries, and similar income, includ-ing pensions, annuities, and similar benefits,paid from public funds of the Republic of thePhilippines to a citizen of the Philippines (orto a citizen of another country other than theUnited States who comes to the United Statesspecifically to work for the Government of thePhilippines) for labor or personal servicesperformed as an employee of the nationalGovernment of the Philippines or any of itsagencies in the discharge of governmentalfunctions are exempt from U.S. income tax.

Page 26

PolandWages, salaries, and similar income, includ-ing pensions, annuities, and similar benefits,paid from public funds of Poland to a citizenof Poland (other than a U.S. citizen or oneadmitted to the United States for permanentresidence) for labor or personal services per-formed as an employee of the national Gov-ernment of Poland in the discharge of gov-ernmental functions are exempt from U.S.income tax.

PortugalIncome, other than a pension, paid byPortugal, its political or administrative subdi-visions, or local authorities to an individual forservices performed for the paying govern-mental body is exempt from U.S. income tax.However, the exemption does not apply topayments for services performed in theUnited States by a U.S. resident who either:



Pensions paid by Portugal for servicesperformed for Portugal are exempt from U.S.income tax unless the recipient is a residentand national of the United States.

These exemptions do not apply to incomeor pensions for services performed in con-nection with a business carried on by Portugalor its political or administrative subdivisions,or local authorities.

RomaniaWages, salaries, and similar income, includ-ing pensions, annuities, and similar benefits,paid from public funds of Romania to a citizenof Romania (other than a U.S. citizen or oneadmitted to the United States for permanentresidence) for labor or personal services per-formed as an employee of the national Gov-ernment of Romania in the discharge of gov-ernmental functions are exempt from U.S.income tax.

RussiaIncome, other than a pension, paid by Russia,its republics, or local authorities to an indi-vidual for government services is exempt fromU.S. tax. However, the exemption does notapply if the services are performed in theUnited States by a U.S. resident who either:



Pensions paid by Russia, its republics, orlocal authorities for services performed forRussia is exempt from U.S. tax unless theindividual is both a resident and citizen of theUnited States.

These exemptions do not apply to incomeor pensions for services performed in con-nection with a business.

Slovak RepublicIncome, including a pension, paid from thepublic funds of the Slovak Republic, its poli-tical subdivisions, or local authorities to aSlovak citizen for services performed in thedischarge of governmental functions is ex-

empt from U.S. income tax. This exemptiondoes not apply to income paid for servicesperformed in connection with a business car-ried on by the Slovak Republic, its politicalsubdivisions, or local authorities.

South AfricaIncome, other than a pension, paid by SouthAfrica or its political subdivisions or local au-thorities to an individual for services per-formed for the paying governmental body isexempt from U.S. income tax. However, theexemption does not apply to payments forservices performed in the United States by aresident of the United States who either:



Pensions paid by South Africa for servicesperformed for South Africa are exempt fromU.S. income tax unless the recipient is botha resident and citizen of the United States.

These exemptions do not apply to incomeor pensions for services performed in con-nection with a business carried on by SouthAfrica or its subdivisions or local authorities.

SpainIncome, other than a pension, paid by Spain,its political subdivisions, or local authorities toan individual for services performed for thepaying governmental body is exempt fromU.S. income tax. However, the exemptiondoes not apply to payments for services per-formed in the United States by a resident ofthe United States who either:



Pensions paid by Spain, its political sub-divisions, or local authorities for servicesperformed for Spain are exempt from U.S. taxunless the individual is a citizen and residentof the United States.

These exemptions do not apply to incomeor pensions for services performed in con-nection with a trade or business carried onby Spain, its subdivisions, or local authorities.

SwedenIncome, other than a pension, paid bySweden, its political subdivisions, or localauthorities to an individual for services per-formed for the paying governmental body isexempt from U.S. income tax. However, theexemption does not apply if the services areperformed in the United States by a U.S.resident who either:



Pensions paid by Sweden, its politicalsubdivisions, or local authorities for servicesperformed for Sweden is exempt from U.S.tax unless the individual is both a resident andcitizen of the United States.

These exemptions do not apply to incomeor pensions for services performed in con-nection with a business carried on bySweden, its political subdivisions, or localauthorities.

SwitzerlandIncome, other than a pension, paid bySwitzerland or its political subdivisions or lo-cal authorities to an individual for servicesperformed for the paying governmental bodyis exempt from U.S. income tax. However, theexemption does not apply to payments forservices performed in the United States by aresident of the United States who either:



Pensions paid by Switzerland for servicesperformed for Switzerland are exempt fromU.S. income tax unless the recipient is botha resident and citizen of the United States.

These exemptions do not apply to incomeor pensions for services performed in con-nection with a business carried on bySwitzerland or its subdivisions or local au-thorities.

ThailandIncome, other than a pension, paid byThailand or its political subdivisions or localauthorities to an individual for services per-formed for the paying governmental body isexempt from U.S. income tax. However, theexemption does not apply to payments forservices performed in the United States by aresident of the United States who either:



Pensions paid by Thailand for servicesperformed for Thailand are exempt from U.S.income tax unless the recipient is both a res-ident and citizen of the United States.

These exemptions do not apply to incomeor pensions for services performed in con-nection with a business carried on byThailand or its subdivisions or local authori-ties.

Trinidad and TobagoWages, salaries and similar income andpensions, annuities, and similar benefits paidby or from the public funds of the Governmentof Trinidad and Tobago to a national of thatcountry for services performed for Trinidadand Tobago in the discharge of governmentalfunctions are exempt from U.S. tax.

TunisiaIncome, other than a pension, paid byTunisia, its political subdivisions, or local au-thorities to a Tunisian citizen for personalservices performed in the discharge of gov-ernmental functions is exempt from U.S. in-come tax.

Pensions paid by Tunisia, its politicalsubdivisions, or local authorities for servicesperformed for Tunisia are exempt from U.S.income tax unless the recipient is a U.S. cit-izen.

These exemptions do not apply to incomeor pensions for services performed in con-nection with a trade or business carried onby Tunisia, its political subdivisions, or localauthorities.

Page 27

TurkeyIncome, other than a pension, paid by Turkeyor its political subdivisions or local authoritiesto an individual for services performed for thepaying governmental body is exempt fromU.S. income tax. However, the exemptiondoes not apply to payments for services per-formed in the United States by a resident ofthe United States who either:



Pensions paid by Turkey for services per-formed for Turkey are exempt from U.S. in-come tax unless the recipient is both a resi-dent and citizen of the United States.

These exemptions do not apply to incomeor pensions for services performed in con-nection with a business carried on by Turkeyor its subdivisions or local authorities.

United KingdomIncome, other than pensions, paid by theUnited Kingdom to employees for servicesperformed for the United Kingdom is exemptfrom U.S. income tax. The exemption doesnot extend to employees of a political subdi-vision or local authority of the UnitedKingdom. The exemption does not apply if theservices are performed in the United Statesand the recipient is both a citizen and a resi-dent of the United States.

Pensions paid by the United Kingdom orits political subdivisions or local authorities toindividuals for services performed in the dis-charge of governmental functions are exemptfrom U.S. income tax, unless the recipient isboth a citizen and a resident of the UnitedStates.

These exemptions do not apply to pay-ments or pensions for services performed inconnection with a business carried on by oron behalf of the United Kingdom.

Venezuela Income, other than a pension, paid byVenezuela, its political subdivisions, or localauthorities to an individual for services per-formed for the paying governmental body is

exempt from U.S. income tax. However, theexemption does not apply to payments forservices performed in the United States by aresident of the United States who either:



Pensions paid by Venezuela, its politicalsubdivisions, or local authorities for servicesperformed for Venezuela are exempt fromU.S. income tax unless the recipient is botha resident and citizen of the United States.

These exemptions do not apply to pay-ments or pensions for services performed inconnection with a business carried on byVenezuela, its political subdivisions, or localauthorities.

Explanationof TablesThe paragraphs below describe the tablesthat follow and provide additional informationthat may make the tables more useful to you.

Table 1This table lists the income tax rates on suchincome as interest, dividends, capital gains,rents, and royalties. The income code num-bers shown in this table are the same as theincome codes on Form 1042–S, ForeignPerson's U.S. Source Income Subject toWithholding.

