61
Contents Reminders ................... 1 Introduction .................. 2 Application of Treaties ........... 2 Tax Exemptions Provided by Treaties .................. 2 Personal Services Income ........ 2 Professors, Teachers, and Researchers ............ 15 Students and Apprentices ....... 19 Wages and Pensions Paid by a Foreign Government ........ 28 Explanation of Tables ........... 33 Table 1.Tax Rates on Income Other Than Personal Service Income Under Chapter 3, Internal Revenue Code, and Income Tax Treaties .............. 35 Table 2. Compensation for Personal Services Performed in United States Exempt from U.S. Income Tax Under Income Tax Treaties ................. 41 Table 3. List of Tax Treaties (Updated through March 31, 2013) .................. 58 How To Get Tax Help ........... 60 Future Developments For the latest information about developments related to Publication 901, such as treaties effective after it was published, go to www.irs.gov/pub901. Reminders Disclosure of a treaty-based position that reduces your tax. If you take the position that any U.S. tax is overruled or otherwise reduced by a U.S. treaty (a treaty-based position), you generally must disclose that position on your af- fected return. See Application of Treaties, later. U.S.–U.S.S.R. income tax treaty. The U.S.– U.S.S.R. income tax treaty remains in effect for the following members of the Commonwealth of Independent States: Armenia, Azerbaijan, Bela- rus, Georgia, Kyrgyzstan, Moldova, Tajikistan, Turkmenistan, and Uzbekistan. That treaty will remain in effect until new treaties with these in- dividual countries are negotiated and ratified. Provisions of the U.S.–U.S.S.R. income tax treaty are discussed in this publication under Commonwealth of Independent States. U.S.–China income tax treaty. The U.S.– China income tax treaty does not apply to Hong Kong. Department of the Treasury Internal Revenue Service Publication 901 (Rev. April 2013) Cat. No. 46849F U.S. Tax Treaties Get forms and other Information faster and easier by: Internet IRS.gov Mar 11, 2013

Treaties U.S. TaxTurkmenistan, and Uzbekistan. That treaty will remain in effect until new treaties with these in-dividual countries are negotiated and ratified. Provisions of the

  • Upload
    others

  • View
    3

  • Download
    0

Embed Size (px)

Citation preview

Page 1: Treaties U.S. TaxTurkmenistan, and Uzbekistan. That treaty will remain in effect until new treaties with these in-dividual countries are negotiated and ratified. Provisions of the

ContentsReminders . . . . . . . . . . . . . . . . . . . 1

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

Application of Treaties . . . . . . . . . . . 2Tax Exemptions Provided by

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

Researchers . . . . . . . . . . . . 15Students and Apprentices . . . . . . . 19Wages and Pensions Paid by a

Foreign Government . . . . . . . . 28

Explanation of Tables . . . . . . . . . . . 33Table 1.Tax Rates on Income Other

Than Personal Service Income Under Chapter 3, Internal Revenue Code, and Income Tax Treaties . . . . . . . . . . . . . . 35

Table 2. Compensation for Personal Services Performed in United States Exempt from U.S. Income Tax Under Income Tax Treaties . . . . . . . . . . . . . . . . . 41

Table 3. List of Tax Treaties (Updated through March 31, 2013) . . . . . . . . . . . . . . . . . . 58

How To Get Tax Help . . . . . . . . . . . 60

Future DevelopmentsFor the latest information about developments related to Publication 901, such as treaties effective after it was published, go to www.irs.gov/pub901.

RemindersDisclosure of a treaty-based position that reduces your tax. If you take the position that any U.S. tax is overruled or otherwise reduced by a U.S. treaty (a treaty-based position), you generally must disclose that position on your af-fected return. See Application of Treaties, later.U.S.–U.S.S.R. income tax treaty. The U.S.–U.S.S.R. income tax treaty remains in effect for the following members of the Commonwealth of Independent States: Armenia, Azerbaijan, Bela-rus, Georgia, Kyrgyzstan, Moldova, Tajikistan, Turkmenistan, and Uzbekistan. That treaty will remain in effect until new treaties with these in-dividual countries are negotiated and ratified. Provisions of the U.S.–U.S.S.R. income tax treaty are discussed in this publication under Commonwealth of Independent States.U.S.–China income tax treaty. The U.S.–China income tax treaty does not apply to Hong Kong.

Department of the TreasuryInternal Revenue Service

Publication 901(Rev. April 2013)Cat. No. 46849F

U.S. TaxTreaties

Get forms and other Informationfaster and easier by:Internet IRS.gov

Userid: CPM Schema: tipx Leadpct: 100% Pt. size: 8 Draft Ok to PrintAH XSL/XML Fileid: … ons/P901/201304/A/XML/Cycle02/source (Init. & Date) _______

Page 1 of 61 10:02 - 11-Mar-2013The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

Mar 11, 2013

Page 2: Treaties U.S. TaxTurkmenistan, and Uzbekistan. That treaty will remain in effect until new treaties with these in-dividual countries are negotiated and ratified. Provisions of the

IntroductionThis publication will tell you whether a tax treaty between the United States and a particular country offers a reduced rate of, or possibly a complete exemption from, U.S. income tax for residents of that particular country.

Tables in the back of this publication show the countries that have income tax treaties with the United States, the tax rates on different kinds of income, and the kinds of income that are exempt from tax.

You should use this publication only for quick reference. It is not a com­plete guide to all provisions of every

income tax treaty.

Comments and suggestions. We welcome your comments about this publication and your suggestions for future editions.

You can write to us at the following address:

Internal Revenue ServiceBusiness Forms and Publications BranchSE:W:CAR:MP:T:B1111 Constitution Ave. NW, IR-6526Washington, DC 20224

We respond to many letters by telephone. Therefore, it would be helpful if you would in-clude your daytime phone number, including the area code, in your correspondence.

You can email us at [email protected]. Please put “Publications Comment” on the sub-ject line. You can also send us comments from www.irs.gov/formspubs. Select “Comment on Tax Forms and Publications” under “Information About.”

Although we cannot respond individually to each comment received, we do appreciate your feedback and will consider your comments as we revise our tax products.

Ordering forms and publications. Visit www.irs.gov/formspubs to download forms and publications, call 1-800-829-3676, or write to the address below and receive a response within 10 days after your request is received.

Internal Revenue Service1201 N. Mitsubishi MotorwayBloomington, IL 61705-6613

Tax questions. If you have a tax question, check the information available on IRS.gov or call 1-800-829-1040. We cannot answer tax questions sent to either of the above ad-dresses.

Obtaining copies of treaties. You can get complete information about treaty provisions from the taxing authority in the country from which you receive income or from the treaty it-self.

You can obtain the text of most of the trea-ties at www.irs.gov/businesses/international. You can also obtain the text of most of the trea-ties at the following address:

CAUTION!

Department of the TreasuryOffice of Public Correspondence1500 Pennsylvania Ave. NW — Rm. 3419Washington, D.C. 20220

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

Internal Revenue ServiceInternational SectionPhiladelphia, PA 19255-0725

Useful ItemsYou may want to see:

PublicationU.S. Tax Guide for AliensInformation on the United States–Canada Income Tax Treaty

Form (and Instructions)Treaty-Based Return Position

Disclosure Under Section 6114 or 7701(b)

See How To Get Tax Help near the end of this publication for information about getting these publications and forms.

Application of TreatiesThe United States has income tax treaties

with a number of foreign countries. Under these treaties, residents (not necessarily citizens) of foreign countries are taxed at a reduced rate, or are exempt from U.S. income taxes on certain items of income they receive from sources within the United States. These reduced rates and exemptions vary among countries and spe-cific items of income.

If there is no treaty between your country and the United States, you must pay tax on the income in the same way and at the same rates shown in the instructions for Form 1040NR. Also see Publication 519.

Many of the individual states of the United States tax the income of their residents. There-fore, you should consult the tax authorities of the state in which you live to find out if that state taxes the income of individuals and, if so, whether the tax applies to any of your income.

Tax treaties reduce the U.S. taxes of resi-dents of foreign countries. With certain excep-tions, they do not reduce the U.S. taxes of U.S. citizens or residents. U.S. citizens and residents are subject to U.S. income tax on their world-wide income.

Treaty provisions generally are reciprocal (apply to both treaty countries); therefore, a U.S. citizen or resident who receives income from a treaty country may refer to the tables in this publication to see if a tax treaty might affect the tax to be paid to that foreign country. For-eign taxing authorities sometimes require certifi-cation from the U.S. Government that an

519 597

8833

applicant filed an income tax return as a U.S. citizen or resident, as part of the proof of entitle-ment to the treaty benefits. See Form 8802, Ap-plication for United States Residency Certifica-tion, to request a certification.

Disclosure of a treaty-based position that reduces your tax. If you take the position that any U.S. tax is overruled or otherwise reduced by a U.S. treaty (a treaty-based position), you generally must disclose that position on Form 8833 and attach it to your return. If you are not required to file a return because of your treaty-based position, you must file a return anyway to report your position. The filing of Form 8833 does not apply to a reduced rate of withholding tax on noneffectively connected in-come, such as dividends, interest, rents or roy-alties, or to a reduced rate of tax on pay re-ceived for services performed as an employee, including pensions, annuities, and social secur-ity. For more information, see Publication 519 and the Form 8833 instructions.

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

Tax ExemptionsProvided by TreatiesIn addition to the tables in the back of this publi-cation, this publication contains discussions of the exemptions from tax and certain other ef-fects of the tax treaties on the following types of income.

Pay for certain personal services per-formed in the United States.Pay of a professor, teacher, or researcher who teaches or performs research in the United States for a limited time.Amounts received for maintenance and studies by a foreign student or apprentice who is here for study or experience.Wages, salaries, and pensions paid by a foreign government.

Personal Services IncomePay for certain personal services performed in the United States is exempt from U.S. income tax if you are a resident of one of the countries discussed below, if you are in the United States for a limited number of days, and if you meet certain other conditions. For this purpose, the word “day” means a day during any part of which you are physically present in the United States.

Terms defined. Several terms appear in many of the discussions that follow. The exact mean-ings of the terms are determined by the particu-lar tax treaty under discussion; thus, the mean-ings vary among treaties. The definitions that follow are, therefore, general definitions that may not give the exact meaning intended by a particular treaty.

The terms fixed base and permanent estab-lishment generally mean a fixed place of busi-ness, such as a place of management, a branch, an office, a factory, a warehouse, or a

Page 2 of 61 Fileid: … ons/P901/201304/A/XML/Cycle02/source 10:02 - 11-Mar-2013The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

Page 2 Publication 901 (April 2013)

Page 3: Treaties U.S. TaxTurkmenistan, and Uzbekistan. That treaty will remain in effect until new treaties with these in-dividual countries are negotiated and ratified. Provisions of the

mining site, through which an enterprise carries on its business.

The term borne by generally means having ultimate financial accounting responsibility for, or providing the monetary resources for, an ex-penditure or payment, even if another entity in another location actually made the expenditure or payment.

AustraliaIncome that residents of Australia receive for performing personal services as independent contractors or self-employed individuals (inde-pendent personal services) in the United States during the tax year is exempt from U.S. income tax if the residents:

Are in the United States for no more than 183 days during the tax year, andDo not have a fixed base regularly availa-ble to them in the United States for the pur-pose of performing the services.

If they have a fixed base available in the United States, they are taxed on the income attributa-ble to the fixed base.

Pay that residents of Australia receive for la-bor or personal services performed in the Uni-ted States as employees (dependent personal services), including services as a director of a company, is exempt from U.S. income tax if:

The residents are in the United States for no more than 183 days during the tax year,The pay is paid by, or on behalf of, an em-ployer or company that is not a resident of the United States, andThe pay is not deductible in determining the taxable income of the trade or business of the employer (or company) in the United States.

These exemptions do not apply to public en-tertainers (such as theater, motion picture, ra-dio, or television entertainers, musicians, and athletes) from Australia who earn more than $10,000 in gross receipts, including reimbursed expenses, from their entertainment activities in the United States during the tax year.

AustriaIncome that residents of Austria receive for per-sonal services as independent contractors or self-employed individuals (independent per-sonal services) in the United States is exempt from U.S. income tax if they do not have a fixed base regularly available to them in the United States for performing the services. If they have a fixed base available in the United States, they are taxed on the income attributable to the fixed base.

Income that residents of Austria receive for services performed in the United States as em-ployees (dependent personal services) is ex-empt from U.S. income tax if the residents meet the following requirements.

They are in the United States for no more than 183 days in any 12-month period be-ginning or ending in the tax year.Their income is paid by, or on behalf of, an employer who is not a U.S. resident.

Their income is not borne by a permanent establishment or a fixed base that the em-ployer has in the United States.

These exemptions do not apply to public en-tertainers (such as theater, motion picture, ra-dio, or television entertainers, musicians, and athletes) from Austria who earn more than $20,000 in gross receipts, including reimbursed expenses, from their entertainment activities in the United States during the tax year.

Income received by a resident of Austria for services performed as an employee and mem-ber of the regular complement of a ship or air-craft operated in international traffic is exempt from U.S. income tax.

BangladeshIncome that residents of Bangladesh receive for performing personal services as independent contractors or self-employed individuals (inde-pendent personal services) in the United States during the tax year is exempt from U.S. income tax if the residents:

Are in the United States for no more than 183 days in any 12-month period begin-ning or ending in the tax year, orDo not have a fixed base regularly availa-ble to them in the United States for the pur-pose of performing the services.

If they have a fixed base available in the United States, they are taxed on the income attributa-ble to the fixed base.

Income that residents of Bangladesh re-ceive for services performed in the United States as employees (dependent personal services) is exempt from U.S. income tax if the residents meet the following requirements.

They are in the United States for no more than 183 days in any 12-month period be-ginning or ending in the tax year.Their income is paid by, or on behalf of, an employer who is not a U.S. resident.Their income is not borne by a permanent establishment or a fixed base that the em-ployer has in the United States.

These exemptions do not apply to pubic en-tertainers (such as theater, motion picture, ra-dio, or television entertainers, musicians, and athletes) from Bangladesh who earn more than $10,000 in gross receipts, including reimbursed expenses, from their entertainment activities in the United States during the tax year. Regard-less of these limits, income of Bangladesh en-tertainers is exempt from U.S. income tax if their visit to the United States is wholly or mainly supported by public funds of Bangladesh, its political subdivisions, or local authorities.

Income received from employment as a member of the regular complement of a ship or an aircraft operated by a Bangladesh enterprise in international traffic is exempt from U.S. tax. If the ship or aircraft is operated by a U.S. enter-prise, the income is subject to U.S. tax.

If the resident of Bangladesh is a share-holder in a U.S. corporation, these exemptions do not apply to directors' fees received as a

member of the board of directors of the U.S. corporation. The amount received by the share-holder that is more than the amount paid to a di-rector that is not a shareholder is subject to U.S. tax at the rate of 15%.

BarbadosIncome that residents of Barbados receive for performing personal services as independent contractors or self-employed individuals (inde-pendent personal services) in the United States during the tax year is exempt from U.S. income tax if the residents:

Are in the United States for no more than 89 days during the tax year,Earn net income for independent services provided to U.S. residents that is not more than $5,000 (there is no dollar limit if the contractors are not U.S. residents), andDo not have a regular base available in the United States for performing the services.

If they have a regular base available in the Uni-ted States but otherwise meet the conditions for exemption, they are taxed only on the income attributable to the regular base.

Income that residents of Barbados receive for personal services performed in the United States as employees (dependent personal services) is exempt from U.S. tax if the resi-dents meet four requirements.

They are in the United States for no more than 183 days during the calendar year.The income earned in the calendar year in the United States is not more than $5,000.Their income is paid by or for an employer who is not a U.S. resident.The income is not borne by a permanent establishment or regular base of the em-ployer in the United States.

Income of a Barbadian resident from em-ployment as a member of the regular comple-ment of a ship or aircraft operated in interna-tional traffic is exempt from U.S. tax.

These exemptions do not apply to Barba-dian resident public entertainers (such as thea-ter, motion picture, radio, or television artists, musicians, or athletes) who receive gross re-ceipts of more than $250 per day or $4,000 in the tax year, not including reimbursed expen-ses, from their entertainment activities in the United States. However, the exemptions do ap-ply regardless of these limits on gross receipts if the entertainer's visit to the United States is substantially supported by Barbadian public funds or if the entertainer's services are provi-ded to a nonprofit organization.

BelgiumIncome that residents of Belgium receive for personal services as independent contractors or self-employed individuals are subject to the provisions of Article 7 (Business Profits) of the treaty. Under that provision, business profits are exempt from U.S. income tax unless the individ-ual has a permanent establishment in the Uni-ted States. If they have a permanent establish-ment in the United States, they are taxed on the

Page 3 of 61 Fileid: … ons/P901/201304/A/XML/Cycle02/source 10:02 - 11-Mar-2013The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

Publication 901 (April 2013) Page 3

Page 4: Treaties U.S. TaxTurkmenistan, and Uzbekistan. That treaty will remain in effect until new treaties with these in-dividual countries are negotiated and ratified. Provisions of the

profit attributable to the permanent establishment.

Income that residents of Belgium receive for services performed in the United States as em-ployees (dependent personal services) is ex-empt from U.S. income tax if the residents meet the following requirements.

They are in the United States for no more than 183 days in any 12-month period be-ginning or ending in the tax year.Their income is paid by, or on behalf of, an employer who is not a U.S. resident.Their income is not borne by a permanent establishment that the employer has in the United States.