Interest. If you are a nonresident alien whoreceives interest that is not effectively con-nected with the conduct of a U.S. trade orbusiness, you do not include the interest inincome if it is paid on deposits with banks,on accounts or deposits with certain financialinstitutions, or on certain amounts held by in-surance companies. These amounts are ex-empt from U.S. tax even though they areconsidered to be income from a U.S. source.Also exempt from U.S. tax (although consid-ered from U.S. sources) is certain portfoliointerest on obligations issued after July 18,

1984. See Publication 519 for more informa-tion.

Table 2This table lists the different kinds of personalservice income that may be fully or partly ex-empt from U.S. income tax. You must meetall of the treaty requirements before the itemof income can be exempt from U.S. incometax. The income code numbers shown in thistable are the same as the income codes onForm 1042-S, Foreign Person's U.S. SourceIncome Subject to Withholding.

Independent personal services. The term“independent personal services” generallymeans services you perform for your ownaccount if you receive the income and bearthe losses arising from those services. Ex-amples of these services are those providedby physicians, lawyers, engineers, dentists,and accountants who perform personal ser-vices as sole proprietors or partners.

Dependent personal services. Dependentpersonal services usually are those you per-form for someone else as an employee.

Table 3This table lists the countries that have taxtreaties with the United States. Some treatiesare published in the Internal Revenue Bulle-tins (I.R.B.) and the Cumulative Bulletins(C.B.), which contain official matters of theInternal Revenue Service. The columnheaded Citation shows the number of theI.R.B. or C.B. and the page on which a par-ticular treaty may be found.

Regulations implementing some treatieswere issued as Treasury Decisions (T.D.).Other treaties are explained by Treasury ex-planation. The fifth column lists the T.D.numbers and the I.R.B. or C.B. in which eachT.D. or Treasury explanation is printed.

You can subscribe to the I.R.B. or buyvolumes of the C.B. from the GovernmentPrinting Office or you are welcome to readthem in most Internal Revenue Service of-fices. Many public libraries and business or-ganizations subscribe to a commercial taxservice that publishes the treaties and regu-lations or explanations.

Page 28

Table 1. Tax Rates on Income Other Than Personal Service Income Under Chapter 3, Internal Revenue Code, and Income Tax TreatiesIncome Code Number

Country of Residence of Payee

Name Code

1 2 3 6 7 9 10 11 12 13 14 21

InterestPaid by

U.S.ObligorsGeneral

Intereston RealProperty

Mortgages

InterestPaid to a

ControllingForeign

Corpora-tion

Dividends Paid by a

U.S.Corpora-

tionGenerala

U.S.Subsidiary

toForeignParent

Corpora-tion a

CapitalGainsv

IndustrialRoyalties

Copyright Royalties

MotionPictures

andTelevision Other

RealPropertyIncome

andNatural

ResourcesRoyalties v

Pensionsand

Annuities

SocialSecurity

Payment u

ASAU

BBBE

CA

g10h0

g5g15

g10

g1030

g5g15

g,ff10

g10h0

g5g15

g10

g15h15

g,x15g15

g, x15

g15b,h5

b,g,x5b,g5

g,x5

3030

g,l0e,g,l0

r30

g10h0

g5g0

g0

g10h10

g5h0

g10

g10h0

g5g0

g0

30 d0

d,f0

30

3030

30

d0

d,f0

15

3030

3030

0CH

CYEZ

DA

g10 g10 g10

n0 30 30g10 g10 g10

g0 g,ff0 g0

h0 h0 h0

g10

30g15

g,x15

h15

g10

30b,g5

b,g,x5

b5

30

30

o0g,l0g,l0

g,w10

0g0

g10

h0

g10

0g0g0

h0

g10

0g0g0

h0

30 d, mm0

d,f0303030

30

30

d,f0

d0

30

303030

30EG

FIFR

GMGR

30

3030

3030303030

30

303030

303030

3030303030

3030303030

0

3030

0303030

ee30

30000

30

030

30

3030303030

3030303030

h15

g0g0

g0h0

30

g0g,ff0

g0h0

h15

g0g0

g030

h15

g,x15g,x15

g,x1530

b,h5

b,g,x5g,x5

b,g,x530

e,h,l0

g,l0g,l0

g,l030

h0

g5g5

g0h0

h0

g0g0

g,dd030

g15

g0g0

g0h0

d,f0

d,f0

d,f0

d0d0

HUICIN

IDEI

g0g0

g,aa15

g15g0

g0g0

g,aa15

g15g,ff0

g0g0

g,aa15

g15

g15g15

g,x25

g15g,x15

b,g5b,g5

b,g,x15

g15g,x5

g,l0e,g,l0

30

g,l,z0

g0g0

g,bb10

g,bb10g0

g030

g15

g15g0

g0g0

g15

g15g0

d,f0

d,f0

d,f0

d,f,g15d,f0

ISITJM

JAKZ

g,aa,ii171⁄2g15g121⁄2

g10g10

g,aa,ff,ii171⁄2g15g121⁄2

g10g,ff10

g,aa,ii171⁄2g15g121⁄2

g10g10

g,x25g15g15

g15g,gg15

b,g,x121⁄2b,g5

b,g10

b,g10g,gg5

e,g,cc0g,l0g,l0

e,g,l0g,l0

g15g,s10

g10

g10g,jj10

g10g8

g10

g10g10

g10g5

g10

g10g10

f0

d,f,p0

d,f0

d0d,f0

KS

LUMXMONLNZ

NOPKRPPLPO

g12

h0g,qq15

g15g0

g10

g030

g15g0

g10

g12

g,ff,qq15g15

30

g0g10

g030

g15g0

g,ff10

g12

g, qq15g15

h0

g0g10

g030

g15g0

g10

g15

h15g,x10

g15g,x15

g15

g1530

g25g15

g,x15

b,g10

b,h5b,g,x5b,g10b,g,x5

g15

g15b,h15b,g20

b,g5b,g,x10

e,g,l0

g,hh0

e,g,l0

30g,l0

e,g,l0

g,l0

e,g,l030g,l0

g,l0

g15

h0g10h10

g0g10

g0h0

g15g10g10

g10

h0g10g10

g,dd0g10

h030

g15g10g10

g10

h0g10g10

g0g10

g0h0

g15g10g10

d,f0

d0d,t0d,f0

d,f,t0d0

d,f0d,j0

q3030d,f0

AustraliaAustria (before 4-1-98)

BarbadosBelgium

CanadaChina, People’s Rep. ofCommonwealth of

Independent StatesCyprusCzech Republic

DenmarkEgypt

FinlandFrance

GermanyGreeceHungaryIcelandIndia

IndonesiaIrelandIsraelItalyJamaica

JapanKazakstanKorea, Rep. of

Luxembourgk

MexicoMoroccoNetherlandsNew Zealand

NorwayPakistanPhilippinesPolandPortugal

AU g,m0 g,m0 g,x15 g,x5 g0 g10 g0 30 0 30Austria (beginning 4-1-98) g,m,ff0 g,l0

g0 g,l0 30

Estonia

Latvia

EN

LGLH

g,oo10

g,oo10g,oo10

g,ff,oo10

g,ff,oo10g,ff,oo10

g,oo10

g,oo10g,oo10

g,x15

g,x15g,x15

b,g,x5

b,g,x5b,g,x5

g,l0 g,bb5 g10

g10g10

g10

g10g10

30

3030

d,f0d,f0Lithuania

g,l0g,l0

g,bb5g,bb5

d,f0 30

3030

Page

29

Table 1. Tax Rates on Income Other Than Personal Service Income Under Chapter 3, Internal Revenue Code, and Income Tax TreatiesIncome Code Number

Country of Residence of Payee

Name Code

1 2 3 6 7 9 10 11 12 13 14 21

InterestPaid by

U.S.ObligorsGeneral

Intereston RealProperty

Mortgages

InterestPaid to a

ControllingForeign

Corpora-tion

Dividends Paid by a

U.S.Corpora-

tionGenerala

U.S.Subsidiary

toForeignParent

Corpora-tion a

CapitalGainsv

IndustrialRoyalties

Copyright Royalties

MotionPictures

andTelevision Other

RealPropertyIncome

andNatural

ResourcesRoyalties v

Pensionsand

Annuities

SocialSecurity

Payment u

Spain

Sweden

Trinidad & TobagoTunisia

SP

SW

TDTS

g10

g0

30g15

g10

g,ff0

30g15

g10

g0

30g15

g,x15

g,x15

30g,x20

b,g,x10

g,x5

30b,g,x14

g,l0

g,l0

30g,l0

g,y8

g0

g15g,bb10

g,y8

g0

30g15

g,y5

g0

g0g15

30 d,f0

30

3030

d0

d,f0f0

30

30

3030

United Kingdom

Other Countries

UK g0 30

30

d,f0

30

030

30 30 30 30 30

g0 g0 g15 b,g5

30 30 30 30

30 g0 h0 g0

Switzerland g,m0 g,m,ff0 g,m0 g,x15 g,x5 g0 g0 g0 d030 15l0Thailand TH g,aa15 g,aa,ff15 g,aa15 g,x15 g,x10 30 bb8 5 ll15 30 d,f0 30