The exemption does not apply to directors' fees and similar payments received by a resi-dent of Belgium for services performed in the United States as a member of the board of di-rectors of a company that is a resident of the United States.

Public entertainers (such as theater, motion picture, radio, or television artists, musicians, or athletes) from Belgium who earn more than $20,000 in gross receipts, including reimbursed expenses, from their entertainment activities in the United States during the tax year are sub-ject to U.S. tax.

Income received by a resident of Belgium for services performed as an employee and member of the regular complement of a ship or aircraft operated in international traffic is ex-empt from U.S. income tax.

BulgariaIncome that residents of Bulgaria receive for personal services as independent contractors or self-employed individuals is subject to the provisions of Article 7 (Business Profits) of the treaty. Under that provision, business profits are exempt from U.S. income tax unless the individ-ual has a permanent establishment in the Uni-ted States. If they have a permanent establish-ment in the United States, they are taxed on the profit attributable to the permanent establish-ment. Under Article 5 (Permanent Establish-ment), you may be considered to provide serv-ices through a permanent establishment in the United States even if you do not have a fixed place of business.

Income that residents of Bulgaria receive for services performed in the United States as em-ployees (dependent personal services) is ex-empt from U.S. income tax if the residents meet the following requirements.

They are in the United States for no more than 183 days in any 12-month period be-ginning or ending in the tax year.Their income is paid by, or on behalf of, an employer who is not a U.S. resident.Their income is not borne by a permanent establishment that the employer has in the United States.

The exemption does not apply to directors' fees and similar payments received by a resi-dent of Bulgaria as a member of the board of di-rectors of a U.S. company.

Public entertainers (such as theater, motion picture, radio, or television artists, musicians, or athletes) from Bulgaria who earn more than $15,000 in gross receipts, including reimbursed expenses, from their entertainment activities in the United States during the tax year are sub-ject to U.S. tax.

Income received by a resident of Bulgaria for services performed as an employee and member of the regular complement of a ship or aircraft operated in international traffic is ex-empt from U.S. income tax.

CanadaIncome that residents of Canada receive for personal services as independent contractors or self-employed individuals is subject to the provisions of Article VII (Business Profits) of the treaty. Under that provision, business profits are exempt from U.S. income tax unless the individ-ual has a permanent establishment in the Uni-ted States. If they have a permanent establish-ment in the United States, they are taxed on the profit attributable to the permanent establish-ment. Under Article V (Permanent Establish-ment), you may be considered to provide serv-ices through a permanent establishment in the United States even if you do not have a fixed place of business.

Income that residents of Canada receive for personal services performed as employees (de-pendent personal services) in the United States is exempt from U.S. tax if it is not more than $10,000 for the year. If the income is more than $10,000 for the year, it is exempt only if:

The residents are present in the United States for no more than 183 days in any 12-month period beginning or ending in the tax year, andThe income is not paid by, or on behalf of, a U.S. resident, and is not borne by a per-manent establishment in the United States.

Public entertainers (such as theater, motion picture, radio, or television artists, musicians, or athletes) from Canada who derive more than $15,000 in gross receipts, including reimbursed expenses, from their entertainment activities in the United States during the calendar year are subject to U.S. tax. However, this article does not apply to athletes participating in team sports in leagues with regularly scheduled games in both Canada and the United States.

Pay received by a resident of Canada for employment regularly done in more than one country on a ship, aircraft, motor vehicle, or train operated by a Canadian resident is ex-empt from U.S. tax.

China, People's Republic ofIncome that residents of the People's Republic of China receive for personal services as inde-pendent contractors or self-employed individu-als (independent personal services) that they

perform during the tax year in the United States is exempt from U.S. income tax if the residents:

Are present in the United States for no more than 183 days in the calendar year, andDo not have a fixed base regularly availa-ble in the United States for performing the services.

If they have a fixed base available in the United States, they are taxable on the income attributa-ble to the fixed base.

Pay received by residents of the People's Republic of China for services performed as employees (dependent personal services) in the United States is exempt from U.S. tax if:

The residents are present in the United States for no more than 183 days in the calendar year,The pay is paid by or for an employer who is not a U.S. resident, andThe pay is not borne by a permanent es-tablishment or fixed base that the em-ployer has in the United States.

These exemptions do not apply to directors' fees for service on the board of directors of a U.S. corporation.

These exemptions generally do not apply to income received as a public entertainer (such as a theater, motion picture, radio, or television artist, musician, or athlete). However, income of athletes or public entertainers from China par-ticipating in a cultural exchange program agreed upon by the U.S. and Chinese govern-ments is exempt from U.S. tax.

Commonwealth ofIndependent StatesIncome that residents of a C.I.S. member re-ceive for performing personal services in the United States is exempt from U.S. income tax if those residents are in the United States for no more than 183 days during the tax year.

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

CyprusIncome that residents of Cyprus receive for per-forming personal services as independent con-tractors or self-employed individuals (independ-ent personal services) in the United States during the tax year is exempt from U.S. income tax if the residents:

Are present in the United States for less than 183 days in the tax year, andDo not have a fixed base regularly availa-ble to them in the United States for per-forming the services.

If they have a fixed base available in the United States, they are taxable on the income attributa-ble to the fixed base.

Pay received by residents of Cyprus from services performed as employees (dependent

Page 4 of 61 Fileid: … ons/P901/201304/A/XML/Cycle02/source 10:02 - 11-Mar-2013The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

Page 4 Publication 901 (April 2013)

Page 5: Treaties U.S. TaxTurkmenistan, and Uzbekistan. That treaty will remain in effect until new treaties with these in-dividual countries are negotiated and ratified. Provisions of the

personal services), including services as an offi-cer of a corporation, is exempt from U.S. in-come tax if:

The residents are in the United States for less than 183 days during the tax year,The pay is paid by or for an employer who is not a U.S. resident, andThe pay is not borne by a permanent es-tablishment, fixed base, or trade or busi-ness that the employer has in the United States.

Pay received by a Cyprus resident for per-forming personal services as an employee and member of the regular complement of a ship or aircraft operated in international traffic by a resi-dent of Cyprus is exempt from U.S. tax.

These exemptions do not apply to Cyprus resident public entertainers (theater, motion pic-ture, radio, or television artists, musicians, or athletes) who receive gross receipts of more than $500 per day or $5,000 for the tax year, not including reimbursed expenses, from their entertainment activities in the United States.

Directors' fees received by residents of Cy-prus for service on the board of directors of a U.S. corporation are exempt from U.S. income tax to the extent of a reasonable fixed amount payable to all directors for each day of attend-ance at directors' meetings held in the United States.

Czech RepublicIncome that residents of the Czech Republic re-ceive for performing personal services as inde-pendent contractors or self-employed individu-als (independent personal services) in the United States is exempt from U.S. income tax if the residents:

Are present in the United States for no more than 183 days in any 12-month pe-riod, andDo not have a fixed base regularly availa-ble to them in the United States for per-forming the services.

If they have a fixed base available, they are taxed only on income attributable to the fixed base.

Income that residents of the Czech Republic receive for employment in the United States (dependent personal services) is exempt from U.S. income tax if the following three require-ments are met.

The resident is present in the United States for no more than 183 days in any 12-month period.The income is paid by, or on behalf of, an employer who is not a U.S. resident.The income is not borne by a permanent establishment or a fixed base that the em-ployer has in the United States.

These exemptions do not apply to income residents of the Czech Republic receive as pub-lic entertainers (such as theater, motion picture, radio, or television artists, or musicians) or sportsmen if their gross receipts, including re-imbursed expenses, are more than $20,000 during the tax year. Regardless of these limits,

income of Czech entertainers and sportsmen is exempt from U.S. income tax if their visit to the United States is substantially supported by pub-lic funds of the Czech Republic, its political sub-divisions, or local authorities, or the visit is made pursuant to a specific arrangement be-tween the United States and the Czech Repub-lic.

These exemptions do not apply to directors' fees and similar payments received by a resi-dent of the Czech Republic as a member of the board of directors of a company that is a resi-dent of the United States.

Income from employment as a member of the regular complement of a ship or aircraft op-erated by a Czech enterprise in international traffic is exempt from U.S. income tax. If the ship or aircraft is operated by a U.S. enterprise, the income is subject to U.S. tax.

DenmarkIncome that residents of Denmark receive for personal services as independent contractors or self-employed individuals (independent per-sonal services) in the United States is exempt from U.S. income tax if they do not have a fixed base regularly available to them in the United States for performing the services. If they have a fixed base available in the United States, they are taxed on the income attributable to the fixed base.

Income that residents of Denmark receive for services performed in the United States as employees (dependent personal services) is exempt from U.S. income tax if the residents meet the following requirements.

They are in the United States for no more than 183 days in any 12-month period be-ginning or ending in the tax year.Their income is paid by, or on behalf of, an employer who is not a U.S. resident.Their income is not borne by a permanent establishment or a fixed base that the em-ployer has in the United States.

These exemptions do not apply to directors' fees and similar payments received by a resi-dent of Denmark as a member of the board of directors of a company that is a resident of the United States.

These exemptions do not apply to public en-tertainers (such as theater, motion picture, ra-dio, or television artists, musicians, and ath-letes) from Denmark who earn more than $20,000 in gross receipts, including reimbursed expenses, from their entertainment activities in the United States during the tax year.

Income received by a resident of Denmark for services performed as an employee and member of the regular complement of a ship or aircraft operated in international traffic is ex-empt from U.S. income tax.

EgyptIncome that residents of Egypt receive for per-forming personal services as independent con-tractors or as self-employed individuals (inde-pendent personal services) in the United States during the tax year is exempt from U.S. income tax if they are in the United States for no more than 89 days during the tax year.

Income that residents of Egypt receive for labor or personal services performed in the Uni-ted States as employees (dependent personal services), including income for services per-formed by an officer of a corporation or com-pany, is exempt from U.S. income tax if the resi-dents meet four requirements.

They are in the United States for no more than 89 days during the tax year.They are employees of a resident of, or a permanent establishment in, Egypt.Their income is not borne by a permanent establishment that the employer has in the United States.Their income is subject to Egyptian tax.

This exemption does not apply to pay re-ceived by a resident of Egypt who is an em-ployee and member of the regular complement of a ship or an aircraft operated in international traffic by a resident of the United States.

These exemptions do not apply to Egyptian resident public entertainers (theater, motion pic-ture, radio, or television artists, musicians, or athletes), who earn income for services as pub-lic entertainers if the gross amount of the in-come is more than $400 for each day they are in the United States performing the services.

EstoniaIncome that residents of Estonia receive for per-forming personal services as independent con-tractors or self-employed individuals (independ-ent personal services) in the United States is exempt from U.S. income tax if the residents:

Are in the United States for no more than 183 days in any 12-month period begin-ning or ending in the tax year, andDo not have a fixed base regularly availa-ble to them in the United States for per-forming the services.

If they have a fixed base available, they are taxed on the income attributable to the fixed base.

Income that residents of Estonia receive for services performed in the United States as em-ployees (dependent personal services) is ex-empt from U.S. income tax if the following re-quirements are met.

The resident is in the United States for no more than 183 days in any 12-month pe-riod beginning or ending in the tax year.The income is paid by, or on behalf of, an employer who is not a U.S. resident.The income is not borne by a permanent establishment or a fixed base that the em-ployer has in the United States.

Page 5 of 61 Fileid: … ons/P901/201304/A/XML/Cycle02/source 10:02 - 11-Mar-2013The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

Publication 901 (April 2013) Page 5

Page 6: Treaties U.S. TaxTurkmenistan, and Uzbekistan. That treaty will remain in effect until new treaties with these in-dividual countries are negotiated and ratified. Provisions of the

These exemptions do not apply to directors' fees and similar payments received by a resi-dent of Estonia as a member of the board of di-rectors or similar body of a company that is a U.S. resident.

Pay received for employment as a member of the regular complement of a ship or an air-craft operated in international traffic by a United States enterprise is subject to U.S. tax.

These exemptions do not apply to income residents of Estonia receive as public entertain-ers (such as theater, motion picture, radio, or television artists, or musicians) or sportsmen if their gross receipts, including reimbursed ex-penses, are more than $20,000 for their per-sonal activities in the United States during the tax year. Regardless of these limits, income of Estonian entertainers or athletes is exempt from U.S. income tax if their visit to the United States is wholly or mainly supported by public funds of Estonia, its political subdivisions, or local au-thorities.

FinlandIncome that residents of Finland receive for per-forming personal services as independent con-tractors or self-employed individuals (independ-ent personal services) in the United States is exempt from U.S. income tax if they do not have a fixed base regularly available to them in the United States for performing the services. If they have a fixed base available in the United States, they are taxed on the income attributa-ble to the fixed base.

Income that residents of Finland receive for labor or personal services performed in the Uni-ted States as employees (dependent personal services) is exempt from U.S. income tax if the residents meet three requirements.

They are in the United States for no more than 183 days during any 12-month period.Their income is paid by, or on behalf of, an employer who is not a resident of the Uni-ted States.Their income is not borne by a permanent establishment, fixed base, or trade or busi-ness that the employer has in the United States.

The exemption does not apply to pay re-ceived by a resident of Finland who is an em-ployee and member of the regular complement of a ship or aircraft operated in international traf-fic by a resident of the United States.

These exemptions do not apply to income residents of Finland receive as public entertain-ers or sportsmen if the gross income, including reimbursed expenses, is more than $20,000 for their personal activities in the United States dur-ing the calendar year.

FranceIncome that residents of France receive for per-forming personal services as independent con-tractors or self-employed individuals (independ-ent personal services) in the United States is exempt from U.S. income tax if they do not

have a fixed base regularly available to them in the United States for performing the services. If they have a fixed base available in the United States, they are taxed on the income attributa-ble to the fixed base.

Income that residents of France receive for labor or personal services performed in the Uni-ted States as employees (dependent personal services) is exempt from U.S. income tax if the residents meet three requirements.

They are in the United States for no more than 183 days in any 12-month period.Their income is paid by, or on behalf of, an employer who is not a resident of the Uni-ted States.Their income is not borne by a permanent establishment or a fixed base that the em-ployer has in the United States.

Income for services performed by a resident of France as an employee and member of the regular complement of a ship or an aircraft op-erated in international traffic is exempt from tax in the United States.

These exemptions do not apply to public en-tertainers (such as theater, motion picture, ra-dio, or television artists, or musicians), or sportsmen from France who earn more than $10,000 in gross receipts, including reimbursed expenses, from their entertainment activities in the United States during the tax year. Regard-less of these limits, income of French entertain-ers or sportsmen is exempt from U.S. tax if their visit is principally supported by public funds of France.

These exemptions do not apply to directors' fees and similar payments received by a resi-dent of France as a member of the board of di-rectors of a company that is a resident of the United States.

GermanyIncome that residents of Germany receive for personal services as independent contractors or self-employed individuals are subject to the provisions of Article 7 (Business Profits) of the treaty. Under that provision, business profits are exempt from U.S. income tax unless the individ-ual has a permanent establishment in the Uni-ted States. If they have a permanent establish-ment in the United States, they are taxed on the profit attributable to the permanent establish-ment.

Income that residents of Germany receive for labor or personal services performed in the United States as employees (dependent per-sonal services) is exempt from U.S. tax if the residents meet three requirements.

They are in the United States for no more than 183 days during the calendar year.The income is paid by, or on behalf of, an employer who is not a resident of the Uni-ted States.The income is not borne by a permanent establishment that the employer has in the United States.

Pay received by a resident of Germany for services performed as an employee and mem-ber of the regular complement of a ship or air-craft operated in international traffic is exempt from U.S. tax.

The exemption does not apply to directors' fees and other similar payments received by a resident of Germany for services performed in the United States as a member of the board of directors of a company resident in the United States.

Income residents of Germany receive as public entertainers (such as theater, motion pic-ture, radio, or television artists, or musicians) or athletes is subject to U.S. tax if their gross re-ceipts, including reimbursed expenses, from their entertainment activities in the United States are more than $20,000 during the calen-dar year. Income of German entertainers or ath-letes is exempt from U.S. tax if their visit to the United States is substantially supported by pub-lic funds of Germany, its political subdivisions, or local authorities.

GreeceIncome that residents of Greece receive for la-bor or personal services (including practicing liberal and artistic professions) is exempt from U.S. income tax if they are in the United States for no more than 183 days during the tax year and the pay is not more than $10,000. The pay, regardless of amount, is exempt from U.S. in-come tax if it is for labor or personal services performed as employees of, or under contract with, a resident of Greece or a Greek corpora-tion or other entity of Greece, and if the resi-dents are in the United States for no more than 183 days during the tax year.

HungaryIncome that residents of Hungary receive for performing personal services as independent contractors or self-employed individuals (inde-pendent personal services) in the United States during the tax year is exempt from U.S. tax if the residents:

Are in the United States for no more than 183 days during the tax year, andDo not have a fixed base regularly availa-ble in the United States.

If they have a fixed base available in the United States, they are taxed on the income attributa-ble to the fixed base.

Income that residents of Hungary receive for labor or personal services performed in the Uni-ted States as employees (dependent personal services) is exempt from U.S. income tax if the residents meet three requirements.

They are in the United States for no more than 183 days during the tax year.Their income is paid by or on behalf of an employer who is not a resident of the Uni-ted States.Their income is not borne by a permanent establishment or a fixed base that the em-ployer has in the United States.

Page 6 of 61 Fileid: … ons/P901/201304/A/XML/Cycle02/source 10:02 - 11-Mar-2013The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

Page 6 Publication 901 (April 2013)

Page 7: Treaties U.S. TaxTurkmenistan, and Uzbekistan. That treaty will remain in effect until new treaties with these in-dividual countries are negotiated and ratified. Provisions of the

Pay received by an employee who is a member of the regular complement of a ship or aircraft operated by a Hungarian enterprise in international traffic is exempt from U.S. tax. If the ship or aircraft is operated by a U.S. enter-prise, the pay is subject to U.S. tax.

IcelandIncome that residents of Iceland receive for per-sonal services as independent contractors or self-employed individuals is subject to the provi-sions of Article 7 (Business Profits) of the treaty. Under that provision, business profits are ex-empt from U.S. income tax unless the individual has a permanent establishment in the United States. If they have a permanent establishment in the United States, they are taxed on the profit attributable to the permanent establishment.

Income that residents of Iceland receive for services performed in the United States as em-ployees (dependent personal services) is ex-empt from U.S. income tax if the residents meet the following requirements.

They are in the United States for no more than 183 days in any 12-month period be-ginning or ending in the tax year.Their income is paid by, or on behalf of, an employer who is not a U.S. resident.Their income is not borne by a permanent establishment that the employer has in the United States.

The exemption does not apply to directors' fees and similar payments received by a resi-dent of Iceland as a member of the board of di-rectors of a U.S. company.

Public entertainers (such as theater, motion picture, radio, or television artists, musicians, or athletes) from Iceland who earn more than $20,000 in gross receipts, including reimbursed expenses, from their entertainment activities in the United States during the tax year are sub-ject to U.S. tax.

Income received by a resident of Iceland for services performed as an employee and mem-ber of the regular complement of a ship or air-craft operated in international traffic is exempt from U.S. income tax.

IndiaIncome that residents of India receive for per-forming personal services in the United States during the tax year as independent contractors or self-employed individuals (independent per-sonal services) is exempt from U.S. income tax if the residents:

Are present in the United States for no more than 89 days during the tax year, andDo not have a fixed base regularly availa-ble to them in the United States for per-forming the services.

If they have a fixed base available, they are taxed only on income attributable to the fixed base.

Income that residents of India receive for personal services performed in the United

States as employees (dependent personal services) is exempt from U.S. income tax if the residents meet three requirements.

They are present in the United States for no more than 183 days during the tax year.The income is paid by, or on behalf of, an employer who is not a resident of the Uni-ted States.The income is not borne by a permanent establishment, fixed base, or trade or busi-ness the employer has in the United States.

The exemption does not apply to pay re-ceived by a resident of India for services per-formed as an employee aboard a ship or aircraft operated in international traffic by a U.S. enter-prise.

These exemptions do not apply to directors' fees and similar payments received by an In-dian resident as a member of the board of di-rectors of a company that is a U.S. resident.

These exemptions do not apply to income residents of India receive as public entertainers (such as theater, motion picture, radio, or televi-sion artists, or musicians) or athletes if their net income is more than $1,500 during the tax year for their entertainment activities in the United States. Regardless of this limit, the income of Indian entertainers and athletes is exempt from U.S. tax if their visit to the United States is wholly or substantially supported from the pub-lic funds of the Indian Government, its political subdivisions, or local authorities.

IndonesiaIncome that residents of Indonesia receive for performing personal services as individual con-tractors or self-employed individuals (independ-ent personal services) in the United States dur-ing the tax year is exempt from U.S. income tax if the residents:

Are present in the United States for no more than 119 days during any consecu-tive 12-month period, andDo not have a fixed base regularly availa-ble to them in the United States for per-forming the services.

If they have a fixed base available, they are taxed only on the income attributable to the fixed base.

Income that residents of Indonesia receive for personal services performed in the United States as employees (dependent personal services) is exempt from U.S. income tax if the residents meet three requirements.

They are present in the United States no more than 119 days during any consecu-tive 12-month period.The income is paid by, or on behalf of, an employer who is not a resident of the Uni-ted States.The income is not borne or reimbursed by a permanent establishment the employer has in the United States.

Pay received by an individual for services performed as an employee aboard a ship or air-craft operated by an Indonesian resident in in-ternational traffic is exempt from U.S. tax if the individual is a member of the regular comple-ment of the ship or aircraft.

These exemptions do not apply to income residents of Indonesia receive as public enter-tainers (such as theater, motion picture, radio, or television artists, or musicians) or athletes if their gross receipts, including reimbursed ex-penses, are more than $2,000 during any con-secutive 12-month period. Regardless of these limits, income of Indonesian entertainers and athletes is exempt from U.S. tax if their visit to the United States is substantially supported or sponsored by the Indonesian Government and the Indonesian competent authority certifies that the entertainers or athletes qualify for this exemption.

IrelandIncome that residents of Ireland receive for per-sonal services as independent contractors or self-employed individuals (independent per-sonal services) in the United States is exempt from U.S. income tax if they do not have a fixed base regularly available to them in the United States for performing the services. If they have a fixed base available in the United States, they are taxed on the income attributable to the fixed base.

Income that residents of Ireland receive for services performed in the United States as em-ployees (dependent personal services) is ex-empt from U.S. income tax if the residents meet the following requirements.

They are in the United States for no more than 183 days in any 12-month period be-ginning or ending in the tax year.Their income is paid by, or on behalf of, an employer who is not a U.S. resident.Their income is not borne by a permanent establishment or a fixed base that the em-ployer has in the United States.

These exemptions do not apply to directors' fees and similar payments received by a resi-dent of Ireland as a member of the board of di-rectors of a company that is a resident of the United States. However, amounts received for attending meetings in Ireland are not subject to U.S. income tax.

Income received by a resident of Ireland for services performed as an employee and mem-ber of the regular complement of a ship or air-craft operated in international traffic is exempt from U.S. income tax.

These exemptions do not apply to public en-tertainers (such as theater, motion picture, ra-dio, or television entertainers, musicians, and athletes) from Ireland who earn more than $20,000 in gross receipts, including reimbursed expenses, from their entertainment activities in the United States during the tax year.

Page 7 of 61 Fileid: … ons/P901/201304/A/XML/Cycle02/source 10:02 - 11-Mar-2013The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

Publication 901 (April 2013) Page 7

Page 8: Treaties U.S. TaxTurkmenistan, and Uzbekistan. That treaty will remain in effect until new treaties with these in-dividual countries are negotiated and ratified. Provisions of the

IsraelIncome that residents of Israel receive for per-forming personal services as independent con-tractors or as self-employed individuals (inde-pendent personal services) in the United States during the tax year is exempt from U.S. income tax if they are in the United States for no more than 182 days during the tax year.

Income that residents of Israel receive for la-bor or personal services performed in the Uni-ted States as employees (dependent personal services), including income for services per-formed by an officer of a corporation or com-pany, is exempt from U.S. income tax if the resi-dents meet four requirements.

They are in the United States for no more than 182 days during the tax year.They are employees of a resident of, or a permanent establishment in, Israel.Their income is not borne by a permanent establishment that the employer has in the United States.Their income is subject to Israeli tax.

The exemption does not apply to pay re-ceived by an employee for labor or personal services performed as a member of the regular complement of a ship or an aircraft operated in international traffic by a U.S. resident.

These exemptions do not apply to income that residents of Israel receive as public enter-tainers (such as theater, motion picture, radio, or television artists, musicians, or athletes), if the gross amount of the income is more than $400 for each day they are in the United States performing the services.

ItalyIncome that residents of Italy receive for per-sonal services as independent contractors or self-employed individuals (independent per-sonal services) in the United States is exempt from U.S. income tax if they do not have a fixed base regularly available to them in the United States for performing the services. If they have a fixed base available in the United States, they are taxed on the income attributable to the fixed base.

Income that residents of Italy receive for la-bor or personal services performed in the Uni-ted States as employees (dependent personal services) is exempt from U.S. income tax if the following requirements are met.

The residents are in the United States for no more than 183 days during the tax year.The income is paid by, or on behalf of, an employer who is not a resident of the Uni-ted States.The income is not borne by a permanent establishment or a fixed base that the em-ployer has in the United States.

These exemptions do not apply to directors' fees and similar payments received by a resi-dent of Italy for services performed in the United States as a member of the board of directors of a company that is a U.S. resident.

Pay received for employment regularly exer-cised aboard a ship or aircraft operated by a U.S. enterprise is subject to U.S. tax.

These exemptions do not apply to income residents of Italy receive as public entertainers (such as theater, motion picture, radio, or televi-sion artists, musicians, or athletes) if they are present in the United States for more than 90 days during the tax year or their gross receipts, including reimbursed expenses, are more than $20,000 during the tax year for their entertain-ment activities in the United States.

JamaicaIncome that residents of Jamaica receive for the performance of personal services as inde-pendent contractors or self-employed individu-als (independent personal services) in the Uni-ted States during the tax year is exempt from U.S. income tax if the residents:

Are in the United States for no more than 89 days during the tax year,Do not have a fixed base regularly availa-ble to them in the United States for per-forming their services, andEarn net income for those services that is not more than $5,000 during the tax year if the income is from a U.S. contractor.

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

Income that residents of Jamaica receive for personal services performed in the United States as employees (dependent personal services) is exempt from U.S. income tax if the residents meet four requirements.

They are in the United States for no more than 183 days during the tax year.Their income is paid by or for an employer who is not a resident of the United States.Their income is not borne by a permanent establishment or a fixed base that the em-ployer has in the United States.Their net income received for the services is not more than $5,000 during the tax year.

Pay received from employment as a mem-ber of the regular complement of a ship or an aircraft operated in international traffic by a Ja-maican enterprise is exempt from U.S. tax. If the ship or aircraft is operated by a U.S. enter-prise, the pay is subject to U.S. tax.

These exemptions do not apply to income that residents of Jamaica receive for performing services in the United States as entertainers, such as theater, motion picture, radio, or televi-sion artists, musicians, or athletes, if the gross receipts (excluding reimbursements for expen-ses) from the services are more than $400 a day or $5,000 for the tax year.

Directors' fees received by residents of Ja-maica for services performed in the United States as members of boards of directors of U.S. corporations are exempt from U.S. tax if the fees (excluding reimbursed expenses) are

not more than $400 per day for each day the di-rectors are present in the United States to per-form the services.

JapanIncome that residents of Japan receive for per-sonal services as independent contractors or self-employed individuals is subject to the provi-sions of Article 7 (business profits) of the treaty. Under that provision, business profits are ex-empt from U.S. income tax unless the individual has a permanent establishment in the United States. If they have a permanent establishment in the United States, they are taxed on the prof-its attributable to the permanent establishment.

Income that residents of Japan receive for services performed in the United States as em-ployees (dependent personal services) is ex-empt from U.S. income tax if the residents meet the following requirements.

They are in the United States for no more than 183 days in any 12-month period be-ginning or ending in the tax year.Their income is paid by, or on behalf of, an employer who is not a U.S. resident.Their income is not borne by a permanent establishment that the employer has in the United States.

The exemption does not apply to directors' fees and similar payments received by a resi-dent of Japan for services performed as a mem-ber of the board of directors of a company that is a resident of the United States.

The exemption does not apply to a resident of Japan who performs services as an em-ployee aboard a ship or an aircraft operated in international traffic by a U.S. resident.

Public entertainers (such as theater, motion picture, radio, or television artists, musicians, or athletes) from Japan who earn more than $10,000 in gross receipts, including reimbursed expenses, from their entertainment activities in the United States during the tax year are sub-ject to U.S. tax.

KazakhstanIncome that residents of Kazakhstan receive for performing personal services as independent contractors or self-employed individuals (inde-pendent personal services) in the United States is exempt from U.S. income tax if:

The residents are in the United States for no more than 183 days in any consecutive 12-month period, andThe income is not attributable to a fixed base in the United States which is regularly available to the residents.

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

Page 8 of 61 Fileid: … ons/P901/201304/A/XML/Cycle02/source 10:02 - 11-Mar-2013The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

Page 8 Publication 901 (April 2013)

Page 9: Treaties U.S. TaxTurkmenistan, and Uzbekistan. That treaty will remain in effect until new treaties with these in-dividual countries are negotiated and ratified. Provisions of the

Income that residents of Kazakhstan receive for employment in the United States (depend-ent personal services) is exempt from U.S. in-come tax if the following three requirements are met.

The resident is in the United States for no more than 183 days in any 12-month pe-riod.The income is paid by, or on behalf of, an employer who is not a resident of the Uni-ted States.The income is not borne by a permanent establishment or a fixed base that the em-ployer has in the United States.

Income derived by a resident of Kazakhstan from employment as a member of the regular complement of a ship or aircraft operated in in-ternational traffic is exempt from U.S. tax.

These exemptions do not apply to directors' fees and similar payments received by a resi-dent of Kazakhstan as a member of the board of directors or similar body of a company that is a U.S. resident.

Korea, SouthIncome that residents of South Korea receive for performing personal services as independ-ent contractors or self-employed individuals (in-dependent personal services) in the United States during the tax year is exempt from U.S. tax if the residents:

Are in the United States for no more than 182 days during the tax year,Earn income for those services that is not more than $3,000 during the tax year, andDo not maintain a fixed base in the United States for more than 182 days during the tax year.

If they maintain a fixed base in the United States for more than 182 days, they are taxed on the income attributable to the fixed base.

Income that residents of Korea receive for labor or personal services performed in the Uni-ted States as employees (dependent personal services), including pay for services performed as an officer of a corporation, is exempt from U.S. tax if the residents meet four requirements.

They are in the United States for no more than 182 days during the tax year.They are employees of a resident of Korea or of a permanent establishment main-tained in Korea.Their compensation is not borne by a per-manent establishment that the employer has in the United States.Their income for those services is not more than $3,000.

Pay received by employees who are mem-bers of the regular complement of a ship or air-craft operated by a resident of Korea in interna-tional traffic is exempt.

LatviaIncome that residents of Latvia receive for per-forming personal services as independent con-tractors or self-employed individuals (independ-ent personal services) in the United States is exempt from U.S. income tax if the residents:

Are in the United States for no more than 183 days in any 12-month period begin-ning or ending in the tax year, andDo not have a fixed base regularly availa-ble to them in the United States for per-forming the services.

If they have a fixed base available, they are taxed only on the income attributable to the fixed base.

Income that residents of Latvia receive for services performed in the United States as em-ployees (dependent personal services) is ex-empt from U.S. income tax if the following re-quirements are met.

The resident is in the United States for no more than 183 days in any 12-month pe-riod beginning or ending in the tax year.The income is paid by, or on behalf of, an employer who is not a U.S. resident.The income is not borne by a permanent establishment or a fixed base that the em-ployer has in the United States.

The exemption does not apply to pay re-ceived for employment as a member of the reg-ular complement of a ship or an aircraft oper-ated in international traffic by a U.S. enterprise.

The exemptions do not apply to directors' fees and similar payments received by a resi-dent of Latvia as a member of the board of di-rectors or similar body of a company that is a U.S. resident.

The exemptions do not apply to income resi-dents of Latvia receive as public entertainers (such as theater, motion picture, radio, or televi-sion artists, or musicians) or sportsmen if their gross receipts, including reimbursed expenses, are more than $20,000 for their personal activi-ties in the United States during the tax year. Re-gardless of these limits, income of Latvian en-tertainers or athletes is exempt from U.S. income tax if their visit to the United States is wholly or mainly supported by public funds of Latvia, its political subdivisions, or local authori-ties.

LithuaniaIncome that residents of Lithuania receive for performing personal services as independent contractors or self-employed individuals (inde-pendent personal services) in the United States is exempt from U.S. income tax if the residents:

Are in the United States for no more than 183 days in any 12-month period begin-ning or ending in the tax year, andDo not have a fixed base regularly availa-ble to them in the United States for per-forming the services.

If they have a fixed base available, they are taxed only on the income attributable to the fixed base.

Income that residents of Lithuania receive for services performed in the United States as employees (dependent personal services) is exempt from U.S. income tax if the following re-quirements are met.

The resident is in the United States for no more than 183 days in any 12-month pe-riod beginning or ending in the tax year.The income is paid by, or on behalf of, an employer who is not a U.S. resident.The income is not borne by a permanent establishment or a fixed base that the em-ployer has in the United States.

The exemption does not apply to pay re-ceived for employment as a member of the reg-ular complement of a ship or an aircraft oper-ated in international traffic by a U.S. enterprise.

The exemptions do not apply to directors' fees and similar payments received by a resi-dent of Lithuania as a member of the board of directors or similar body of a company that is a U.S. resident.

The exemptions do not apply to income resi-dents of Lithuania receive as public entertainers (such as theater, motion picture, radio, or televi-sion artists, or musicians) or sportsmen if their gross receipts, including reimbursed expenses, are more than $20,000 for their personal activi-ties in the United States during the tax year. Re-gardless of these limits, income of Lithuanian entertainers or athletes is exempt from U.S. in-come tax if their visit to the United States is wholly or mainly supported by public funds of Lithuania, its political subdivisions, or local au-thorities.

LuxembourgIncome that residents of Luxembourg receive for personal services as independent contrac-tors or self-employed individuals (independent personal services) in the United States is ex-empt from U.S. income tax if they do not have a fixed base regularly available to them in the Uni-ted States for performing the services. If they have a fixed base available in the United States, they are taxed on the income attributa-ble to the fixed base.

Income that residents of Luxembourg re-ceive for services performed in the United States as employees (dependent personal services) is exempt from U.S. income tax if the residents meet the following requirements.

They are in the United States for no more than 183 days in any 12-month period be-ginning or ending in the tax year.Their income is paid by, or on behalf of, an employer who is not a U.S. resident.Their income is not borne by a permanent establishment or a fixed base that the em-ployer has in the United States.