Turkey TU g,i,aa15 g,i,aa,ff15 g,i,aa15 g,x20 g,x15 g,l0 bb5 10 10 30 d0 30

30 30LO g0 g,ff0 g0 g,x15 b,g,x5 g,l0 g10 g0 g0 d,f0Slovak Republic30 30SF g,m0 g,m,ff0 g,m0 g,x15 g,x5 l0 g0 g0 g0 d,kk15South Africa

3030

030

RORS

g10g0

g10g,ff0

g10g0

g10g,gg10

g10b,g,gg5

e,g,l0g,l0

g15g0

g10g0

g10g0

d,f0d0

RomaniaRussia

VE g,ff,nn,oo10 g,ff,nn,oo10 g,pp15 b,g,pp5 g10 d,mm0g,nn,oo10Venezuela g,l0 g,bb5 g10

SZ

3030

Page 30

a

b

c

d

e

f

g

h

No U.S. tax is imposed on a dividend paid by a U.S. corporation thatreceived at least 80% of its gross income from an active foreignbusiness for the 3-year period before the dividend is declared.The reduced rate applies to dividends paid by a subsidiary toa foreign parent corporation that has the required percentageof stock ownership. In some cases, the income of the subsidiarymust meet certain requirements (e.g., a certain percentage ofits total income must consist of income other than dividendsand interest). For Italy, the reduced rate is 10% if the foreigncorporation owns 10% to 50% of the voting stock (for a12-month period) of the company paying the dividends. ForPortugal, the reduced rate is 5% for dividends paid after 1999.The exemption or reduction in rate applies only if the recipientis subject to tax on this income in the country of residence.Otherwise, a 30% rate applies.Exemption does not apply to U.S. Government (federal, state,or local) pensions and annuities; a 30% rate applies to thesepensions and annuities. For this purpose, railroad retirement tier2, dual, and supplemental benefits are not considered U.S.Government pensions or annuities. U.S. Government pensionspaid to an individual who is both a resident and national ofChina, Estonia, Finland, France (if not a U.S. national), Hungary,India, Ireland, Latvia, Lithuania, Mexico, the Netherlands,Portugal, Russia, South Africa, Spain, Switzerland, Thailand,Turkey, the United Kingdom, or Venezuela are exempt from U.S.tax. U.S. Government pensions paid to an individual who is botha resident and citizen of Kazakstan, New Zealand, or Swedenare exempt from U.S. tax.The treaty exemption that applies to U.S. source capital gainsincludes capital gains under section 871(a)(2) of the InternalRevenue Code if they are received by a nonresident alien whois in the U.S. for no more than 183 days. (182 days for Belgium,Egypt, and Israel.)Includes alimony.Under the treaty the exemption or reduction in rate does notapply if the recipient has a permanent establishment in theUnited States and the property giving rise to the income iseffectively connected with this permanent establishment. Undercertain treaties, exemption or reduction in rate also does notapply if the property producing the income is effectivelyconnected with a fixed base in the United States from whichthe recipient performs independent personal services. Even withthe treaty, if the income is not effectively connected with a tradeor business in the United States by the recipient, the recipientwill be considered as not having a permanent establishment inthe United States under Internal Revenue Code section 894(b).Under the treaty the exemption or reduction in rate does notapply if the recipient is engaged in a trade or business in theUnited States through a permanent establishment that is in theUnited States. However, if the income is not effectivelyconnected with a trade or business in the United States by therecipient, the recipient will be considered as not having apermanent establishment in the United States to apply thereduced treaty rate to that item of income.

i

l

m

n

o

p

q

r

s

t

u

v

Contingent interest that does not qualify as portfolio interest istreated as a dividend and is subject to the rate under column6 or 7.

Exemption does not apply to gains from the sale of real property.

The exemption applies only to interest on credits, loans, andother indebtedness connected with the financing of tradebetween the United States and the C.I.S. member. It does notinclude interest from the conduct of a general bankingbusiness.The exemption applies only to gains from the sale or otherdisposition of property acquired by gift or inheritance.The exemption does not apply if the recipient was a residentof the United States when the pension was earned or whenthe annuity was purchased.Annuities paid in return for other than the recipient’s servicesare exempt.Generally, if the property was owned by the Canadianresident on September 26, 1980, not as part of the businessproperty of a permanent establishment or fixed base in theU.S., the taxable gain is limited to the appreciation after1984. Capital gains on personal property not belonging to apermanent establishment or fixed base of the taxpayer in theU.S. are exempt.Under the treaty, the reduced rate for royalties with respect totangible personal property is 7%.The exemption does not apply if (1) the recipient was a U.S.resident during the 5-year period before the date of payment,(2) the amount was paid for employment performed in theUnited States, and (3) the amount is not a periodic payment,or is a lump-sum payment in lieu of a right to receive anannuity.Applies to 85% of the social security payments received fromthe U.S. Government. The effective rate on the total socialsecurity payments received is 85% of the rate shown in thetable. These rates also apply to the social security equivalentportion of tier 1 railroad retirement benefits (income code 22)received from the U.S. The remainder of tier 1, all of tier 2,dual, and supplemental railroad retirement benefits (incomecode 23) are taxed as shown in column 14, “Pensions andAnnuities.”Gains on the disposition of U.S. real property interests areconsidered effectively connected with a U.S. trade orbusiness and thus are subject to graduated rates of tax ratherthan the flat percentage shown in this column.

The rate is 15% (30% for Switzerland) for contingent interestthat does not qualify as portfolio interest.

w

x

y

z

aa

bb

cc

dd

ee

ff

gg

hh

ii

jj

Tax imposed on 70% of gross royalties for rentals ofindustrial, commercial, or scientific equipment.The rate in column 6 applies to dividends paid by a regulatedinvestment company (RIC) or a real estate investment trust(REIT). However, that rate applies to dividends paid by a REITonly if the beneficial owner of the dividends is an individualholding less than a 10% interest (25% in the case ofNetherlands, Portugal, Spain, and Tunisia) in the REIT.Royalties not taxed at the 5% or 8% rate are taxed at a 10%rate, unless footnote (g) applies.The exemption does not apply if the recipient of the gain isan individual who is present in the United States for morethan 119 days during the year.The rate is 10% if the interest is paid on a loan granted by abank or similar financial institution. For Thailand, the 10% ratealso applies to interest from an arm’s length sale on credit ofequipment, merchandise, or services.