The exemption does not apply to pay re-ceived for employment exercised continuously or predominantly aboard a ship or aircraft oper-ated in international traffic by a U.S. enterprise.

The exemptions do not apply to directors' fees and similar payments received by a resi-dent of Luxembourg for services performed in

Page 9 of 61 Fileid: … ons/P901/201304/A/XML/Cycle02/source 10:02 - 11-Mar-2013The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

Publication 901 (April 2013) Page 9

Page 10: Treaties U.S. TaxTurkmenistan, and Uzbekistan. That treaty will remain in effect until new treaties with these in-dividual countries are negotiated and ratified. Provisions of the

the United States as a member of the board of directors of a company that is a resident of the United States.

The exemptions do not apply to public en-tertainers (such as theater, motion picture, ra-dio, or television artists, musicians, or athletes) from Luxembourg who earn more than $10,000 in gross receipts, including reimbursed expen-ses, from their entertainment activities in the United States during the tax year.

MaltaIncome that residents of Malta receive for per-sonal services as independent contractors or self-employed individuals is subject to the provi-sions of Article 7 (Business Profits) of the treaty. Under that provision, business profits are ex-empt from U.S. income tax unless the individual has a permanent establishment in the United States. If they have a permanent establishment in the United States, they are taxed on the prof-its attributable to the permanent establishment.

Income that residents of Malta receive for services performed in the United States as em-ployees (dependent personal services) is ex-empt from U.S. income tax if the residents meet the following requirements.

They are in the United States for no more than 183 days in any 12-month period be-ginning or ending in the tax year.Their income is paid by, or on behalf of, an employer who is not a U.S. resident.Their income is not borne by a permanent establishment that the employer has in the United States.

The exemption does not apply to directors' fees and similar payments received by a resi-dent of Malta for services performed in the Uni-ted States as a member of the board of direc-tors of a company that is a resident of the United States.

Public entertainers (such as theater, motion picture, radio, or television artists, musicians, or athletes) from Malta who earn more than $20,000 in gross receipts, including reimbursed expenses, from their entertainment activities in the United States during the tax year are sub-ject to U.S. tax.

Income received by a resident of Malta for employment aboard a ship or an aircraft oper-ated in international traffic is exempt from U.S. income tax if the individual is a member of the regular complement of the ship or aircraft.

MexicoIncome that residents of Mexico receive for per-forming personal services as independent con-tractors or self-employed individuals (independ-ent personal services) in the United States is exempt from U.S. income tax if the residents:

Are in the United States for no more than 182 days in a 12-month period, andDo not have a fixed base that they regu-larly use for performing the services.

If they have a fixed base available, they are taxed only on income attributable to the fixed base.

Income that residents of Mexico receive for employment in the United States (dependent personal services) is exempt from U.S. tax if the following three requirements are met.

The resident is present in the United States for no more than 183 days in a 12-month period.The income is paid by, or on behalf of, an employer who is not a resident of the Uni-ted States.The income is not borne by a permanent establishment or fixed base that the em-ployer has in the United States.

These exemptions do not apply to directors' fees and similar payments received by a resi-dent of Mexico for services performed outside Mexico as a director or overseer of a company that is a U.S. resident.

These exemptions do not apply to income residents of Mexico receive as public entertain-ers (such as theater, motion picture, radio, or television artists, or musicians) or athletes if the income, including reimbursed expenses, is more than $3,000 during the tax year for their entertainment activities in the United States. This includes income from activities performed in the United States relating to the entertainer or athlete's reputation, such as endorsements of commercial products. Regardless of this limit, the income of Mexican entertainers and ath-letes is exempt from U.S. tax if their visit to the United States is substantially supported by pub-lic funds of Mexico, its political subdivisions, or local authorities.

MoroccoIncome that residents of Morocco receive for performing personal services as independent contractors or as self-employed persons (inde-pendent personal services) in the United States during the tax year is exempt from U.S. income tax if the residents:

Are in the United States for no more than 182 days during the tax year,Do not maintain a fixed base in the United States for more than 89 days during the tax year, andEarn total income for those services that is not more than $5,000.

If they have a fixed base in the United States for more than 89 days, they are taxed only on the income attributable to the fixed base.

Income that residents of Morocco receive for labor or personal services performed in the United States as employees (dependent per-sonal services) is exempt from U.S. income tax if the residents meet three requirements.

They are in the United States for less than 183 days during the tax year.They are employees of a resident of Mo-rocco or of a permanent establishment of a resident of a country other than Morocco if the permanent establishment is located in Morocco.

Their income is not borne by a permanent establishment that the employer has in the United States.

Compensation received for services per-formed by a member of the board of directors of a corporation does not qualify for this exemp-tion.

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

These exemptions do not apply to income received for services performed in the United States by professional entertainers, including theater, film, radio, and television performers, musicians, and athletes, unless the services are performed by, or for the account of, a Moroccan nonprofit organization.

NetherlandsIncome that residents of the Netherlands re-ceive for performing personal services as inde-pendent contractors or self-employed individu-als (independent personal services) in the United States is exempt from U.S. income tax if the income is not attributable to a fixed base in the United States that is regularly available for performing the services.

Income that residents of the Netherlands re-ceive for employment in the United States (de-pendent personal services) is exempt from U.S. income tax if the following three requirements are met.

The resident is in the United States for no more than 183 days during the tax year.The income is paid by, or on behalf of, an employer who is not a U.S. resident.The income is not borne by a permanent establishment or fixed base the employer has in the United States.

Income received by a Netherlands resident for employment as a member of the regular complement of a ship or aircraft operated in in-ternational traffic is exempt from U.S. tax.

These exemptions do not apply to directors' fees and other similar payments received by a resident of the Netherlands for services per-formed outside the Netherlands as a member of the board of directors of a company that is a resident of the United States.

These exemptions do not apply to income residents of the Netherlands receive as public entertainers (such as theater, motion picture, radio, or television artists, or musicians) or ath-letes if the gross income, including reimbursed expenses, is more than $10,000.

New ZealandIncome that residents of New Zealand receive for performing personal services as independ-ent contractors or self-employed individuals is

Page 10 of 61 Fileid: … ons/P901/201304/A/XML/Cycle02/source 10:02 - 11-Mar-2013The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

Page 10 Publication 901 (April 2013)

Page 11: Treaties U.S. TaxTurkmenistan, and Uzbekistan. That treaty will remain in effect until new treaties with these in-dividual countries are negotiated and ratified. Provisions of the

subject to the provisions of Article 7 (Business Profits) of the treaty. Under that provision, busi-ness profits are exempt from U.S. income tax unless the individual has a permanent estab-lishment in the United States. If they have a per-manent establishment in the United States, they are taxed on the profits attributable to the per-manent establishment.

Income that residents of New Zealand re-ceive for labor or personal services performed in the United States as employees (dependent personal services) is exempt from U.S. income tax if the residents meet these requirements.

They are present in the United States for no more than 183 days in any consecutive 12-month period.Their income is paid by or on behalf of an employer that is not a resident of the Uni-ted States.Their income is not borne by a permanent establishment that the employer has in the United States.

The exemption does not apply to public en-tertainers (artists, athletes, etc.) from New Zea-land who earn more than $10,000 in gross re-ceipts, including reimbursed expenses, from their entertainment activities in the United States during the tax year.

Pay received by a New Zealand resident as an employee and member of the regular com-plement of a ship or aircraft operated in interna-tional traffic is exempt from U.S. tax.

NorwayIncome that residents of Norway receive for performing personal services as independent contractors or self-employed individuals (inde-pendent personal services) in the United States during the tax year is exempt from U.S. income tax if the residents:

Are present in the United States for no more than 182 days during the tax year, andDo not maintain a fixed base in the United States for more than 182 days during the tax year.

If they do not meet requirement (2), they are taxed only on the income attributable to the fixed base.

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

Income that residents of Norway receive for labor or personal services performed in the Uni-ted States as employees (dependent personal services) is exempt from U.S. income tax if the residents meet three requirements.

They are in the United States less than 183 days during the tax year.They are employees of a resident of Nor-way or of a permanent establishment of a resident of a state other than Norway if the

permanent establishment is situated in Norway.Their income is not borne by a permanent establishment that the employer has in the United States.

The exemption does not apply to a resident of Norway who performs services as an em-ployee aboard a ship or an aircraft operated by a United States resident in international traffic or in fishing on the high seas if the resident of Norway is a member of the regular complement of the ship or aircraft.

PakistanResidents of Pakistan who perform personal services (including professional services) for or on behalf of a resident of Pakistan while in the United States for no more than 183 days during the tax year are exempt from U.S. income tax on the income from the services if they are sub-ject to Pakistani tax.

PhilippinesIncome that residents of the Philippines receive for performing personal services as independ-ent contractors or as self-employed individuals (independent personal services) in the United States during the tax year is exempt from U.S. income tax if the residents:

Are in the United States for no more than 89 days during the tax year,Earn gross income for those services that is not more than $10,000 for the tax year if the income is from U.S. contractors, andDo not have a fixed base regularly availa-ble to them in the United States for per-forming their services.

If they have a fixed base available in the United States, they are taxed only on the income attrib-utable to the fixed base. There is no dollar limit for condition (2) if the contractor is a resident of a country other than the United States.

Income that residents of the Philippines re-ceive for personal services performed in the United States as employees (dependent per-sonal services) is exempt from U.S. income tax if the residents meet three requirements.

They are in the United States for no more than 89 days during the tax year.They are employees of a resident of the Philippines or of a permanent establish-ment maintained in the Philippines.Their income is not borne by a permanent establishment that the employer has in the United States.

Pay received by an employee of a resident of the Philippines for personal services per-formed as a member of the regular complement of a ship or an aircraft operated in international traffic by a resident of the Philippines is exempt from U.S. tax.

These exemptions do not apply to income residents of the Philippines receive for perform-ing services (both independent and dependent personal services) in the United States as en-tertainers, such as theater, motion picture, ra-dio, or television artists, musicians, or athletes,

if the income is more than $100 a day or $3,000 for the tax year. Regardless of these limits, in-come of Philippine entertainers is exempt from U.S. tax if their visit to the United States is sub-stantially supported or sponsored by the Philip-pine Government and the entertainers are certi-fied as qualified for this exemption by the Philippine competent authority.

PolandIncome that residents of Poland receive for per-forming personal services as independent con-tractors or self-employed individuals (independ-ent personal services) in the United States is exempt from U.S. income tax if they are in the United States for no more than 182 days during the tax year.

Income that residents of Poland receive for labor or personal services performed as em-ployees (dependent personal services), includ-ing services performed by an officer of a corpo-ration or company, in the United States during the tax year is exempt from U.S. income tax if the residents meet three requirements.

They are in the United States for no more than 182 days during the tax year.Their income is paid by or on behalf of an employer who is not a U.S. resident.Their income is not borne by a permanent establishment that the employer has in the United States.

Pay received by employees who are mem-bers of the regular complement of a ship or air-craft operated by a resident of Poland in inter-national traffic is exempt from U.S. tax.

PortugalIncome that residents of Portugal receive for performing personal services as independent contractors or self-employed individuals (inde-pendent personal services) in the United States is exempt from U.S. income tax if the residents:

Are in the United States for no more than 182 days in any 12-month period, andDo not have a fixed base regularly availa-ble to them in the United States for per-forming the activities.

If they have a fixed base available, they are taxed only on the income attributable to the fixed base.

Income that residents of Portugal receive for employment in the United States (dependent personal services) is exempt from U.S. income tax if the following three requirements are met.

The resident is in the United States for no more than 183 days in any 12-month pe-riod.The income is paid by, or on behalf of, an employer who is not a U.S. resident.The income is not borne by a permanent establishment or fixed base that the em-ployer has in the United States.

Income received by a resident of Portugal for employment as a member of the regular complement of a ship or aircraft operated in in-ternational traffic is exempt from U.S. tax.

Page 11 of 61 Fileid: … ons/P901/201304/A/XML/Cycle02/source 10:02 - 11-Mar-2013The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

Publication 901 (April 2013) Page 11

Page 12: Treaties U.S. TaxTurkmenistan, and Uzbekistan. That treaty will remain in effect until new treaties with these in-dividual countries are negotiated and ratified. Provisions of the

These exemptions do not apply to income residents of Portugal receive as public enter-tainers (such as theater, motion picture, radio, or television artists, or musicians) or athletes if that income, including reimbursed expenses, is more than $10,000. The income of Portuguese entertainers and athletes is exempt from U.S. tax if their visit to the United States is substan-tially supported by public funds of Portugal or its political or administrative subdivisions.

These exemptions do not apply to directors' fees and similar payments received by a resi-dent of Portugal for services performed outside of Portugal as a member of the board of direc-tors of a company that is a resident of the Uni-ted States.

RomaniaIncome that residents of Romania receive for performing personal services as independent contractors or self-employed individuals (inde-pendent personal services) in the United States during the tax year is exempt from U.S. income tax if the residents:

Are present in the United States for no more than 182 days during the tax year, andDo not maintain a permanent establish-ment in the United States with which the in-come is effectively connected.

Income that residents of Romania receive for labor or personal services performed as em-ployees (dependent personal services), includ-ing services performed by an officer of a corpo-ration or company, in the United States during the tax year is exempt from U.S. income tax if the residents meet these requirements.

They are in the United States for no more than 182 days during the tax year.They are employees of a resident of Ro-mania or of a permanent establishment maintained in Romania by a resident of the United States.Their income is not borne by a permanent establishment that the employer has in the United States.

These exemptions do not apply to entertain-ers, such as theater, motion picture, radio, or television artists, musicians, or athletes, who are present in the United States for more than 90 days during the tax year (90 days or more if the entertainers are employees) or who earn gross income as entertainers in the United States of more than $3,000 during the tax year ($3,000 or more if they are employees). How-ever, the exemptions do apply, without regard to the 90 day, $3,000 requirement, if the enter-tainers are present in the United States by spe-cific arrangements between the United States and Romania.

Pay received by employees who are mem-bers of the regular complement of a ship or air-craft operated by a resident of Romania in inter-national traffic is exempt from U.S. tax.

RussiaIncome that residents of Russia receive for per-forming personal services as independent con-tractors or self-employed individuals (independ-ent personal services) in the United States is exempt from U.S. income tax if:

The residents are in the United States for no more than 183 days during the calendar year, orThe income is not attributable to a fixed base in the United States which is regularly available to the residents.

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

Income that residents of Russia receive for employment in the United States (dependent personal services) is exempt from U.S. income tax if the following three requirements are met.

The resident is in the United States for no more than 183 days during the calendar year.The income is paid by, or on behalf of, an employer who is not a resident of the Uni-ted States.The income is not borne by a permanent establishment or a fixed base that the em-ployer has in the United States.

However, income from employment directly connected with a place of business that is not a permanent establishment is exempt if the resi-dent is present in the United States not longer than 12 consecutive months. For this purpose, a place of business means a construction site, assembly or installation project, or drilling oper-ation.

Income derived by a resident of Russia from employment as a member of the regular com-plement of a ship or aircraft operated in interna-tional traffic is exempt from U.S. tax.

Income from technical services directly con-nected with the application of a right or property giving rise to a royalty is exempt if those serv-ices are provided as part of a contract granting the use of the right or property.

These exemptions do not apply to directors' fees and similar payments received by a resi-dent of Russia as a member of the board of di-rectors or similar body of a company that is a resident of the United States.

Slovak RepublicIncome that residents of the Slovak Republic re-ceive for performing personal services as inde-pendent contractors or self-employed individu-als (independent personal services) in the United States is exempt from U.S. income tax if the residents:

Are present in the United States for no more than 183 days in any 12-month pe-riod, andDo not have a fixed base regularly availa-ble to them in the United States for per-forming the activities.

If they have a fixed base available, they are taxed only on income attributable to the fixed base.

Income that residents of the Slovak Repub-lic receive for employment in the United States (dependent personal services) is exempt from U.S. income tax if the following three require-ments are met.

The resident is present in the United States for no more than 183 days in any 12-month period.The income is paid by, or on behalf of, an employer who is not a U.S. resident.The income is not borne by a permanent establishment or a fixed base that the em-ployer has in the United States.

These exemptions do not apply to income residents of the Slovak Republic receive as public entertainers (such as theater, motion pic-ture, radio, or television artists, or musicians) or sportsmen if their gross receipts, including re-imbursed expenses, are more than $20,000 during the tax year. Regardless of these limits, income of Slovak entertainers and sportsmen is exempt from U.S. income tax if their visit to the United States is substantially supported by pub-lic funds of the Slovak Republic, its political subdivisions, or local authorities, or the visit is made pursuant to a specific arrangement be-tween the United States and the Slovak Repub-lic.

These exemptions do not apply to directors' fees and similar payments received by a resi-dent of the Slovak Republic for services per-formed in the United States as a member of the board of directors of a company that is a resi-dent of the United States.

Income from employment as a member of the regular complement of a ship or aircraft op-erated by a Slovak enterprise in international traffic is exempt from U.S. income tax. If the ship or aircraft is operated by a U.S. enterprise, the income is subject to U.S. income tax.

SloveniaIncome that residents of Slovenia receive for personal services as independent contractors or self-employed individuals (independent per-sonal services) in the United States is exempt from U.S. income tax if they do not have a fixed base regularly available to them in the United States for performing the services. If they have a fixed base available in the United States, they are taxed on the income attributable to the fixed base.

Income that residents of Slovenia receive for services performed in the United States as em-ployees (dependent personal services) is ex-empt from U.S. income tax if the residents meet the following requirements.

They are in the United States for no more than 183 days in any 12-month period be-ginning or ending in the tax year.Their income is paid by, or on behalf of, an employer who is not a U.S. resident.Their income is not borne by a permanent establishment or a fixed base that the em-ployer has in the United States.

Page 12 of 61 Fileid: … ons/P901/201304/A/XML/Cycle02/source 10:02 - 11-Mar-2013The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

Page 12 Publication 901 (April 2013)

Page 13: Treaties U.S. TaxTurkmenistan, and Uzbekistan. That treaty will remain in effect until new treaties with these in-dividual countries are negotiated and ratified. Provisions of the

These exemptions do not apply to directors' fees and similar payments received by a resi-dent of Slovenia for services performed in the United States as a member of the board of di-rectors of a company that is a resident of the United States.

Income received by a Slovenian resident for employment as a member of the regular com-plement of a ship or aircraft operated in interna-tional traffic is exempt from U.S. tax.

These exemptions do not apply to income residents of Slovenia receive as public enter-tainers (such as theater, motion picture, radio, or television artists, or musicians) or athletes if their gross receipts, including reimbursed ex-penses, are more than $15,000 during the tax year. Regardless of these limits, income of Slovenian entertainers or athletes is exempt from U.S. tax if their visit to the United States is wholly or mainly paid by public funds of either the United States or Slovenia or their political subdivisions, or local authorities.

South AfricaIncome that residents of South Africa receive for performing personal services as independ-ent contractors or self-employed individuals (in-dependent personal services) in the United States is exempt from U.S. income tax if the residents:

Are in the United States for no more than 183 days in any 12-month period begin-ning or ending in the tax year, andDo not have a fixed base regularly availa-ble to them in the United States for per-forming the services.

If they have a fixed base available, they are taxed only on income attributable to the fixed base.

Income that residents of South Africa re-ceive for services performed in the United States as employees (dependent personal services) is exempt from U.S. income tax if the following requirements are met.

The resident is in the United States for no more than 183 days in any 12-month pe-riod beginning or ending in the tax year.The income is paid by, or on behalf of, an employer who is not a U.S. resident.The income is not borne by a permanent establishment or a fixed base that the em-ployer has in the United States.

These exemptions do not apply to directors' fees and similar payments received by a resi-dent of South Africa for services performed in the United States as a member of the board of directors of a company resident in the United States.

These exemptions do not apply to income residents of South Africa receive as public en-tertainers (such as theater, motion picture, ra-dio, or television artists, or musicians) or ath-letes if their gross receipts, including reimbursed expenses, are more than $7,500 during the tax year. Regardless of these limits, income of South African entertainers or athletes is exempt from U.S. income tax if their visit to

the United States is wholly or mainly supported by public funds of South Africa, its political sub-divisions, or local authorities.

Income received by a resident of South Af-rica for services performed as an employee and member of the complement of a ship or aircraft operated in international traffic is exempt from U.S. income tax.

SpainIncome that residents of Spain receive as inde-pendent contractors or self-employed individu-als (independent personal services) in the Uni-ted States is exempt from U.S. income tax if the residents do not have a fixed base available to them in the United States for performing the services. If they have a fixed base, they are taxed only on the income attributable to the fixed base.

Income that residents of Spain receive for personal services performed in the United States as employees (dependent personal services) is exempt from U.S. income tax if:

The residents are present in the United States no more than 183 days in any 12-month period,The income is paid by, or on behalf of, an employer who is not a U.S. resident, andThe income is not borne by a permanent establishment or fixed base the employer has in the United States.

The exemption does not apply to pay re-ceived by employees who are members of a regular complement of a ship or aircraft oper-ated in international traffic by a U.S. enterprise.

These exemptions do not apply to public en-tertainers (such as theater, motion picture, ra-dio, or television artists, or musicians) or ath-letes from Spain who earn more than $10,000 in income, including reimbursed expenses, from their entertainment activities in the United States during the tax year. Regardless of these limits, Spanish entertainers and athletes are ex-empt from U.S. tax if their visit to the United States is substantially supported by public funds of Spain, a political subdivision, or local authority.

Sri LankaIncome that residents of Sri Lanka receive for performing personal services as independent contractors or self-employed individuals (inde-pendent personal services) in the United States during the tax year is exempt from U.S. income tax if the residents:

Are in the United States for no more than 183 days in any 12-month period, orDo not have a fixed base regularly availa-ble to them in the United States for the pur-pose of performing the services.

If they have a fixed base available in the United States, they are taxed on the income at-tributable to the fixed base.

Income that residents of Sri Lanka receive for services performed in the United States as

employees (dependent personal services) is exempt from U.S. income tax if the residents meet the following requirements.

They are in the United States for no more than 183 days in any 12-month period.Their income is paid by, or on behalf of, an employer who is not a U.S. resident.Their income is not borne by a permanent establishment or a fixed base that the em-ployer has in the United States.

Income received from employment as a member of the regular complement of a ship or an aircraft operated in international traffic by a Sri Lanka enterprise is exempt from U.S. tax. If the ship or aircraft is operated by a U.S. enter-prise, the income is subject to U.S. tax.

These exemptions do not apply to public en-tertainers (such as theater, motion picture, ra-dio, or television entertainers, musicians, and athletes) from Sri Lanka who earn more than $6,000 in gross receipts, including reimbursed expenses, from their entertainment activities in the United States during the tax year. Regard-less of these limits, income of Sri Lanka enter-tainers is exempt from U.S. income tax if their visit to the United States is directly or indirectly supported wholly or substantially by public funds of Sri Lanka or the United States, their political subdivisions, or local authorities.

These exemptions do not apply to directors' fees and other compensation received by a res-ident of Sri Lanka for services performed in the United States as a member of the board of di-rectors of a company resident in the United States.

SwedenIncome that residents of Sweden receive for performing personal services as independent contractors or self-employed individuals (inde-pendent personal services) in the United States during the tax year is exempt from U.S. income tax if they do not have a fixed base regularly available to them in the United States for per-forming the services. If they have a fixed base available in the United States, they are taxed on the income attributable to the fixed base.

Income that residents of Sweden receive for labor or personal services performed in the Uni-ted States as employees (dependent personal services) is exempt from U.S. income tax if the residents meet three requirements.

They are in the United States for no more than 183 days during any consecutive 12-month period.Their income is paid by, or on behalf of, an employer who is not a resident of the Uni-ted States.Their income is not borne by a permanent establishment or a fixed base that the em-ployer has in the United States.

Income received by a resident of Sweden for employment as a member of the regular complement of a ship or aircraft operated in in-ternational traffic is exempt from U.S. tax.

Page 13 of 61 Fileid: … ons/P901/201304/A/XML/Cycle02/source 10:02 - 11-Mar-2013The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

Publication 901 (April 2013) Page 13

Page 14: Treaties U.S. TaxTurkmenistan, and Uzbekistan. That treaty will remain in effect until new treaties with these in-dividual countries are negotiated and ratified. Provisions of the

These exemptions do not apply to income residents of Sweden receive as public enter-tainers (such as theater, motion picture, radio, or television artists, or musicians) or athletes if the gross income, including reimbursed expen-ses, is more than $6,000 for any 12-month pe-riod.

These exemptions do not apply to directors' fees received by a resident of Sweden for serv-ices performed outside of Sweden as a member of the board of directors of a company that is a resident of the United States.

SwitzerlandIncome that residents of Switzerland receive for personal services as independent contractors or self-employed individuals (independent per-sonal services) that they perform during the tax year in the United States is exempt from U.S. income tax if they do not have a fixed base reg-ularly available to them in the United States for performing the services. If they have a fixed base available in the United States, they are taxed on the income attributable to the fixed base.

Income that residents of Switzerland receive for services performed in the United States as employees (dependent personal services) is exempt from U.S. income tax if the residents meet the following requirements.

They are in the United States for no more than 183 days in any 12-month period be-ginning or ending in the tax year.Their income is paid by, or on behalf of, an employer who is not a U.S. resident.Their income is not borne by a permanent establishment or a fixed base that the em-ployer has in the United States.

These exemptions do not apply to directors' fees and similar payments received by a resi-dent of Switzerland as a member of the board of directors of a company that is a resident of the United States.

These exemptions do not apply to public en-tertainers (such as theater, motion picture, ra-dio, or television entertainers, musicians, and athletes) from Switzerland who earn more than $10,000 in gross receipts, including reimbursed expenses, from their entertainment activities in the United States during the tax year.

Income received by a resident of Switzer-land for services performed as an employee and member of the regular complement of a ship or aircraft operated in international traffic is exempt from U.S. income tax.

ThailandIncome that residents of Thailand receive for performing personal services as independent contractors or as self-employed individuals (in-dependent personal services) in the United States during the tax year is exempt from U.S. income tax if the residents:

Are in the United States for no more than 89 days during the tax year, and

Do not have a fixed base regularly availa-ble to them in the United States for per-forming their services.

If they have a fixed base available in the United States, they are taxed only on the income attrib-utable to the fixed base.

This exemption does not apply if a resident of Thailand earns more than $10,000 for inde-pendent personal services and that income is paid by a U.S. resident or borne by a perma-nent establishment or fixed base in the United States.

Income that residents of Thailand receive for services performed in the United States as em-ployees (dependent personal services) is ex-empt from U.S. income tax if the following re-quirements are met.

The resident is in the United States for no more than 183 days in any 12-month pe-riod beginning or ending in the tax year.The income is paid by, or on behalf of, an employer who is not a U.S. resident.The income is not borne by a permanent establishment or a fixed base that the em-ployer has in the United States.

These exemptions do not apply to directors' fees and similar payments received by a resi-dent of Thailand for services performed outside of Thailand as a member of the board of direc-tors of a company that is a resident of the Uni-ted States.

These exemptions do not apply to income residents of Thailand receive for performing services in the United States as entertainers (such as theater, motion picture, radio, or televi-sion artists, or musicians) and athletes, if the in-come is more than $100 a day or $3,000 for the tax year. Regardless of these limits, income of Thai entertainers is exempt from U.S. tax if their visit to the United States is substantially suppor-ted by public funds of Thailand or its political subdivisions or local authorities.

The exemption does not apply to pay re-ceived by employees who are members of the regular complement of a ship or aircraft oper-ated in international traffic by a U.S. enterprise.

Trinidad and TobagoIncome (including reimbursed travel expenses) that residents of Trinidad and Tobago receive during the tax year for personal services per-formed in the United States is exempt from U.S. income tax if the individuals are in the United States for no more than 183 days during the tax year and either:

The residents are employees of a resident of a country other than the United States or are employees of a permanent establish-ment of a U.S. resident outside the United States and the income is not deducted in figuring the profits of a permanent estab-lishment in the United States, orThe income is not more than $3,000 (ex-cluding reimbursed travel expenses).

These exemptions do not apply to the pro-fessional earnings of public entertainers such

as actors, musicians, and professional athletes or to any person providing their services if the pay is more than $100 per day (excluding reim-bursed travel expenses).

Pay received by members of the regular complement of a ship or aircraft operated in in-ternational traffic by a resident of Trinidad and Tobago is exempt from U.S. tax.

TunisiaIncome that residents of Tunisia receive for per-forming personal services as independent con-tractors or self-employed individuals (independ-ent personal services) in the United States are exempt from U.S. income tax if:

They are in the United States for no more than 183 days during the tax year,They do not have a fixed base regularly available in the United States for perform-ing the services, andThe gross income for the tax year from U.S. residents for services performed in the United States is no more than $7,500.

If they do not meet condition (2), they are taxed on the income that is attributable to the fixed base.

Income that residents of Tunisia receive for personal services performed in the United States as employees (dependent personal services) is exempt from U.S. income tax if:

The residents are in the U.S. for no more than 183 days during the tax year,Their income is paid by, or on behalf of, an employer who is not a resident of the Uni-ted States, andTheir income is not borne by a permanent establishment or fixed base the employer has in the United States.

Pay received by employees who are mem-bers of the regular complement of a ship or air-craft operated by an enterprise in international traffic is exempt from U.S. tax if the place of management of the enterprise is in Tunisia. However, if the enterprise is created under the laws of the United States (or a U.S. state), the pay is subject to U.S. tax.

These exemptions do not apply to income residents of Tunisia receive as public entertain-ers (such as theater, motion picture, radio, or television artists, and musicians) or athletes if their gross receipts, including reimbursed ex-penses, are more than $7,500 during the tax year.

These exemptions do not apply to fees re-ceived by a resident of Tunisia for services per-formed as a director of a U.S. corporation if the fees are treated as a distribution of profits and cannot be taken as a deduction by the corpora-tion.

Page 14 of 61 Fileid: … ons/P901/201304/A/XML/Cycle02/source 10:02 - 11-Mar-2013The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

Page 14 Publication 901 (April 2013)

Page 15: Treaties U.S. TaxTurkmenistan, and Uzbekistan. That treaty will remain in effect until new treaties with these in-dividual countries are negotiated and ratified. Provisions of the

TurkeyIncome that residents of Turkey receive for per-forming personal services as independent con-tractors or self-employed individuals (independ-ent personal services) in the United States is exempt from U.S. income tax if the residents:

Are in the United States for purposes of performing the services or activities for no more than 183 days in any 12-month pe-riod, andDo not have a fixed base regularly availa-ble to them in the United States for per-forming the services.

If they have a fixed base available, they are taxed only on income attributable to the fixed base.

Income that residents of Turkey receive for services performed in the United States as em-ployees (dependent personal services) is ex-empt from U.S. income tax if the following re-quirements are met.

The resident is in the United States for no more than 183 days in any 12-month pe-riod.The income is paid by, or on behalf of, an employer who is not a U.S. resident.The income is not borne by a permanent establishment or a fixed base that the em-ployer has in the United States.

This exemption does not apply to a resident of Turkey who performs services as a member of the regular complement of a ship or an air-craft operated by a U.S. resident in international traffic.

These exemptions do not apply to directors' fees and similar payments received by a resi-dent of Turkey for services provided in the Uni-ted States as a member of the board of direc-tors of a company that is a resident of the United States.

These exemptions do not apply to income residents of Turkey receive as public entertain-ers (such as theater, motion picture, radio, or television artists, or musicians) or athletes if their gross receipts are more than $3,000 dur-ing the tax year for their entertainment activities in the United States. If their visit to the United States is substantially supported by a Turkish non-profit organization or from the public funds of Turkey, its political subdivisions, or local au-thorities, the income is taxed as independent personal services or dependent personal serv-ices.

UkraineIncome that residents of Ukraine receive for performing personal services as independent contractors or self-employed individuals (inde-pendent personal services) in the United States is exempt from U.S. income tax if the income is not attributable to a fixed base in the United States that is regularly available for performing the services.

Income that residents of Ukraine receive for employment in the United States (dependent

personal services) is exempt from U.S. income tax if the following three requirements are met.

The resident is in the United States for no more than 183 days during the tax year.The income is paid by, or on behalf of, an employer who is not a resident of the Uni-ted States.The income is not borne by a permanent establishment or a fixed base that the em-ployer has in the United States.

These exemptions do not apply to directors' fees and similar payments received by a resi-dent of Ukraine for services performed outside of Ukraine as a member of the board of direc-tors of a company that is a resident of the Uni-ted States.

These exemptions generally do not apply to income received as a public entertainer (such as a theater, motion picture, radio, or television artist, musician, or athlete). However, income of Ukrainian entertainers and sportsmen is exempt from U.S. income tax if their visit to the United States is substantially supported by public funds of Ukraine, its political subdivisions, or lo-cal authorities, or the visit is made pursuant to a specific arrangement between the United States and Ukraine.

Income derived by a resident of Ukraine from employment as a member of the regular complement of a ship or aircraft operated in in-ternational traffic is exempt from U.S. tax.

United KingdomIncome that residents of the United Kingdom re-ceive for personal services as independent con-tractors or self-employed individuals are subject to the provisions of Article 7 (Business Profits) of the treaty. Under that provision, business profits are exempt from U.S. income tax unless the individual has a permanent establishment in the United States. If they have a permanent es-tablishment in the United States, they are taxed on the profits attributable to the permanent es-tablishment.

Income that residents of the United King-dom receive for services performed in the Uni-ted States as employees (dependent personal services) is exempt from U.S. income tax if the residents meet the following requirements.

They are in the United States for no more than 183 days in any 12-month period be-ginning or ending in the tax year.Their income is paid by, or on behalf of, an employer who is not a U.S. resident.Their income is not borne by a permanent establishment that the employer has in the United States.

The exemption does not apply to directors' fees and similar payments received by a resi-dent of the United Kingdom for services per-formed in the United States as a member of the board of directors of a company resident in the United States.

Public entertainers (such as theater, motion picture, radio, or television artists, musicians, or athletes) from the United Kingdom who earn more than $20,000 in gross receipts, including

reimbursed expenses, from their entertainment activities in the United States during the tax year are subject to U.S. tax.

Income received by a resident of the United Kingdom for services performed as an em-ployee and member of the regular complement of a ship or aircraft operated in international traf-fic is exempt from U.S. income tax.

VenezuelaIncome that residents of Venezuela receive for personal services as independent contractors or self-employed individuals (independent per-sonal services) in the United States is exempt from U.S. income tax if they do not have a fixed base regularly available to them in the United States for performing the services. If they have a fixed base available, they are taxed on the in-come attributable to the fixed base.

Income that residents of Venezuela receive for services performed in the United States as employees (dependent personal services) is exempt from U.S. income tax if the residents meet the following requirements.