This is the rate for royalties for the use of, or the right to use,industrial, commercial, and scientific equipment. The rate forroyalties for information concerning industrial, commercial andscientific know-how is subject to the rate in column 12.The exemption does not apply to gain from the sale or otherdisposition of property described in Article 14(2)(c) (copyrightsof literary, artistic, or scientific works).The exemption does not apply to cinematographic items, orworks on film, tape, or other means of reproduction for use inradio or television broadcasting.U.S. social security benefits paid to individuals who are bothresidents and nationals of India, are exempt from tax if they arefor services performed for the United States, its subdivisions,or local authorities.Exemption or reduced rate does not apply to an excessinclusion for a residual interest in a real estate mortgageinvestment conduit (REMIC).The rate in column 6 applies to dividends paid by a regulatedinvestment company (RIC). Dividends paid by a real estateinvestment trust (REIT) are subject to a 30% rate.The exemption does not apply to gains from the sale of U.S.real property. However, for U.S. real property that was ownedcontinuously since June 18, 1980, by the Netherlandsresident, the taxable gain may be limited to the appreciationafter 1984. For details, see Article 14(2) of the treaty.An election can be made to treat this interest income as if itwere industrial and commercial profits taxable under article 8of the treaty.If the payments were for the use of, or the right to use,industrial, commercial, or scientific equipment, an electionmay be made to compute the tax on a net basis as if suchincome were attributable to a permanent establishment orfixed base in the U.S.

kk The reduced rate does not apply if the distribution is subject toa penalty for early withdrawal. Annuities that were purchasedwhile the annuitant was not a resident of the United States arenot taxable in the United States.

ll The rate is 5% for royalties on the use of any copyright of literary,artistic, or scientific work, including software.

mm Does not apply to annuities.nn The rate is 4.95% if the interest is beneficially owned by a

financial institution (including an insurance company).

qq The rate is 4.9% for interest derived from (1) loans granted bybanks and insurance companies and (2) bonds or securities thatare regularly and substantially traded on a recognized securitiesmarket. The rate is 10% for interest not described in thepreceding sentence and paid (i) by banks or (ii) by the buyer ofmachinery and equipment to the seller due to a sale on credit.

oo The rate is 15% for interest determined with reference to (a) receipts,sales, income, profits or other cash flow of the debtor or a relatedperson, (b) any change in the value of any property of the debtoror a related person, or (c) any dividend, partnership distribution orsimilar payment made by the debtor or related person.

pp The rate in column 6 applies to dividends paid by a regulatedinvestment company (RIC) or real estate investment trust (REIT).However, that rate applies to dividends paid by a REIT only ifthe beneficial owner of the dividends is (a) an individual holdingnot more than a 10% interest in the REIT, (b) a person holdingnot more than 5% of any class of the REIT’s stock and thedividends are paid on stock that is publicly traded, or (c) aperson holding not more than a 10% interest in the REIT andthe REIT is diversified.

j

k

Exemption is not available when paid from a fund under anemployees’ pension or annuity plan, if contributions to it aredeductible under U.S. tax laws in determining taxable incomeof the employer.Exemption from or reduction in rate of tax does not apply toincome of holding companies entitled to special tax benefitsunder the laws of Luxembourg.

Page

31

Table 2. Compensation for Personal Services Performed in United States Exempt from U.S. Income Tax Under Income Tax Treaties

Country(1)

Code1

(2)

Category of Personal Services

Purpose(3)

MaximumPresence

in U.S.(4)

Required Employer or Payer(5)

MaximumAmount of

Compensation(6)

Treaty ArticleCitation

(7)Australia

Barbados

Belgium

Canada

1620172019

16

20

1720

19

151620171819

1617

19

Any contractor

Any foreign resident

No limit$10,000

14171517

20

Any contractor



$10,000No limit

No limit

Any foreign contractorAny U.S. contractorAny contractor

Any foreign residentAny U.S. or foreign resident


No limit

No limit

$5,000$250 per dayor $4,000 p.a.6

$5,000$250 per dayor $4,000 p.a.6

1414

1715

17

20

Any U.S. or foreign resident5

Any contractorAny contractorBelgian residentU.S. educational institution


Other foreign or U.S. residentBelgian resident

Belgian resident

U.S. Government or its contractor

No limitNo limit

No limitNo limit

No limit

$3,000

$5,000

$5,000$2,000 p.a.

$10,000

21(1)14(2)(a)(b)14(2)(c)1520

21(1)21(2)(b)21(1)21(2)(a)

21(3)

Any contractor No limit12

Any U.S. or foreign resident $10,000Any foreign resident15 No limit12

Any foreign resident No limit

XIVXVXV

XX

Independent personal services22

Public entertainmentDependent personal services15

Public entertainment15

Studying and training:Remittances or allowances10

Independent personal services7,22

Public entertainment

Dependent personal services7,15


Studying and training:20

Remittances or allowances10

Scholarship or fellowship grantIndependent personal services22


Teaching4

Studying and training:Remittances or allowancesCompensation during training

Compensation while gaining experience2

Compensation under U.S.Government program


Dependent personal services


183 days183 days183 days183 days

No limit

89 days89 daysNo limit

183 daysNo limit

No limit

5 years182 days90 days182 days2 years

5 years12 consec. mo.5 years12 consec. mo.

1 year

No limitNo limit183 days

No limit

Austria (beginning 1-1-99) 1620172019

Any contractorAny contractor

Any U.S. or foreign resident

1417

17

20Any foreign resident

No limit$20,00025

No limit$20,00025

No limit

15




Remittances or allowances

No limitNo limit183 daysNo limit

3 years11

Public entertainmentAny foreign resident

China, People’s Rep. of 15162017201819

Any U.S. or foreign resident5 No limitAny contractor No limitAny contractor No limitAny foreign resident No limitAny U.S. or foreign resident No limitU.S. educational or research institute No limit

Any foreign resident No limit

Any U.S. or foreign resident $5,000 p.a.

20(b)1316141619

20(a)

20(c)





Teaching4

Studying and training:Remittances or allowancesCompensation during training or while

gaining experience

No specific limit183 daysNo limit183 daysNo limit3 years

No specific limit

No specific limit

Page 32

Table 2. ( Continued)

Country(1)

Code1

(2)


Purpose(3)

MaximumPresence

in U.S.(4)


MaximumAmount of

Compensation(6)


(7)Commonwealth of

Independent States

Cyprus

Czech Republic

Denmark

1516171819

15

1620

17

20

19

151620172018

19

16

17

1819

Scholarship or fellowship grantIndependent personal servicesDependent personal servicesTeaching4,18

Studying and training:Remittances or allowancesCompensation while gaining experienceCompensation under U.S.

Government program

Scholarship or fellowship grant



Dependent personal services15

Directors’ feesPublic entertainment

Studying and training:Remittances or allowances

Compensation during training

Compensation while gaining experience2



Public entertainmentDependent personal services7,15

Public entertainmentTeaching4,35

Studying and training:Remittances and allowancesCompensation during trainingCompensation while gaining experience2


Independent personal services


TeachingStudying and training:


183 days183 days

5 years

2 years

1 year

Generally, 5years182 days

12 consec. mos.

180 days90 days

5 years

1 year

No limit

182 daysNo limitNo limit

Generally, 5yearsGenerally, 5years1 year

1 year

5 years183 days183 days183 days183 days2 years

5 years5 years

1 year

180 days90 days2 years

No limit

Any U.S. or foreign residentAny U.S. or foreign contractorAny U.S. or foreign residentAny U.S. educational or scientific institution

Any U.S. or foreign residentC.I.S. resident



Any contractor

U.S. corporation


Cyprus resident


Any contractor





Any contractorAny contractorAny foreign residentAny foreign residentAny U.S. educational or research

institution

Any foreign residentAny U.S. or foreign residentCzech resident

U.S. Government

Danish resident contractorOther foreign or U.S. resident contractorDanish residentOther foreign or U.S. residentU.S. educational institution


Limited19

No limitNo limitNo limit

Limited19

No limit19

No limit

No limit

No limit$500 per day or$5,000 p.a.6

No limitNo limit21

$500 per day or$5,000 p.a.6

No limit

$2,000 p.a.$7,500

$10,000

$20,000 p.a.30

$5,000 p.a.$8,000

$3,000

No limitNo limit

$3,000

$20,000 p.a.30No limit

No limit

No limit

$10,000

No limit

No limit

No limit

No limit

VI(1)VI(2)VI(2)VI(1)

VI(1)VI(1)

VI(1)

21(1)17

19(1)1820

19(1)

21(1)

21(1)21(2)

21(3)

21(1)14181518

21(5)

21(1)21(1)21(2)

21(3)

XIXIXIXIXIV

XIII

Page

33


Country(1)

Code1

(2)


Purpose(3)

MaximumPresence

in U.S.(4)


MaximumAmount of

Compensation(6)


(7)Egypt

Finland

France

Germany

15162017201819

1620172019

15162017201819

15162017201819

Scholarship or fellowship grantIndependent personal services


Public entertainmentTeaching4

Studying and training:Remittances or allowancesCompensation during trainingCompensation while gaining experience2


Generally, 5 years89 daysNo limit89 daysNo limit2 years

Generally, 5 yearsGenerally, 5 years12 consec. mos.

1 year


Any contractorAny contractorEgyptian residentAny U.S. or foreign residentU.S. educational institution

Any foreign residentU.S. or any foreign residentEgyptian resident


No limitNo limit$400 per dayNo limit$400 per dayNo limit

No limit$3,000 p.a.$7,500

$10,000

23(1)1517161722

23(1)23(1)23(2)

23(3)



Public entertainmentStudying and training:



No limit

Any contractorAny contractorAny foreign residentAny U.S. or foreign resident


No limit

No limit

No limit

$20,000 p.a.25

$20,000 p.a.25

14171517

20





Remittances or allowancesCompensation during study or

training

Compensation while gaining experience

5 years40

No limitNo limit183 daysNo limit2 years40

5 years40

12 consec. mos.5 years12 consec. mos.


Any contractorAny contractorAny foreign residentAny U.S. or foreign residentU.S. educational or research institution


French residentOther foreign or U.S. residentFrench resident2

No limitNo limit$10,00030

No limit$10,00030

No limit

No limit

$8,000$5,000 p.a.$8,000

21(1)1417151720

21(1)

21(2)21(1)21(2)

Scholarship or fellowship grantIndependent personal services7,22




Teaching4


Compensation during study or trainingCompensation while gaining experience2

No limitNo limitNo limit183 days183 days2 years

No limit4 years1 year


Any contractorAny contractorAny foreign residentAny foreign residentU.S. educational or research institution

Any foreign residentAny U.S. or foreign residentAny German enterprise or foreign

organization or institution

No limit 20(3)No limit 14$20,000 p.a.30 17No limit 15$20,000 p.a.30 17No limit 20(1)

No limit 20(2)$5,000 p.a. 20(4)

$10,00028 20(5)

Estonia 15

17

19

No limit

No limit

No limit

Scholarship or fellowship grants4



5 years

183 days

5 years

20 Public entertainment


No limit

No limitAny foreign residentAny contractor



$20,0009

$20,0009

20(1)

171517

20(1)

16 No limitIndependent personal services22 Any contractor 14


Compensation while gainingexperience2

Compensation under U.S. Gov’t.program

183 days

1 year

12 consec. mos.

12 consec. mos.5 years


Estonian resident

Estonian resident

Other foreign or U.S. resident


$8,000$5,000 p.a.

$8,000

$10,000

20(2)20(1)

20(2)

20(3)

Page 34


Country(1)

Code1

(2)


Purpose(3)

MaximumPresence

in U.S.(4)


MaximumAmount of

Compensation(6)


(7)

Iceland

India

Indonesia

151620171819

162017201819

15162017201819

Scholarship and fellowship grantIndependent personal services22


Teaching4




5 years5 years12 consec. mo.

1 year


Any contractorAny contractorIceland resident16

U.S. educational institution

Any foreign residentU.S. or any foreign residentIceland resident


No limitNo limit$100 per dayNo limitNo limit

No limit$2,000 p.a.$5,000

$10,000

22(1)18181921

22(1)22(1)22(2)

22(3)





Teaching4


89 days89 days183 days183 days2 years

No limit

Any contractorAny contractorAny foreign residentAny foreign residentU.S. educational institution

Any foreign resident27

No limit$1,500 p.a.26

No limit


No limit

1518161822

21(1)

Scholarship and fellowship grant 5 years Any U.S. or foreign resident5

Independent personal services22 119 days Any contractorPublic entertainment No limit Any contractor

Dependent personal services15 119 days Any foreign residentPublic entertainment No limit Any U.S. or foreign resident

Teaching4 2 years U.S. educational institutionStudying and training:

Remittances or allowances 5 years Any foreign residentCompensation during trainingCompensation while gaining experience

5 years Any foreign or U.S. resident12 consec. mo. Any U.S. or foreign resident

No limitNo limit$2,000 p.a.25


No limit

No limit$2,000 p.a.$7,500

19(1)1517161720

19(1)19(1)19(2)

Ireland 16

17

19





No limit

183 daysNo limit

1 year11

Any contractor



No limit 14

1517

20

No limit$20,00025

No limit



No limit Any contractor $20,00025 17

Greece

Hungary

16

17

1819

16171819

Independent personal services 183 days183 days183 days183 days3 years

No limit




Greek resident contractor


U.S. educational institutionOther foreign or U.S. residentGreek residentOther foreign or U.S. resident contractor

No limit$10,000No limit

No limit

No limit

$10,000

XXXXXII

XIII



Teaching4



183 days

2 years

No limit

183 daysAny contractorAny foreign residentU.S. educational institution


No limit 13No limit 14No limit 17

No limit 18(1)

Page

35


Country(1)

Code1

(2)


Purpose(3)

MaximumPresence

in U.S.(4)


MaximumAmount of

Compensation(6)


(7)

Italy

Jamaica

Japan

Kazakstan

162017201819

16

20

1720

1819

151620171819

15161719





183 days90 days183 days90 days2 years

No limit

Any contractorAny contractorAny foreign residentAny U.S. or foreign residentU.S. educational institution




No limit

No limit

1417(1)1517(1)20

21





Directors’ feesTeaching4



Compensation during studyCompensation while gaining experience2

89 days89 daysNo limit

183 daysNo limit

No limit2 years

No limit12 consec. mo.12 consec. mo.

Any foreign contractorAny U.S. contractorAny contractor


U.S. residentU.S. educational institution

Any foreign residentJamaican residentJamaican resident

No limit$5,000 p.a.$400 per dayor $5,000 p.a.6

$5,000 p.a.$400 per dayor $5,000 p.a.6

$400 per day6

No limit

No limit$7,500 p.a.$7,500 p.a.

1414

1815

181622

21(1)21(2)21(2)



Teaching4





1 year


Any contractorAny contractorJapanese resident16


Any foreign residentU.S. or any foreign residentJapanese resident



No limitNo limit


$5,0006

$10,0006

20(1)17171819

20(1)20(1)20(2)

20(3)

Scholarship or fellowship grant44 5 years31 Any U.S. or foreign resident5

Independent personal services22 183 days Any contractorDependent personal services7,15 183 days Any foreign residentStudying and training:4

Remittances or allowances 5 years Any foreign resident

No limit 19No limit 14No limit 15

No limit 19

Israel 15162017201819

Scholarship and fellowship grantIndependent personal services



Studying and training:Remittances or allowancesCompensation during study or

trainingCompensation while gaining experience2


5 years Any U.S. or foreign resident5

182 days Any contractorNo limit Any contractor182 days Israeli resident16

No limit Any U.S. or foreign resident2 years U.S. educational institution

5 years Any foreign resident

5 years Any U.S. or foreign resident12 consec. mo. Israeli resident

1 year U.S. Government or its contractor

No limitNo limit

No limit

No limit

No limit

$3,000 p.a.$7,500

$10,000

$400 per day26

$400 per day26

24(1)1618171823

24(1)

24(1)24(2)

24(3)

Page 36


Country(1)

Code1

(2)


Purpose(3)

MaximumPresence

in U.S.(4)


MaximumAmount of

Compensation(6)


(7)

Luxembourg 1516

17

1819

Scholarship or fellowship grantIndependent personal services


Teaching8



XIV(1)XIIXIIXIIXIIXIII

XIV(1)XIV(1)XIV(2)

XIV(3)

Mexico 1620172019





14181518

21

No limitNo limit$3,000No limit$3,000No limit


$10,000



No limit

Any foreign resident5

Luxembourg resident43

Any U.S. or foreign residentLuxembourg resident43

Any U.S. or foreign residentU.S. educational institution

Any foreign residentAny foreign residentAny foreign resident

U.S. Government, its contractor, or aforeign resident



No limit180 days180 days180 days180 days2 years

No limit1 year1 year

1 year

183 daysNo limit183 daysNo limit

No limit

Korea, Rep. of 1516171819

Scholarship or fellowship grant 5 years Any U.S. or foreign resident5

Independent personal services22 182 days Any contractorDependent personal services15 182 days Korean resident16

Teaching4 2 years U.S. educational institutionStudying and training:

Remittances or allowances 5 years Any foreign residentCompensation during trainingCompensation while gaining experience2


5 years Any foreign or U.S. resident1 year Korean resident

1 year U.S. Government or its contractor

No limit 21(1)$3,000 p.a. 18$3,000 p.a. 19No limit 20

No limit 21(1)$2,000 p.a. 21(1)$5,000 21(2)

$10,000 21(3)

Latvia 15

17

19

No limit

No limit

No limit




5 years

183 days

5 years



No limit




$20,0009

$20,0009

20(1)

171517

20(1)





183 days

1 year

12 consec. mos.