They are in the United States for no more than 183 days in any 12-month period be-ginning or ending in the tax year.Their income is paid by, or on behalf of, an employer who is not a U.S. resident.The income is not borne by a permanent establishment or a fixed base that the em-ployer has in the United States.

These exemptions do not apply to directors' fees and similar payments received by a resi-dent of Venezuela for services performed in the United States as a member of the board of di-rectors of a company resident in the United States.

Pay received by a resident of Venezuela for services performed as an employee of a ship or an aircraft operated in international traffic is ex-empt from U.S. income tax.

These exemptions do not apply to income residents of Venezuela receive as public enter-tainers (such as theater, motion picture, radio, or television artists, or musicians) or sportsmen if their gross income, including reimbursed ex-penses, is more than $6,000 for their personal activities in the United States during the tax year. Regardless of these limits, income of Ven-ezuelan entertainers or athletes is exempt from U.S. income tax if their visit to the United States is wholly or mainly supported by public funds of Venezuela, its political subdivisions, or local au-thorities.

Professors, Teachers,and ResearchersPay of professors and teachers who are resi-dents of the following countries is generally ex-empt from U.S. income tax for 2 or 3 years if they temporarily visit the United States to teach or do research. The exemption applies to pay earned by the visiting professor or teacher dur-ing the applicable period. For most of the fol-lowing countries, the applicable period begins

Page 15 of 61 Fileid: … ons/P901/201304/A/XML/Cycle02/source 10:02 - 11-Mar-2013The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

Publication 901 (April 2013) Page 15

Page 16: Treaties U.S. TaxTurkmenistan, and Uzbekistan. That treaty will remain in effect until new treaties with these in-dividual countries are negotiated and ratified. Provisions of the

on the date of arrival in the United States for the purpose of teaching or engaging in research. Furthermore, for most of the following countries, the exemption applies even if the stay in the United States extends beyond the applicable period.

The exemption generally applies to pay re-ceived during a second teaching assignment if both are completed within the specified time, even if the second assignment was not ar-ranged until after arrival in the United States on the first assignment. For each of the countries listed, the conditions are stated under which the pay of a professor or teacher from that country is exempt from U.S. income tax.

If you do not meet the requirements for ex-emption as a teacher or if you are a resident of a treaty country that does not have a special provision for teachers, you may qualify under a personal services income provision discussed earlier.

BangladeshAn individual is exempt from U.S. income tax on income from teaching or research for not more than 2 years from the date of arrival for such purposes if he or she:

Is a resident of Bangladesh immediately before visiting the United States, andIs in the United States to teach or engage in research at a university, college, or other recognized educational institution.

This exemption does not apply to income from research carried on mainly for the private benefit of any person rather than in the public interest.

BelgiumAn individual who is a resident of Belgium at the beginning of the visit to the United States and who is temporarily in the United States to teach or carry on research at a school, college, uni-versity or other educational or research institu-tion is exempt from U.S. income tax for a period not exceeding 2 years from the date of arrival in the United States on income received for teach-ing or carrying on research.

This exemption does not apply to income from research carried on mainly for the private benefit of any person rather than in the public interest.

BulgariaAn individual who is a resident of Bulgaria at the beginning of the visit to the United States and who is temporarily in the United States to teach or carry on research at a school, college, uni-versity or other recognized educational or re-search institution is exempt from U.S. income tax for a period not exceeding 2 years from the date of arrival in the United States on income received for teaching or carrying on research.

This exemption does not apply to income from research carried on mainly for the private benefit of any person rather than in the public interest.

China, People's Republic ofAn individual who is a resident of the People's Republic of China and who is temporarily in the United States primarily to teach, lecture, or con-duct research at a university or other accredited educational institution or scientific research in-stitution is exempt from U.S. income tax on in-come for the teaching, lecturing, or research for a total of not more than 3 years.

This exemption does not apply to income from research carried on mainly for the private benefit of any person rather than in the public interest.

Commonwealth ofIndependent States (C.I.S.)An individual who is a resident of a C.I.S. mem-ber on the date of arrival in the United States and who is temporarily in the United States at the invitation of the U.S. Government or an edu-cational or scientific research institution in the United States primarily to teach, engage in re-search, or participate in scientific, technical, or professional conferences is exempt from U.S. income tax on income for teaching, research, or participation in these conferences for a maxi-mum period of 2 years.

This exemption does not apply to income from research carried on mainly for the benefit of a private person, including a commercial en-terprise of the United States or a foreign trade organization of a C.I.S. member.

The exemption does, however, apply if the research is conducted through an intergovern-mental agreement on cooperation.

This exemption also applies to journalists and correspondents who are temporarily in the United States for periods not longer than 2 years and who receive their compensation from abroad. It is not necessary that the journalists or correspondents be invited by the U.S. Govern-ment or other appropriate institution, nor does it matter that they are employed by a private per-son, including commercial enterprises and for-eign trade organizations.

Czech RepublicAn individual is exempt from U.S. income tax on income for teaching or research for up to 2 years if he or she:

Is a resident of the Czech Republic imme-diately before visiting the United States, andIs in the United States primarily to teach or conduct research at a university, college, school, or other accredited educational or research institution.

A Czech resident is entitled to these benefits only once. However, the exemption does not apply if:

The resident claimed during the immediate preceding period the benefits described later under Students and Apprentices, or

The income is from research undertaken primarily for the private benefit of a specific person or persons.

EgyptAn individual who is a resident of Egypt on the date of arrival in the United States and who is temporarily in the United States primarily to teach or engage in research, or both, at a uni-versity or other recognized educational institu-tion is exempt from U.S. income tax on income from the teaching or research for a maximum of 2 years from the date of arrival in the United States. The individual must have been invited to the United States for a period not expected to be longer than 2 years by the U.S. Government or a state or local government, or by a university or other recognized educational institution in the United States.

The exemption does not apply if the resident claimed, during the immediately preceding pe-riod, the benefits described later under Stu­dents and Apprentices.

This exemption does not apply to income from research carried on mainly for the private benefit of any person rather than in the public interest.

FranceAn individual who is a resident of France on the date of arrival in the United States and who is temporarily in the United States at the invitation of the U.S. Government, a university, or other recognized educational or research institution in the United States primarily to teach or engage in research, or both, at a university or other edu-cational or research institution is exempt from U.S. income tax on income from teaching or re-search for a maximum of 2 years from the date of arrival in the United States.

An individual may claim this benefit only once. Also, this benefit and the benefits descri-bed later under Students and Apprentices can be claimed for no more than 5 years.

This exemption does not apply to income from research carried on mainly for the private benefit of any person rather than in the public interest.

GermanyA professor or teacher who is a resident of Ger-many and who is temporarily in the United States to engage in advanced study or research or teaching at an accredited educational institu-tion or institution engaged in research for the public benefit is exempt from U.S. tax on in-come received for such study, research, or teaching for a maximum of 2 years from the date of arrival in the United States.

The exemption does not apply to income from research carried on mainly for the private benefit of any person rather than in the public interest. The exemption does not apply if, dur-ing the preceding period, the benefit described

Page 16 of 61 Fileid: … ons/P901/201304/A/XML/Cycle02/source 10:02 - 11-Mar-2013The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

Page 16 Publication 901 (April 2013)

Page 17: Treaties U.S. TaxTurkmenistan, and Uzbekistan. That treaty will remain in effect until new treaties with these in-dividual countries are negotiated and ratified. Provisions of the

in paragraph (2), (3), or (4) of Article 20 of the treaty, pertaining to students, was claimed.

GreeceA professor or teacher who is a resident of Greece and who is temporarily in the United States to teach at a university, college, or other educational institution for a maximum of 3 years is exempt from U.S. income tax on the income received for teaching during that period.

HungaryAn individual who is a resident of Hungary on the date of arrival in the United States and who is temporarily in the United States primarily to teach or engage in research, or both, at a uni-versity or other recognized educational institu-tion is exempt from U.S. income tax on income for the teaching or research for a maximum of 2 years from the date of arrival in the United States. The individual must have been invited to the United States for a period not expected to be longer than 2 years by the U.S. Government or a state or local government, or by a university or other recognized educational institution in the United States.

The exemption does not apply to income from research carried on mainly for the private benefit of any person rather than in the public interest.

IcelandAlthough there is no provision to exempt in-come derived by teachers or researchers in the treaty, an individual who was otherwise entitled to treaty benefits under Article 21 (Teachers) of the treaty in effect before 2009 can continue to apply those provisions.

IndiaAn individual is exempt from U.S. tax on income received for teaching or research if he or she:

Is a resident of India immediately before visiting the United States, andIs in the United States to teach or engage in research at an accredited university or other recognized educational institution in the United States for a period not longer than 2 years.

If the individual's visit to the United States exceeds 2 years, the exemption is lost for the entire visit.

This exemption does not apply to income from research carried on mainly for the private benefit of any person rather than in the public interest.

IndonesiaAn individual is exempt from U.S. tax on income for teaching or research for a maximum of 2 years from the date of arrival in the United States if he or she:

Is a resident of Indonesia immediately be-fore visiting the United States, and

Is in the United States at the invitation of a university, school, or other recognized ed-ucational institution to teach or engage in research, or both, at that educational insti-tution.

A resident of Indonesia is entitled to this ex-emption only once. But this exemption does not apply to income from research carried on mainly for the private benefit of any person.

IsraelAn individual who is a resident of Israel on the date of arrival in the United States and who is temporarily in the United States primarily to teach or engage in research, or both, at a uni-versity or other recognized educational institu-tion is exempt from U.S. income tax on income from the teaching or research for a maximum of 2 years from the date of arrival in the United States. The individual must have been invited to the United States for a period not expected to be longer than 2 years by the U.S. Government or a state or local government, or by a university or other recognized educational institution in the United States.

This exemption does not apply to income from research carried on mainly for the private benefit of any person rather than in the public interest. The exemption does not apply if, dur-ing the immediately preceding period, the bene-fits described in Article 24(1) of the treaty, per-taining to students, were claimed.

ItalyA professor or teacher who is a resident of Italy immediately before the date of arrival in the Uni-ted States and whose visit to the United States is expected to last no more than 2 years to teach or conduct research at a university, col-lege, school, or other recognized educational institution, or at a medical facility primarily fun-ded from government sources, is exempt from U.S. income tax for up to 2 years on pay from this teaching or research.

This exemption does not apply to income from research carried on mainly for the private benefit of any person rather than in the public interest.

JamaicaAn individual who is a resident of Jamaica on the date of arrival in the United States and who temporarily visits the United States to teach or engage in research at a university, college, or other recognized educational institution for a period not expected to exceed 2 years, is ex-empt from U.S. income tax on the income re-ceived for the teaching or research for not more than 2 years from the date of arrival in the Uni-ted States. A resident of Jamaica is entitled to this exemption only once.

This exemption does not apply to income from research carried on mainly for the private benefit of any person rather than in the public interest.

JapanAn individual who is a resident of Japan and who is temporarily in the United States primarily to teach or engage in research at a university, college, or other recognized educational institu-tion is exempt from U.S. income tax on income for the teaching or research for a maximum of 2 years from the date of arrival in the United States.

The exemption does not apply to income from research carried on mainly for the private benefit of any person rather than in the public interest.

Korea, SouthAn individual who is a resident of South Korea on the date of arrival in the United States and who is temporarily in the United States primarily to teach or engage in research, or both, at a university or other recognized educational insti-tution is exempt from U.S. income tax on in-come for the teaching or research for a maxi-mum of 2 years from the date of arrival in the United States. The individual must have been invited to the United States for a period not ex-pected to be longer than 2 years by the U.S. Government or a state or local government, or by a university or other recognized educational institution in the United States.

The exemption does not apply to income from research carried on mainly for the private benefit of any person rather than in the public interest.

LuxembourgA resident of Luxembourg who is temporarily in the United States at the invitation of a U.S. uni-versity, college, school, or other recognized ed-ucational institution only to teach or engage in research, or both, at that educational institution is exempt from U.S. income tax on income for the teaching or research for not more than 2 years from the date of arrival in the United States.

If the individual's visit to the United States is longer than 2 years, the exemption is lost for the entire visit unless the competent authorities of Luxembourg and the United States agree other-wise.

This exemption does not apply to pay for re-search carried on for the benefit of any person other than the educational institution that exten-ded the invitation.

NetherlandsAn individual is exempt from U.S. income tax on income received for teaching or research for a maximum of 2 years from the date of arrival if he or she:

Is a resident of the Netherlands immedi-ately before visiting the United States, andIs in the United States to teach or engage in research at a university, college, or other recognized educational institution for not more than 2 years.

Page 17 of 61 Fileid: … ons/P901/201304/A/XML/Cycle02/source 10:02 - 11-Mar-2013The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

Publication 901 (April 2013) Page 17

Page 18: Treaties U.S. TaxTurkmenistan, and Uzbekistan. That treaty will remain in effect until new treaties with these in-dividual countries are negotiated and ratified. Provisions of the

If the individual's visit to the United States is longer than 2 years, the exemption is lost for the entire visit unless the competent authorities of the Netherlands and the United States agree otherwise.

The exemption does not apply to income from research carried on primarily for the pri-vate benefit of any person rather than in the public interest. Nor does the exemption apply if the resident claimed during the immediate pre-ceding period the benefits described later under Students and Apprentices.

NorwayAn individual who is a resident of Norway on the date of arrival in the United States and who is temporarily in the United States at the invitation of the U.S. Government, a university, or other recognized educational institution in the United States primarily to teach or engage in research, or both, at a university or other recognized edu-cational institution is exempt from U.S. income tax on income for the teaching or research for a maximum period of 2 years from the date of ar-rival in the United States.

This exemption does not apply to income from research carried on mainly for the private benefit of any person rather than in the public interest.

PakistanA professor or teacher who is a resident of Paki-stan and who temporarily visits the United States to teach at a university, college, school, or other educational institution for not longer than 2 years is exempt from U.S. income tax on the income received for teaching for that period.

PhilippinesAn individual who is a resident of the Philip-pines on the date of arrival in the United States and who is temporarily in the United States pri-marily to teach or engage in research, or both, at a university or other recognized educational institution is exempt from U.S. income tax on in-come from the teaching or research for not more than 2 years from the date of arrival in the United States. The individual must have been invited to the United States for a period not ex-pected to be longer than 2 years by the U.S. Government or a state or local government, or by a university or other recognized educational institution in the United States.

This exemption does not apply to income from research carried on mainly for the private benefit of any person rather than in the public interest. The exemption does not apply if, dur-ing the immediately preceding period, the bene-fits described in Article 22(1) of the treaty, per-taining to students, were claimed.

PolandAn individual who is a resident of Poland on the date of arrival in the United States and who is temporarily in the United States at the invitation of the U.S. Government, a university, or other

recognized educational institution in the United States primarily to teach or engage in research, or both, at a university or other recognized edu-cational institution is exempt from U.S. income tax on income for the teaching or research for a maximum of 2 years from the date of arrival in the United States.

The exemption does not apply if the resident claimed, during the immediately preceding pe-riod, the benefits described later under Stu­dents and Apprentices.

This exemption does not apply to income from research carried on mainly for the private benefit of any person rather than in the public interest.

PortugalAn individual who is a resident of Portugal on the date of arrival in the United States and who is temporarily in the United States at the invita-tion of the U.S. Government, a university, other accredited educational institution, or recognized research institution in the United States, or un-der an official cultural exchange program, only to teach or engage in research, or both, at a university or educational institution is exempt from U.S. income tax on income from teaching or research for a maximum of 2 years from the date of arrival in the United States. An individual is entitled to these benefits only once. However, these benefits, and the benefits described later under Students and Apprentices cannot be claimed either simultaneously or consecutively.

This exemption does not apply to income from research carried on mainly for the private benefit of any person rather than in the public interest.

RomaniaAn individual who is a resident of Romania on the date of arrival in the United States and who is temporarily in the United States at the invita-tion of the U.S. Government, a university, or other recognized educational institution in the United States primarily to teach or engage in re-search, or both, at a university or other recog-nized educational institution is exempt from U.S. income tax on income for the teaching or research for a maximum of 2 years from the date of arrival in the United States.

This exemption does not apply to income from research carried on mainly for the private benefit of any person rather than in the public interest.

Slovak RepublicAn individual is exempt from U.S. income tax on income for teaching or research for up to 2 years if he or she:

Is a resident of the Slovak Republic imme-diately before visiting the United States, andIs in the United States primarily to teach or conduct research at a university, college, school, or other accredited educational or research institution.

A Slovak resident is entitled to these bene-fits only once. However, the exemption does not apply if:

The resident claimed during the immediate preceding period the benefits described later under Students and Apprentices, orThe income is from research undertaken primarily for the private benefit of a specific person or persons.

SloveniaAn individual who is a resident of Slovenia on the date of arrival in the United States and who temporarily visits the United States to teach or engage in research at a recognized educational or research institution is exempt from U.S. in-come tax on the income received for the teach-ing or research for not more than 2 years from the date of arrival in the United States. This benefit can be claimed for no more than 5 years.

The exemption does not apply to income from research carried on mainly for the private benefit of any person rather than in the public interest.

ThailandAn individual who is a resident of Thailand on the date of arrival in the United States and who is in the United States for not longer than 2 years primarily to teach or engage in research at a university, college, school, or other recog-nized educational institution is exempt from U.S. income tax on income for the teaching or research. The exemption from tax applies only if the visit does not exceed 2 years from the date the individual first visits the United States for the purpose of engaging in teaching or re-search.