Latvian resident

Latvian resident



$8,000$5,000 p.a.

$8,000

$10,000

20(2)20(1)

20(2)

20(3)

Lithuania 15

17

19

No limit

No limit

No limit




5 years

183 days

5 years



No limit




$20,0009

$20,0009

20(1)

171517

20(1)





183 days

1 year

12 consec. mos.



Lithuanian resident

Lithuanian resident



$8,000$5,000 p.a.

$8,000

$10,000

20(2)20(1)

20(2)

20(3)

Page

37


Country(1)

Code1

(2)


Purpose(3)

MaximumPresence

in U.S.(4)


MaximumAmount of

Compensation(6)


(7)

Pakistan 1516171819

XIII(1)XIXIXII

XIII(1)XIII(1)XIII(2)

XIII(3)




Remittances or allowancesCompensation during trainingCompensation while gaining experience2

Compensation while under U.S.Government program

No limit183 days183 days2 years

No limitNo limit1 year

No limit

Pakistani nonprofit organizationPakistani resident contractorPakistani residentU.S. educational institution

Any foreign residentU.S. or any foreign residentPakistani resident

U.S. Government, its contractor, or anyforeign resident employer

No limitNo limitNo limitNo limit

No limit$5,000 p.a.$6,000

$10,000

Morocco

Netherlands

New Zealand

15161719

15162017201819

1620172019



Studying and training:Remittances or allowancesCompensation during training

181415

1818

Scholarship or fellowship grant33





Remittances or allowancesCompensation while gaining experienceCompensation while recipient of

scholarship or fellowship grant

22(2)1518161821(1)

22(1)22(1)

22(2)






14171517

20

No limit$5,000No limit

No limit$2,000 p.a.



No limit

No limit$2,000 p.a.

$2,000 p.a.36

No limit$10,00025

No limit$10,00025

No limit


Any contractor12

Moroccan resident12, 16

Any foreign residentU.S. or any foreign resident


Any contractorAny contractorAny foreign residentAny foreign residentU.S. educational institution



Any contractorAny contractorAny foreign residentAny foreign resident


5 years182 days182 days

5 years5 years

3 yearsNo limitNo limit183 days183 days2 years

No limitNo limit

3 years

183 days183 days183 days183 days

No limit

Norway 151620171819

16(1)13131415

16(1)16(1)16(2)

16(3)


Public entertainmentDependent personal servicesTeaching4





1 year


Any contractorAny contractorNorwegian resident16


Any foreign residentU.S. or any foreign residentNorwegian resident


No limitNo limit$10,000 p.a.No limitNo limit

No limit$2,000 p.a.$5,000

$10,000

Page 38


Country(1)

Code1

(2)


Purpose(3)

MaximumPresence

in U.S.(4)


MaximumAmount of

Compensation(6)


(7)

Romania

Russia

15162017201819

15161719








Dependent personal services7,15,32


Remittances

20(1)1414151519

20(1)20(1)20(2)

20(3)181314

18

No limitNo limit$3,000No limit$2,999.99No limit

No limit$2,000 p.a.$5,000

$10,000No limitNo limitNo limit

No limit


Any contractorAny contractorRomanian residentRomanian residentU.S. educational institution

Any foreign residentU.S. or any foreign residentRomanian resident

U.S. Government or its contractorAny U.S. or foreign resident5

Any contractorAny foreign resident



5 years5 years1 year

1 year5 years31

183 days183 days

5 years31

Philippines

Poland

1516

20

1720

1819

1516171819



22(1)1515

17Dependent personal services15


17Teaching4,38 21Studying and training:

Remittances or allowancesCompensation during studyCompensation while gaining experience2


22(1)22(1)22(2)

22(3)

Scholarship or fellowship grantIndependent personal servicesDependent personal services15

Teaching4



18(1)151617

18(1)18(1)18(2)

18(3)

5 years89 days89 daysNo limit

89 daysNo limit

2 years


1 year

5 years182 days182 days2 years

5 years5 years1 year

1 year


Any foreign contractorAny U.S. residentAny contractor

Any Philippines resident16



Any foreign residentAny U.S. or foreign residentPhilippines resident



Any contractorAny foreign residentU.S. educational institution

Any foreign residentU.S. or any foreign residentPolish resident


No limitNo limit$10,000 p.a.$100 per dayor $3,000 p.a.No limit$100 per dayor $3,000 p.a.No limit

No limit$3,000 p.a.$7,500 p.a.

$10,000 p.a.

No limitNo limitNo limitNo limit

No limit$2,000 p.a.$5,000

$10,000

Portugal 15162017201819





Remittances or allowancesCompensation during study or

training

Compensation while gaining experience

23(1)1519161922

23(1)

23(2)23(1)23(2)



No limit

No limit

$8,000$5,000 p.a.$8,000


Any contractorAny contractorAny foreign residentAny U.S. or foreign residentU.S. educational institution


Portuguese residentOther foreign or U.S. residentPortuguese resident2

5 years182 daysNo limit183 daysNo limit2 years

5 years

12 consec. mos.5 years12 consec. mos.

Page

39


Country(1)

Code1

(2)


Purpose(3)

MaximumPresence

in U.S.(4)


MaximumAmount of

Compensation(6)


(7)

Switzerland 1620172019



Public entertainmentStudying and training:10


14171517

20

No limit$10,00025

No limit$10,00025

No limit




No limit

Thailand16

17

1819



Teaching or research4,38


1515

1619

23

22(1)


Compensation during trainingCompensation while gaining experienceCompensation under U.S.

Government program

22(1)

22(1)22(2)

22(3)

No limit$10,000No limit45

No limit

No limit

No limit$3,000 p.a.$7,500

$10,000


Any foreign contractor


Any foreign residentAny U.S. or foreign residentThai resident2

U.S. Government

5 years89 days89 days

183 daysNo limit

2 years

5 years5 years12 consec. mos.

1 year


No limit20 Public entertainment

Any U.S. resident

Any contractor



$100 per dayor $3,000 p.a.9

$100 per dayor $3,000 p.a.9

19

Slovak Republic

South Africa

15162017201819

1620172019










21(1)1418151821(5)

21(1)21(1)21(2)

21(3)14171517

20



No limit

No limit$5,000 p.a.$8,000

$10,000No limit$7,50030

No limit$7,50030

No limit


Any contractorAny contractorAny foreign residentAny foreign residentAny U.S. educational or research institution

Any foreign residentAny U.S. or foreign residentSlovak resident

U.S. GovernmentAny contractorAny contractorAny foreign residentAny U.S. or foreign resident



5 years5 years12 consec. mos.

1 year

No limit183 daysNo limit

1 year11

Spain 151620172019




Remittances or allowancesCompensation during trainingCompensation while gaining experience2

22(1)15191619

22(1)22(1)22(2)



No limit$5,000 p.a.$8,000




Spanish resident

5 yearsNo limitNo limit183 daysNo limit



183 days

Sweden 1620172019





14181518

21

No limit$6,00042

No limit$6,00042

No limit




No limit

Page 40


Country(1)

Code1

(2)


Purpose(3)

MaximumPresence

in U.S.(4)


MaximumAmount of

Compensation(6)


(7)Trinidad and Tobago

16

17

1819



Teaching4


1717171718

19(1)


Compensation during trainingCompensation during professional trainingCompensation while gaining experience2


19(1)

19(1)19(1)19(2)

19(3)

Tunisia16

17

19





14171517

20



20

20



20

20

United Kingdom 1617

19




141520

21

18 Teaching4


No limit$3,0006

No limit


$5,000 p.a.6

$5,0006

$10,0006

No limit$7,500 p.a.$7,500 p.a.25


No limit$4,000 p.a.

No limit12

No limit12

No limit

No limit


Any foreign resident contractorAny U.S. contractorAny foreign residentAny U.S. residentU.S. educational institution or U.S. Government

Any foreign residentU.S. or any foreign residentU.S. or any foreign residentTrinidad—Tobago resident



U.S. resident contractorAny contractorAny foreign residentAny U.S. or foreign resident


Any contractorAny foreign residentU.S. educational institution



5 years5 years5 years1 year

1 year

5 years183 daysNo limit183 daysNo limit

5 years5 years

183 days183 days2 years

No limit

Turkey 16201720

19







14171517

20(1)

No limit$3,00049

No limit$3,00049

No limit



183 daysNo limit183 daysNo limit

No limit

18 Teaching or research 20(2)No limit2 years Any foreign resident

Venezuela 15

17

19

No limit

No limit

No limit





5 years47

183 days

5 years47



No limit


Any U.S. or foreign contractor


$6,00030

$6,00030

21(1)

181518

21(1)

16 No limitIndependent personal services7,22 Any contractor 14


Compensation while gainingexperience2 12 mos.

12 mos.5 years47


Venezuelan resident

Venezuelan resident

Other foreign or U.S. resident$8,000$5,000 p.a.

$8,000

21(2)21(1)

21(2)

18 No limitTeaching4 2 years48 21(3)Any U.S. or foreign resident

No limit

Page

41

1

2

3

4

5

6

7

8

9

10

11

12

13

14

Refers to income code numbers under which the income isreported on Forms 1042-S. Personal services must beperformed by a nonresident alien individual who is a residentof the specified treaty country.Applies only if training or experience is received from a personother than alien’s employer.Annual compensation for services wherever performed.Does not apply to compensation for research work primarilyfor private benefit.Grant must be from a nonprofit organization. In many cases,the exemption also applies to amounts from either the U.S. orforeign government. For Indonesia and the Netherlands, theexemption also applies if the amount is awarded under atechnical assistance program entered into by the United Statesor the foreign government, or its political subdivisions or localauthorities.Reimbursed expenses are not taken into account in figuringany maximum compensation to which the exemption applies.For Japan and Trinidad and Tobago, only reimbursed travelexpenses are disregarded in figuring the maximumcompensation.Does not apply to fees of a foreign director of a U.S.corporation.Does not apply to compensation for research work for otherthan the U.S. educational institution involved.Exemption does not apply if gross receipts exceed this amount.Income is fully exempt if visit to the United States issubstantially supported by public funds of the treaty countryor its political subdivisions or local authorities.Applies only to full-time student or trainee.The time limit pertains only to an apprentice or business trainee.Does not apply to compensation paid to public entertainers(actors, artists, musicians, athletes, etc.). For Canadian or U.K.resident public entertainers, the exemption does not apply ifthe gross receipts (including reimbursements) are more than$15,000 in any year.Does not apply to compensation paid to public entertainersthat is more than $100 a day.Exemption applies only if the compensation is subject to taxin the country of residence.

15

16

17

18

19

20

21

22

23

24

25

26

27

The exemption does not apply if the employee’scompensation is borne by a permanent establishment (or insome cases a fixed base) that the employer has in theUnited States.The exemption also applies if the employer is a permanentestablishment in the treaty country but is not a resident ofthe treaty country.This exemption does not apply in certain cases if theemployee is a substantial owner of that employer and theemployer is engaged in certain defined activities.The exemption is also extended to journalists andcorrespondents who are temporarily in the U.S. for periodsnot longer than 2 years and who receive compensation fromabroad.

Also exempt are amounts of up to $10,000 received fromU.S. sources to provide ordinary living expenses. Forstudents, the amount will be less than $10,000, determinedon a case by case basis.A student or trainee may choose to be treated as a U.S.resident for tax purposes. If the choice is made, it may notbe changed without the consent of the U.S. competentauthority.Amounts received in excess of a reasonable fixed amountpayable to all directors for attending meetings in the UnitedStates are taxable.Exemption does not apply to the extent income isattributable to the recipient’s fixed U.S. base. For residentsof Japan, this fixed base must be maintained in the U.S. formore than 183 days during the tax year for the exemptionnot to apply; for residents of Belgium, Iceland, Korea, andNorway, the fixed base must be maintained for more than182 days; for residents of Morocco, the fixed base must bemaintained for more than 89 days.Fees paid to a resident of Thailand for services as a directorof a U.S. corporation are subject to U.S. tax, unless the servicesare performed in Thailand.Fees paid to a resident of Turkey for services performed in theUnited States as a director of a U.S. corporation are subjectto tax.Exemption does not apply if gross receipts (includingreimbursements) exceed this amount.Exemption does not apply if net income (or gross income forIsrael) exceeds this amount.Exemption does not apply to payments borne by apermanent establishment in the United States or paid by aU.S. citizen or resident or the federal, state, or localgovernment.

28

29

30

31

32

33

34

35

36

37

38

39

40

41

42

43

44

Exemption does not apply if compensation exceeds thisamount.The exemption applies only to income from activitiesperformed under special cultural exchange programs agreedto by the U.S. and Chinese governments.Exemption does not apply if gross receipts (or compensationfor Portugal), including reimbursements, exceed this amount.Income is fully exempt if visit to the United States issubstantially supported by public funds of the treaty countryor its political subdivisions or local authorities.The 5-year limit pertains only to training or research.Compensation from employment directly connected with aplace of business that is not a permanent establishment isexempt if the alien is present in the United States for aperiod not exceeding 12 consecutive months. Compensationfor technical services directly connected with the applicationof a right or property giving rise to a royalty is exempt if theservices are provided as part of a contract granting the useof the right or property.

Exemption does not apply if, during the immediatelypreceding period, the individual claimed the benefits ofArticle 21.Exemption does not apply if, during the immediatelypreceding period, the individual claimed the benefits ofArticle 22.Exemption does not apply if the individual either (a) claimedthe benefit of Article 21(5) during a previous visit, or (b)during the immediately preceding period, claimed the benefitof Article 21(1), (2), or (3).Exemption applies only to compensation for personalservices performed in connection with, or incidental to, theindividual’s study, research, or training.Exemption does not apply if, during the immediatelypreceding period, the individual claimed the benefits ofArticle 24(1).Exemption does not apply if, during the immediatelypreceding period, the individual claimed the benefits ofArticle 22(1).Exemption does not apply if the individual previously claimedthe benefit of this Article.The combined period of benefits under Articles 20 and 21(1)cannot exceed 5 years.Exemption does not apply if the individual either (a)previously claimed the benefit of this Article, or (b) during theimmediately preceding period, claimed the benefit of Article23. The benefits under Articles 22 and 23 cannot be claimedat the same time.Exemption does not apply if gross receipts (includingreimbursements) exceed this amount during any 12-monthperiod.The exemption also applies if the income is borne by anemployer that is a permanent establishment of a U.S.enterprise in Luxembourg.Applies to grants, allowances, and other similar paymentsreceived for studying or doing research.

45 A $10,000 limit applies if the expense is borne by a permanentestablishment or a fixed base in the United States.

46 This provision does not apply if these activities are substantiallysupported by a nonprofit organization or by public funds of thetreaty country or its political subdivisions or local authorities.

47 Applies to any additional period that a full-time student needsto complete the educational requirements as a candidate fora postgraduate or professional degree from a recognizededucational institution.

48 The combined benefit for teaching cannot exceed 5 years.49 Exemption does not apply if the recipient maintains a

permanent establishment in the U.S. with which the income iseffectively connected.

Page 42

Table 3. List of Tax Treaties

CountryOfficial Text

Symbol1General

Effective Date Citation

Applicable TreasuryExplanations or

Treasury Decision (T.D.)

AustraliaAustriaBarbados

ProtocolBelgium

ProtocolCanada2

ProtocolChina, People’s Republic ofCommonwealth of

Independent States3

CyprusCzech RepublicDenmark

Egypt

FinlandFranceGermanyGreeceHungaryIcelandIndiaIndonesiaIrelandIsraelItalyJamaicaJapanKazakstanKorea, Republic of

LuxembourgMexico

ProtocolMoroccoNetherlandsNew ZealandNorway

ProtocolPakistanPhilippinesPolandPortugalRomaniaRussia

South AfricaSpainSwedenSwitzerland

Trinidad and TobagoTunisia

Venezuela

TIAS 10773TIASTIAS 11090TIASTIAS 7463TIAS 11254TIAS 11087TIASTIAS 12065

TIAS 8225TIAS 10965TIASTIAS 1854

TIAS 10149

TIAS 12101TIASTIASTIAS 2902TIAS 9560TIAS 8151TIASTIAS 11593TIASTIASTIAS 11064TIAS 10207TIAS 7365TIASTIAS 9506

TIAS 5726TIASTIASTIAS 10195TIASTIAS 10772TIAS 7474TIAS 10205TIAS 4232TIAS 10417TIAS 8486TIASTIAS 8228TIAS

TIASTIASTIASTIAS

TIAS 7047TIAS

TIAS

Dec. 1, 1983Jan. 1, 1999Jan. 1, 1984Jan. 1, 1994Jan. 1, 1971Jan. 1, 1988Jan. 1, 1985Jan. 1, 1996Jan. 1, 1987