This exemption does not apply to income from research carried on mainly for the private benefit of any person rather than in the public interest. This exemption does not apply if, dur-ing the immediately preceding period, the bene-fits described in treaty Article 22(1), pertaining to students, were claimed.

Trinidad and TobagoAn individual who is a resident of Trinidad and Tobago on the date of arrival in the United States and who is temporarily in the United States at the invitation of the U.S. Government, a university, or other accredited educational in-stitution in the United States primarily to teach or engage in research, or both, at a university or other accredited educational institution is ex-empt from U.S. income tax on the income re-ceived for the teaching or research for a maxi-mum of 2 years from the date of arrival in the United States.

This exemption does not apply to income from research carried on mainly for the private benefit of any person rather than in the public

Page 18 of 61 Fileid: … ons/P901/201304/A/XML/Cycle02/source 10:02 - 11-Mar-2013The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

Page 18 Publication 901 (April 2013)

Page 19: Treaties U.S. TaxTurkmenistan, and Uzbekistan. That treaty will remain in effect until new treaties with these in-dividual countries are negotiated and ratified. Provisions of the

interest. Nor does the exemption apply to in-come if an agreement exists between the Gov-ernments of Trinidad and Tobago and the Uni-ted States for providing the services of these individuals.

TurkeyAn individual who was a resident of Turkey im-mediately before visiting the United States who is in the United States for not longer than 2 years for the purpose of teaching or engaging in scientific research is exempt from U.S. income tax on payments received from outside the Uni-ted States for teaching or research.

United KingdomA professor or teacher who is a resident of the United Kingdom on the date of arrival in the Uni-ted States and who is in the United States for not longer than 2 years primarily to teach or en-gage in research at a university, college, or other recognized educational institution is ex-empt from U.S. income tax on income for the teaching or research. If the individual's 2-year period is exceeded, the exemption is lost for the entire visit, including the 2-year period.

The exemption does not apply to income from research carried on mainly for the private benefit of any person rather than in the public interest.

VenezuelaAn individual who is a resident of Venezuela on the date of arrival in the United States and who temporarily visits the United States to teach or engage in research at a recognized educational or research institution is exempt from U.S. in-come tax on the income received for the teach-ing or research for not more than 2 years from the date of arrival in the United States. This benefit can be claimed for no more than 5 years.

The exemption does not apply to income from research carried on mainly for the private benefit of any person rather than in the public interest.

Students and ApprenticesResidents of the following countries who are in the United States to study or acquire technical experience are exempt from U.S. income tax, under certain conditions, on amounts received from abroad for their maintenance and studies.

This exemption does not apply to the salary paid by a foreign corporation to one of its exec-utives, a citizen and resident of a foreign coun-try who is temporarily in the United States to study a particular industry for an employer. That amount is a continuation of salary and is not re-ceived to study or acquire experience.

For each country listed there is a statement of the conditions under which the exemption applies to students and apprentices from that country.

Amounts received from the National Insti-tutes of Health (NIH) under provisions of the Visiting Fellows Program are generally treated as a grant, allowance, or award for purposes of whether an exemption is provided by treaty. Amounts received from NIH under the Visiting Associate Program and Visiting Scientist Pro-gram are not exempt from U.S. tax as a grant, allowance, or award.

AustraliaA resident of Australia or an individual who was a resident of Australia immediately before visit-ing the United States who is temporarily here for full-time education is exempt from U.S. income tax on payments received from outside the Uni-ted States for the individual's maintenance or education.

AustriaA student, apprentice, or business trainee who is a resident of Austria immediately before visit-ing the United States and is in the United States for the purpose of full-time education at a recog-nized educational institution or full-time training is exempt from U.S. income tax on amounts re-ceived from sources outside the United States for the individual's maintenance, education, or training.

Apprentices and business trainees are enti-tled to the benefit of this exemption for a maxi-mum period of 3 years.

BangladeshAn individual who is a resident of Bangladesh immediately before visiting the United States and who is temporarily present in the United States for the primary purpose of:

1. Studying at a university, college, school, or other recognized educational institution in the United States,

2. Securing training as a business or techni-cal apprentice, or

3. Studying or doing research as a recipient of a grant, allowance, or award from a governmental, religious, charitable, or ed-ucational organization

is exempt from U.S. tax on the following amounts.

The payments from abroad for the purpose of maintenance, education, or training.The grant, allowance, or award.The income from personal services per-formed in the United States of up to $8,000 for the tax year.

For an individual described in (2), the ex-emption from tax applies for not more than 2 years from the date the individual first arrived in the United States.

BarbadosA student or business apprentice who is a resi-dent of Barbados on the date of arrival in the United States and is here for full-time education

or training is exempt from U.S. income tax on payments received from outside the United States for the individual's maintenance, educa-tion, or training.

Nevertheless, an individual who qualifies for this exemption may instead choose to be trea-ted as a resident alien of the United States for all U.S. income tax purposes. Once made, this choice applies for the entire period that the indi-vidual remains qualified for exemption and may not be revoked without the permission of the U.S. competent authority.

BelgiumA student or business trainee who is a resident of Belgium immediately before visiting the Uni-ted States and is in the United States for the purpose of full-time education or training is ex-empt from U.S. income tax on the following amounts.

Payments received from abroad for main-tenance, education, or training.Income from personal services of up to $9,000 for each tax year.

An apprentice or a business trainee is enti-tled to the benefit of this exemption for a maxi-mum period of 2 years.

For this purpose, a business trainee is an in-dividual who is temporarily in the United States:

To secure training to practice a profession or professional specialty, orAs an employee of, or under contract with, a resident of Belgium, for the primary pur-pose of acquiring technical, professional, or business experience from a person other than that resident of Belgium or other than a person related to that resident.

BulgariaA student or business trainee who is a resident of Bulgaria immediately before visiting the Uni-ted States and is in the United States for the purpose of full-time education at a college, uni-versity, or other recognized educational institu-tion of a similar nature, or full-time training is ex-empt from U.S. income tax on the following amounts.

Payments received from abroad for main-tenance, education, or training.Income from personal services of up to $9,000 for each tax year.

An apprentice or a business trainee is enti-tled to the benefit of this exemption for a maxi-mum period of 2 years.

For this purpose, a business trainee is an in-dividual who is temporarily in the United States:

To secure training to practice a profession or professional specialty, orAs an employee of, or under contract with, a resident of Bulgaria, for the primary pur-pose of acquiring technical, professional, or business experience from a person other than that resident of Bulgaria or other than a person related to that resident.

Page 19 of 61 Fileid: … ons/P901/201304/A/XML/Cycle02/source 10:02 - 11-Mar-2013The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

Publication 901 (April 2013) Page 19

Page 20: Treaties U.S. TaxTurkmenistan, and Uzbekistan. That treaty will remain in effect until new treaties with these in-dividual countries are negotiated and ratified. Provisions of the

CanadaA student, business trainee, or apprentice who is or was a Canadian resident immediately be-fore visiting the United States, and is in the Uni-ted States for the purpose of full-time education or full-time training, is exempt from U.S. income tax on amounts received from sources outside the United States for maintenance, education, or training.

Apprentices and business trainees are enti-tled to the benefit of this exemption for a maxi-mum period of 1 year.

Also see Publication 597, Information on the United States–Canada Income Tax Treaty.

China, People's Republic ofA student, business apprentice, or trainee who is a resident of the People's Republic of China on the date of arrival in the United States and who is present in the United States solely to ob-tain training, education, or special technical ex-perience is exempt from U.S. income tax on the following amounts.

Payments received from abroad for main-tenance, education, study, research, or training.Grants or awards from a government, sci-entific, educational, or other tax-exempt or-ganization.Income from personal services performed in the United States of up to $5,000 for each tax year.

An individual is entitled to this exemption only for the time reasonably necessary to com-plete the education or training.

Commonwealth ofIndependent States (C.I.S.)An individual who is a resident of a C.I.S. mem-ber and who is temporarily in the United States primarily to study at an educational or scientific research institution or to obtain training for qual-ification in a profession or specialty is exempt from U.S. income tax on amounts received as stipends, scholarships, or other substitute al-lowances necessary to provide ordinary living expenses. An individual is entitled to the benefit of this exemption for a maximum of 5 years and for less than $10,000 in each tax year.

An individual who is a resident of a C.I.S. member and who is temporarily in the United States primarily to acquire technical, professio-nal, or commercial experience or perform tech-nical services and who is an employee of, or under contract with, a resident of a C.I.S. mem-ber is exempt from U.S. income tax on the amounts received from that resident. Also ex-empt is an amount received from U.S. sources, of not more than $10,000, that is necessary to provide for ordinary living expenses. The ex-emption contained in this paragraph is limited to 1 year.

An individual who is a resident of a C.I.S. member and who is temporarily present in the United States under an exchange program

provided for by an agreement between govern-ments on cooperation in various fields of sci-ence and technology is exempt from U.S. in-come tax on all income received in connection with the exchange program for a period not lon-ger than 1 year.

CyprusAn individual who is a resident of Cyprus on the date of arrival in the United States and who is temporarily here primarily to study at a univer-sity or other recognized educational institution in the United States, obtain professional train-ing, or study or do research as a recipient of a grant, allowance, or award from a governmen-tal, religious, charitable, scientific, literary, or educational organization is exempt from U.S. income tax on the following amounts.

Gifts from abroad for maintenance, educa-tion, or training.The grant, allowance, or award.Income from personal services performed in the United States of up to $2,000 for each tax year.

An individual is entitled to this exemption for up to 5 tax years and for an additional period as is necessary to complete, as a full-time student, educational requirements for a postgraduate or professional degree from a recognized educa-tional institution.

An individual who is a resident of Cyprus on the date of arrival in the United States and who is temporarily here as an employee of, or under contract with, a resident of Cyprus is exempt from U.S. income tax for not more than 1 year on income from personal services for a maxi-mum of $7,500 if the individual is in the United States primarily to either:

Acquire technical, professional, or busi-ness experience from a person other than a resident of Cyprus or other than a person related to that resident, orStudy at a university or other recognized educational institution.

An individual who is a resident of Cyprus on the date of arrival in the United States and who is temporarily here for a period of not more than 1 year as a participant in a program sponsored by the U.S. Government primarily to train, re-search, or study is exempt from U.S. income tax on income for personal services for the training, research, or study. This exemption is limited to $10,000.

Czech RepublicAn individual who is a resident of the Czech Re-public at the beginning of his or her visit to the United States and who is temporarily present in the United States is exempt from U.S. income tax on certain amounts for a period of up to 5 years. To be entitled to the exemption, the indi-vidual must be in the United States for the pri-mary purpose of:

Studying at a university or other accredited educational institution in the United States,Obtaining training required to qualify him or her to practice a profession or professional specialty, or

Studying or doing research as a recipient of a grant, allowance, or award from a gov-ernmental, religious, charitable, scientific, literary, or educational organization.

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

The payments from abroad, other than compensation for personal services, for the purpose of maintenance, education, study, research, or training.The grant, allowance, or award.The income from personal services per-formed in the United States of up to $5,000 for the tax year.

An individual who is a Czech resident at the beginning of the visit to the United States and who is temporarily present in the United States as an employee of, or under contract with, a Czech resident is exempt from U.S. income tax for a period of 12 consecutive months on up to $8,000 received for personal services if the indi-vidual is in the United States primarily to:

Acquire technical, professional, or busi-ness experience from a person other than the Czech resident, orStudy at a university or other accredited educational institution in the United States.

An individual who is a Czech resident at the time he or she becomes temporarily present in the United States and who is temporarily present in the United States for a period not lon-ger than 1 year as a participant in a program sponsored by the U.S. Government for the pri-mary purpose of training, research, or study is exempt from U.S. income tax on up to $10,000 of income from personal services for that train-ing, research, or study.

These exemptions do not apply to income from research undertaken primarily for the pri-vate benefit of a specific person or persons.

DenmarkA student, apprentice, or business trainee who is a resident of Denmark immediately before visiting the United States and is in the United States for the purpose of full-time education at an accredited educational institution, or full-time training, is exempt from U.S. income tax on amounts received from sources outside the Uni-ted States for the individual's maintenance, ed-ucation, or training.

Apprentices and business trainees are enti-tled to the benefit of this exemption for a maxi-mum period of 3 years.

The exemption does not apply to income from research undertaken primarily for the pri-vate benefit of a specific person or persons.

EgyptAn individual who is a resident of Egypt on the date of arrival in the United States and who is temporarily in the United States primarily to study at a university or other recognized educa-tional institution in the United States, obtain pro-fessional training, or study or do research as a

Page 20 of 61 Fileid: … ons/P901/201304/A/XML/Cycle02/source 10:02 - 11-Mar-2013The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

Page 20 Publication 901 (April 2013)

Page 21: Treaties U.S. TaxTurkmenistan, and Uzbekistan. That treaty will remain in effect until new treaties with these in-dividual countries are negotiated and ratified. Provisions of the

recipient of a grant, allowance, or award from a governmental, religious, charitable, scientific, literary, or educational organization is exempt from U.S. income tax on the following amounts.

Gifts from abroad for maintenance, educa-tion, study, research, or training.The grant, allowance, or award.Income from personal services performed in the United States of up to $3,000 each tax year.

An individual is entitled to the benefit of this exemption for a maximum of 5 tax years and for any additional period of time needed to com-plete, as a full-time student, educational re-quirements as a candidate for a postgraduate or professional degree from a recognized edu-cational institution.

An individual who is a resident of Egypt on the date of arrival in the United States and who is temporarily in the United States as an em-ployee of, or under contract with, a resident of Egypt is exempt from U.S. income tax for a pe-riod of 12 consecutive months on up to $7,500 received for personal services if the individual is in the United States primarily to:

Acquire technical, professional, or busi-ness experience from a person other than that resident of Egypt or other than a per-son related to that resident, orStudy at a university or other educational institution.

An individual who is a resident of Egypt on the date of arrival in the United States and who is temporarily in the United States for no more than 1 year as a participant in a program spon-sored by the U.S. Government primarily to train, research, or study is exempt from U.S. income tax on income received for personal services for the training, research, or study for a maximum of $10,000.

EstoniaAn individual who is a resident of Estonia on the date of arrival in the United States and who is temporarily in the United States primarily to study at a university or other accredited educa-tional institution in the United States, obtain pro-fessional training, or study or do research as a recipient of a grant, allowance, or award from a governmental, religious, charitable, scientific, literary, or educational organization is exempt from U.S. income tax on the following amounts.

Payments from abroad, other than com-pensation for personal services, for main-tenance, education, study, research, or training.The grant, allowance, or award.Income from personal services performed in the United States of up to $5,000 for each tax year.

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

An individual who is a resident of Estonia on the date of arrival in the United States and who is in the United States as an employee of, or un-der contract with, a resident of Estonia is ex-empt from U.S. income tax for a period of 12

consecutive months on up to $8,000 received for personal services if the individual is in the United States primarily to:

Acquire technical, professional, or busi-ness experience from a person other than that resident of Estonia, orStudy at an educational institution.

An individual who is a resident of Estonia on the date of arrival in the United States and who is temporarily present in the United States for not longer than 1 year as a participant in a pro-gram sponsored by the U.S. Government pri-marily to train, research, or study is exempt from U.S. income tax on income received for personal services for the training, research, or study in the amount of $10,000.

These provisions do not apply to income from research carried on mainly for the private benefit of any person rather than in the public interest.

FinlandA full-time student, trainee, or business appren-tice who is a resident of Finland immediately before visiting the United States is exempt from U.S. income tax on amounts received from sources outside the United States for mainte-nance, education, or training.

FranceAn individual who is a resident of France on the date of arrival in the United States and who is temporarily in the United States primarily to study at a university or other recognized educa-tional institution in the United States, obtain pro-fessional training, or study, or do research as a recipient of a grant, allowance, or award from a not-for-profit governmental, religious, charita-ble, scientific, artistic, cultural, or educational organization is exempt from U.S. income tax on the following amounts.

Gifts from abroad for maintenance, educa-tion, study, research, or training.The grant, allowance, or award.Income from personal services performed in the United States of up to $5,000 each tax year.

An individual is entitled to this benefit and the benefit described earlier under Professors, Teachers, and Researchers for a maximum of 5 tax years.

This exemption does not apply to income from research carried on mainly for the private benefit of any person rather than in the public interest.

An individual who is a resident of France on the date of arrival in the United States and who is in the United States as an employee of, or un-der contract with, a resident of France is ex-empt from U.S. income tax for a period of 12 consecutive months on up to $8,000 received for personal services if the individual is in the United States primarily to:

Acquire technical, professional, or busi-ness experience from a person other than that resident of France, or

Study at an educational institution.

GermanyA student or business apprentice (including Vo-lontaere and Praktikanten) who is or was imme-diately before visiting the United States a resi-dent of Germany and who is present in the United States for full-time education or training is exempt from U.S. income tax on amounts from sources outside the United States for maintenance, education, or training.

An individual who is or was immediately be-fore visiting the United States a resident of Ger-many is exempt from U.S. tax on amounts re-ceived as a grant, allowance, or award from a nonprofit religious, charitable, scientific, literary, or educational organization.

Individuals described in the previous two paragraphs are also exempt from U.S. tax on compensation for dependent personal services of up to $9,000 per year if:

They are present in the United States for not more than 4 years, andThe services are performed for the pur-pose of supplementing funds available oth-erwise for maintenance, education, or training.

If the individual's visit exceeds 4 years, the exemption is lost for the entire visit unless the competent authorities of Germany and the Uni-ted States agree otherwise.