Jan. 1, 1976Jan. 1, 1986Jan. 1, 1993Jan. 1, 1948

Jan. 1, 1982

Jan. 1, 1991Jan. 1, 1996Jan. 1, 19904

Jan. 1, 1953Jan. 1, 1980Jan. 1, 1976Jan. 1, 1991Jan. 1, 1990Jan. 1, 1998Jan. 1, 1995Jan. 1, 1985Jan. 1, 1982Jan. 1, 1973Jan. 1, 1996Jan. 1, 1980

Jan. 1, 1964Jan. 1, 1994Oct. 26, 1995Jan. 1, 1981Jan. 1, 1994Nov. 2, 1983Jan. 1, 1971Jan. 1, 1982Jan. 1, 1959Jan. 1, 1983Jan. 1, 1974Jan. 1, 1996Jan. 1, 1974Jan. 1, 1994

Jan. 1, 1998

Jan. 1, 1996Jan. 1, 1998

Jan. 1, 1970Jan. 1, 1990

Jan. 1, 2000

Jan. 1, 1991

1986-2 C.B. 220

1991-2 C.B. 436

1973-1 C.B. 619

1986-2 C.B. 258

1988-1 C.B. 414

1976-2 C.B. 4631989-2 C.B. 280

1950-1 C.B. 77

1982-1 C.B. 219

1958-2 C.B. 10541980-1 C.B. 3331976-1 C.B. 442

1992-1 C.B. 4421982-1 C.B. 2571973-1 C.B. 630

1979-2 C.B. 435

1965-1 C.B. 6151994-2 C.B. 424

1982-2 C.B. 405

1990-2 C.B. 2741973-1 C.B. 6691982-2 C.B. 4401960-2 C.B. 6461984-2 C.B. 3841977-1 C.B. 416

1976-2 C.B. 492

1971-2 C.B. 479

1986-2 C.B. 246

1991-2 C.B. 466

1987-2 C.B. 298

1988-1 C.B. 447

1976-2 C.B. 4751989-2 C.B. 314

T.D. 5692, 1949-1 C.B. 104;T.D. 5777, 1950-1 C.B. 76

1982-1 C.B. 243

T.D. 6109, 1954-2 C.B. 6381980-1 C.B. 3541976-1 C.B. 456

1992-1 C.B. 4731982-1 C.B. 2911973-1 C.B. 653

1979-2 C.B. 458

1965-1 C.B. 6421994-2 C.B. 489

1982-2 C.B. 427

1990-2 C.B. 3031973-1 C.B. 6931982-2 C.B. 454T.D. 6431, 1960-1 C.B. 7551984-2 C.B. 4121977-1 C.B. 427

1976-2 C.B. 504

1

2

3

4

(TIAS)—Treaties and Other International Act Series.Information on the treaty can be found in Publication 597, Information on the United States—Canada Income Tax Treaty.The U.S.—U.S.S.R. income tax treaty applies to the countries of Armenia, Azerbaijan, Belarus, Georgia, Kyrgyzstan, Moldova, Tajikistan, Turkmenistan,Ukraine, and Uzbekistan.The general effective date for the area that was the German Democratic Republic is January 1, 1991.

Slovak Republic TIAS Jan. 1, 1993

Thailand TIAS Jan. 1, 1998

Turkey TIAS Jan. 1, 1998

Estonia TIAS Jan. 1, 2000

Latvia TIAS Jan. 1, 2000Lithuania TIAS Jan. 1, 2000

United Kingdom TIAS 9682 Jan. 1, 1975 1980-1 C.B. 394 1980-1 C.B. 455

Page 43

How To Get MoreInformationYou can order free publications and forms,ask tax questions, and get more informationfrom the IRS in several ways. By selecting themethod that is best for you, you will havequick and easy access to tax help.

Free tax services. To find out what servicesare available, get Publication 910, Guide toFree Tax Services. It contains a list of free taxpublications and an index of tax topics. It alsodescribes other free tax information services,including tax education and assistance pro-grams and a list of TeleTax topics.

Personal computer. With your per-sonal computer and modem, you canaccess the IRS on the Internet at

www.irs.gov . While visiting our web site, youcan select:

• Frequently Asked Tax Questions (locatedunder Taxpayer Help & Ed) to find an-swers to questions you may have.

• Forms & Pubs to download forms andpublications or search for forms andpublications by topic or keyword.

• Fill-in Forms (located under Forms &Pubs) to enter information while the formis displayed and then print the completedform.

• Tax Info For You to view Internal Reve-nue Bulletins published in the last fewyears.

• Tax Regs in English to search regulationsand the Internal Revenue Code (underUnited States Code (USC)).

• Digital Dispatch and IRS Local News Net(both located under Tax Info For Busi-ness) to receive our electronic newslet-ters on hot tax issues and news.

• Small Business Corner (located underTax Info For Business) to get informationon starting and operating a small busi-ness.

You can also reach us with your computerusing File Transfer Protocol at ftp.irs.gov.

TaxFax Service. Using the phoneattached to your fax machine, you canreceive forms and instructions by

calling 703–368–9694. Follow the directionsfrom the prompts. When you order forms,enter the catalog number for the form youneed. The items you request will be faxed toyou.

Phone. Many services are availableby phone.

• Ordering forms, instructions, and publi-cations. Call 1–800–829–3676 to ordercurrent and prior year forms, instructions,and publications.

• Asking tax questions. Call the IRS withyour tax questions at 1–800–829–1040.

• TTY/TDD equipment. If you have accessto TTY/TDD equipment, call 1–800–829–4059 to ask tax questions or to orderforms and publications.

• TeleTax topics. Call 1–800–829–4477 tolisten to pre-recorded messages coveringvarious tax topics.

Evaluating the quality of our telephoneservices. To ensure that IRS representativesgive accurate, courteous, and professionalanswers, we evaluate the quality of our tele-phone services in several ways.

• A second IRS representative sometimesmonitors live telephone calls. That persononly evaluates the IRS assistor and doesnot keep a record of any taxpayer's nameor tax identification number.

• We sometimes record telephone calls toevaluate IRS assistors objectively. Wehold these recordings no longer than oneweek and use them only to measure thequality of assistance.

• We value our customers' opinions.Throughout this year, we will be survey-ing our customers for their opinions onour service.

Walk-in. You can walk in to manypost offices, libraries, and IRS officesto pick up certain forms, instructions,

and publications. Also, some libraries and IRSoffices have:

• An extensive collection of products avail-able to print from a CD-ROM or photo-copy from reproducible proofs.

• The Internal Revenue Code, regulations,Internal Revenue Bulletins, and Cumula-tive Bulletins available for research pur-poses.

Mail. You can send your order forforms, instructions, and publicationsto the Distribution Center nearest to

you and receive a response within 10 work-days after your request is received. Find theaddress that applies to your part of thecountry.

• Western part of U.S.:Western Area Distribution CenterRancho Cordova, CA 95743–0001

• Central part of U.S.:Central Area Distribution CenterP.O. Box 8903Bloomington, IL 61702–8903

• Eastern part of U.S. and foreign ad-dresses:Eastern Area Distribution CenterP.O. Box 85074Richmond, VA 23261–5074

CD-ROM. You can order IRS Publi-cation 1796, Federal Tax Products onCD-ROM, and obtain:

• Current tax forms, instructions, and pub-lications.

• Prior-year tax forms, instructions, andpublications.

• Popular tax forms which may be filled inelectronically, printed out for submission,and saved for recordkeeping.

• Internal Revenue Bulletins.

The CD-ROM can be purchased fromNational Technical Information Service (NTIS)by calling 1–877–233–6767 or on the Internetat www.irs.gov/cdorders. The first releaseis available in mid-December and the finalrelease is available in late January.

IRS Publication 3207, Small BusinessResource Guide, is an interactive CD-ROMthat contains information important to smallbusinesses. It is available in mid-February.You can get one free copy by calling1–800–829–3676.

Page 44

Documents

Publication 901 (Rev. April 2000) · Publication 901 (Rev. April 2000) Cat. No. 46849F U.S. Tax Treaties. countries are negotiated and ratified. Pro- ... to pay a $1,000 penalty