An individual who is a resident of Germany and who is employed by a German enterprise or by a nonprofit religious, charitable, scientific, literary, or educational organization is exempt from U.S. tax on compensation paid by the em-ployer from outside the United States if:

The individual is temporarily in the United States for not more than 1 year to acquire technical, professional, or business experi-ence from any person other than his or her employer, andThe 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 a resi-dent of Greece and is temporarily in the United States only to study or acquire business experi-ence is exempt from U.S. income tax on amounts received from sources outside the Uni-ted States for maintenance or studies.

HungaryAn individual who is a resident of Hungary im-mediately before arrival in the United States and is here for full-time education or training is exempt from U.S. income tax on payments re-ceived from outside the United States for the in-dividual's maintenance, education, or training.

The full-time student or trainee may instead choose to be treated as a resident alien of the

Page 21 of 61 Fileid: … ons/P901/201304/A/XML/Cycle02/source 10:02 - 11-Mar-2013The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

Publication 901 (April 2013) Page 21

Page 22: Treaties U.S. TaxTurkmenistan, and Uzbekistan. That treaty will remain in effect until new treaties with these in-dividual countries are negotiated and ratified. Provisions of the

United States for U.S. income tax purposes. Once made, the choice applies for the entire period that the individual remains qualified for exemption as a full-time student or trainee and may not be changed unless permission is ob-tained from the U.S. competent authority.

IcelandAn individual who is a resident of Iceland on the date of arrival in the United States and who is temporarily in the United States primarily to study at a university or other recognized educa-tional institution in the United States, obtain pro-fessional training, or study or do research as a recipient of a grant, allowance, or award from a governmental, religious, charitable, scientific, literary, or educational organization is exempt from U.S. income tax on the following amounts.

Gifts from abroad for maintenance, educa-tion, study, research, or training.The grant, allowance, or award.Income from personal services performed in the United States of up to $9,000 each tax year.

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

An individual who is a resident of Iceland on the date of arrival in the United States and who is temporarily in the United States as an em-ployee of, or under contract with, a resident of Iceland is exempt from U.S. income tax for a period of 12 consecutive months on up to $9,000 received for personal services if the indi-vidual is in the United States primarily to:

Acquire technical, professional, or busi-ness experience from a person other than that resident of Iceland or other than a per-son related to that person, orStudy at a university or other educational institution.

An individual who is a resident of Iceland on the date of arrival in the United States and who is temporarily present in the United States for not longer than 1 year as a participant in a pro-gram sponsored by the U.S. Government pri-marily to train, research, or study is exempt from U.S. income tax on income received for personal services for the training, research, or study for a maximum of $9,000.

IndiaAn individual who is a resident of India immedi-ately before visiting the United States and who is temporarily in the United States primarily for studying or training is exempt from U.S. income tax on payments from abroad for maintenance, study, or training. The exemption does not ap-ply to payments borne by a permanent estab-lishment in the United States or paid by a U.S. citizen or resident, the U.S. Government, or any of its agencies, instrumentalities, political subdi-visions, or local authorities.

Under the treaty, if the payments are not ex-empt under the rule described above, an indi-vidual described in the previous paragraph may be eligible to deduct exemptions for his or her spouse and dependents and the standard

deduction. The individual must file Form 1040NR or Form 1040NR-EZ to claim these amounts. For information on how to claim these amounts, see chapter 5 in Publication 519.

The individual is entitled to these benefits only for a period of time considered reasonable or customarily required to complete studying or training.

IndonesiaAn individual who is a resident of Indonesia im-mediately before visiting the United States and who is temporarily in the United States is ex-empt from U.S. income tax on certain amounts for a period of up to 5 years. To be entitled to the exemption, the individual must be tempora-rily in the United States for full-time study at a U.S. university, school, or other recognized ed-ucational institution, or for full-time study, re-search, or training as a recipient of a grant, al-lowance, or award from either the U.S. or Indonesian Government, a scientific, educa-tional, religious, or charitable organization, or under a technical assistance program entered into by either the U.S. or Indonesian Govern-ment. If the individual meets any of these re-quirements, the following amounts are exempt from tax.

All payments from abroad for mainte-nance, education, study, research, or train-ing.The grant, allowance, or award.Income from personal services performed in the United States of up to $2,000 each tax year.

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

IrelandA student, apprentice, or business trainee who is a resident of Ireland immediately before visit-ing the United States and is in the United States for the purpose of full-time education at a recog-nized educational institution or full-time training is exempt from U.S. income tax on amounts re-ceived from sources outside the United States for the individual's maintenance, education, or training.

Apprentices and business trainees are enti-tled to the benefit of this exemption for a maxi-mum period of 1 year.

IsraelAn individual who is a resident of Israel on the date of arrival in the United States and who is temporarily in the United States primarily to study at a university or other recognized educa-tional institution in the United States, obtain pro-fessional training, or study or do research as a recipient of a grant, allowance, or award from a governmental, religious, charitable, scientific,

literary, or educational organization is exempt from U.S. income tax on the following amounts.

Gifts from abroad for maintenance, educa-tion, study, research, or training.The grant, allowance, or award.Income from personal services performed in the United States of up to $3,000 each tax year.

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

An individual who is a resident of Israel on the date of arrival in the United States and who is temporarily in the United States as an em-ployee of, or under contract with, a resident of Israel is exempt from U.S. income tax for a pe-riod of 12 consecutive months on up to $7,500 received for personal services if the individual is in the United States primarily to:

Acquire technical, professional, or busi-ness experience from a person other than that resident of Israel or other than a per-son related to that resident, orStudy at a university or other educational institution.

An individual who is a resident of Israel on the date of arrival in the United States and who is temporarily in the United States for no more than 1 year as a participant in a program spon-sored by the U.S. Government primarily to train, research, or study is exempt from U.S. income tax on income received for personal services for the training, research, or study for a maximum of $10,000.

ItalyA student or business apprentice (trainee) who is a resident of Italy immediately before the date of arrival in the United States and who is present in the United States only for education or training at a recognized educational institu-tion is exempt from U.S. income tax on amounts received from outside the United States for maintenance, education, and training.

JamaicaA student who is a resident of Jamaica on the date of arrival in the United States and is here for full-time education or training is exempt from U.S. income tax on payments received from outside the United States for the student's maintenance, education, or training.

An individual who is a resident of Jamaica on the date of arrival in the United States and who is temporarily in the United States as an employee of, or under contract with, a resident of Jamaica is exempt from U.S. income tax for a period of 12 consecutive months on up to $7,500 of net income from personal services if the individual is in the United States primarily to:

Acquire technical, professional, or busi-ness experience from a person other than that resident of Jamaica or other than a person related to that resident, orStudy at a university or other recognized educational institution.

Page 22 of 61 Fileid: … ons/P901/201304/A/XML/Cycle02/source 10:02 - 11-Mar-2013The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

Page 22 Publication 901 (April 2013)

Page 23: Treaties U.S. TaxTurkmenistan, and Uzbekistan. That treaty will remain in effect until new treaties with these in-dividual countries are negotiated and ratified. Provisions of the

An individual who qualifies for one of the ex-emptions discussed above may instead choose to be treated as a resident alien of the United States for all U.S. income tax purposes. Once made, the choice applies for the entire period that the individual remains qualified for exemp-tion and may not be revoked unless permission is obtained from the U.S. competent authority.

JapanA student or business apprentice who is a resi-dent of Japan immediately before visiting the United States and is in the United States for the purpose of education or training is exempt from U.S. income tax on amounts received from abroad for the individual's maintenance, educa-tion, or training.

Business apprentices are entitled to the benefit of this exemption for a maximum period of 1 year.

KazakhstanAn individual who is a resident of Kazakhstan at the beginning of his or her visit to the United States is exempt from U.S. tax on payments from abroad for maintenance, education, study, research, or training and on any grant, allow-ance, or other similar payments. To be entitled to the exemption, the individual must be tempo-rarily present in the United States primarily to:

Study at a university or other accredited educational institution,Obtain training required to qualify him or her to practice a profession or professional specialty, or,Study or do research as a recipient of a grant, allowance, or other similar payments from a governmental, religious, charitable, scientific, literary, or educational organiza-tion.

The individual is entitled to this exemption only for a period of time necessary to complete the study, training, or research, but the exemp-tion for training or research may not extend for a period exceeding 5 years.

These exemptions do not apply to income from research if it is undertaken primarily for the private benefit of a specific person or persons.

Korea, SouthAn individual who is a resident of South Korea on the date of arrival in the United States and who is temporarily in the United States primarily to study at a university or other recognized edu-cational institution in the United States, obtain professional training, or study or do research as a recipient of a grant, allowance, or award from a governmental, religious, charitable, scientific, literary, or educational organization is exempt from U.S. income tax on the following amounts.

Amounts from abroad for maintenance, ed-ucation, study, research, or training.The grant, allowance, or award.Income from personal services performed in the United States of up to $2,000 each tax year.

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

An individual who is a resident of Korea on the date of arrival in the United States and who is temporarily in the United States as an em-ployee of, or under contract with, a resident of Korea is exempt from U.S. income tax for 1 year on up to $5,000 received for personal services if the individual is in the United States primarily to:

Acquire technical, professional, or busi-ness experience from a person other than that resident of Korea or other than a per-son related to that resident, orStudy at an educational institution.

An individual who is a resident of Korea on the date of arrival in the United States and who is temporarily present in the United States for not longer than 1 year as a participant in a pro-gram sponsored by the U.S. Government pri-marily to train, research, or study is exempt from U.S. income tax on income received for personal services for the training, research, or study for a maximum of $10,000.

LatviaAn individual who is a resident of Latvia on the date of arrival in the United States and who is temporarily in the United States primarily to study at a university or other accredited educa-tional institution in the United States, obtain pro-fessional training, or study or do research as a recipient of a grant, allowance, or award from a governmental, religious, charitable, scientific, literary, or educational organization is exempt from U.S. income tax on the following amounts.

Payments from abroad, other than com-pensation for personal services, for main-tenance, education, study, research, or training.The grant, allowance, or award.Income from personal services performed in the United States of up to $5,000 for each tax year.

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

An individual who is a resident of Latvia on the date of arrival in the United States and who is in the United States as an employee of, or un-der contract with, a resident of Latvia is exempt from U.S. income tax for a period of 12 consec-utive months on up to $8,000 received for per-sonal services if the individual is in the United States primarily to:

Acquire technical, professional, or busi-ness experience from a person other than that resident of Latvia, orStudy at an educational institution.

An individual who is a resident of Latvia on the date of arrival in the United States and who is temporarily present in the United States for not longer than 1 year as a participant in a pro-gram sponsored by the U.S. Government pri-marily to train, research, or study is exempt from U.S. income tax on income received for personal services for the training, research, or study in the amount of $10,000.

These provisions do not apply to income from research carried on mainly for the private benefit of any person rather than in the public interest.

LithuaniaAn individual who is a resident of Lithuania on the date of arrival in the United States and who is temporarily in the United States primarily to study at a university or other accredited educa-tional institution in the United States, obtain pro-fessional training, or study or do research as a recipient of a grant, allowance, or award from a governmental, religious, charitable, scientific, literary, or educational organization is exempt from U.S. income tax on the following amounts.

Payments from abroad, other than com-pensation for personal services, for main-tenance, education, study, research, or training.The grant, allowance, or award.Income from personal services performed in the United States of up to $5,000 for each tax year.

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

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

Acquire technical, professional, or busi-ness experience from a person other than that resident of Lithuania, orStudy at an educational institution.

An individual who is a resident of Lithuania on the date of arrival in the United States and who is temporarily present in the United States for not longer than 1 year as a participant in a program sponsored by the U.S. Government primarily to train, research, or study is exempt from U.S. income tax on income received for personal services for the training, research, or study in the amount of $10,000.

These provisions do not apply to income from research carried on mainly for the private benefit of any person rather than in the public interest.

LuxembourgA student, apprentice, or business trainee who is a resident of Luxembourg immediately before visiting the United States and is in the United States for the purpose of full-time education at a recognized educational institution or full-time training is exempt from U.S. income tax on amounts received for the individual's mainte-nance, education, or training.

Apprentices and business trainees are enti-tled to the benefit of this exemption for a maxi-mum period of 2 years.

Page 23 of 61 Fileid: … ons/P901/201304/A/XML/Cycle02/source 10:02 - 11-Mar-2013The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

Publication 901 (April 2013) Page 23

Page 24: Treaties U.S. TaxTurkmenistan, and Uzbekistan. That treaty will remain in effect until new treaties with these in-dividual countries are negotiated and ratified. Provisions of the

If the individual's visit to the United States is longer than 2 years, the exemption is lost for the entire visit unless the competent authorities of Luxembourg and the United States agree other-wise.

MaltaA student or business trainee, who is a resident of Malta immediately before visiting the United States and is in the United States for the pur-pose of full-time education or training, is exempt from U.S. income tax on the following amounts.

Payments received from sources outside the United States for the individual's main-tenance, education, or training. Apprenti-ces and business trainees are entitled to this benefit for a maximum period of 1 year.Income from personal services performed in the United States of up to $9,000 for each tax year.

MexicoA student or business apprentice who is a resi-dent of Mexico immediately before visiting the United States and is in the United States solely for the purpose of education or training is ex-empt from U.S. tax on amounts received from sources outside the United States for the indi-vidual's maintenance, education, or training.

MoroccoAn individual who is a resident of Morocco on the date of arrival in the United States and who is temporarily in the United States primarily to study at a university or other recognized educa-tional institution in the United States, obtain pro-fessional training, or study or do research as a recipient of a grant, allowance, or award from a governmental, religious, charitable, scientific, literary, or educational organization is exempt from U.S. income tax on the following amounts.

Gifts from abroad for maintenance, educa-tion, study, research, or training.The grant, allowance, or award.Income from personal services performed in the United States of up to $2,000 each tax year.

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

NetherlandsAn individual who immediately before visiting the United States is a resident of the Nether-lands and who is present in the United States primarily for full-time study at a recognized uni-versity, college, or school or securing training as a business apprentice is exempt from U.S. income tax on the following amounts.

Payments from abroad for maintenance, education, or training.Income from personal services performed in the United States of up to $2,000 each tax year.

The individual is entitled to this exemption only for a period of time considered reasonable

or customarily required to complete studying or training.

An individual who immediately before visit-ing the United States is a resident of the Nether-lands and is temporarily present in the United States for a period not exceeding 3 years for the purpose of study, research, or training solely as a recipient of a grant, allowance, or award from a scientific, educational, religious, or charitable organization or under a technical assistance program entered into by either the Netherlands or the United States, or its political subdivisions or local authorities is exempt from U.S. income tax on the following amounts.

The amount of the grant, allowance, or award.Income of up to $2,000 for personal serv-ices performed in the United States for any tax year if the services are connected with, or incidental to, the study, research, or training.

An individual is not entitled to these exemp-tions if, during the immediately preceding pe-riod, the individual claimed the exemption dis-cussed earlier under Professors, Teachers, and Researchers.

New ZealandA resident of New Zealand or an individual who was a resident of New Zealand immediately be-fore visiting the United States who is in the Uni-ted States for full-time education is exempt from U.S. income tax on amounts received from abroad for maintenance or education.

NorwayAn individual who is a resident of Norway on the date of arrival in the United States and who is temporarily in the United States primarily to study at a university or other recognized educa-tional institution in the United States, obtain pro-fessional training, or study or do research as a recipient of a grant, allowance, or award from a governmental, religious, charitable, scientific, literary, or educational organization is exempt from U.S. income tax on the following amounts.

Gifts from abroad for maintenance, educa-tion, study, research, or training.The grant, allowance, or award.Income from personal services performed in the United States of up to $2,000 each tax year.

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

An individual who is a resident of Norway on the date of arrival in the United States and who is in the United States as an employee of, or un-der contract with, a resident of Norway is ex-empt from U.S. income tax for a period of 12 consecutive months on up to $5,000 received for personal services if the individual is in the United States primarily to:

Acquire technical, professional, or busi-ness experience from a person other than that resident of Norway or other than a per-son related to that resident of Norway, orStudy at an educational institution.

Also exempt is a resident of Norway who is present in the United States for not longer than 1 year as a participant in a program sponsored by the Government of the United States primar-ily to train, research, or study. The individual is exempt from tax on income from personal serv-ices performed in the United States and re-ceived for the training, research, or study, for a maximum of $10,000.

PakistanResidents of Pakistan temporarily in the United States are exempt from U.S. income tax on cer-tain income they may receive. To be entitled to this exemption, they must be in the United States only as students at a recognized univer-sity, college, or school, or as recipients of grants, allowances, or awards from religious, charitable, scientific, or educational organiza-tions of Pakistan primarily to study or research. The income exempt in these cases is any pay-ment from abroad for maintenance, education, or training, and any pay for personal services of not more than $5,000 for any tax year.

Other residents of Pakistan who are tempo-rarily in the United States for no more than 1 year are exempt from U.S. income tax on pay of not more than $6,000 received for that period, including pay from the enterprise or organiza-tion of which they are employees or with which they are under contract. To qualify for this ex-emption, they must be employees of, or under contract with, a Pakistani enterprise or religious, charitable, scientific, or educational organiza-tion and be in the United States only to acquire technical, professional, or business experience from a person other than that enterprise or or-ganization.

Also exempt from U.S. income tax on cer-tain income are residents of Pakistan tempora-rily in the United States under an arrangement with the U.S. Government, or any of its agen-cies or instrumentalities, only for study, training, or orientation. They are exempt from tax on in-come of not more than $10,000 for services di-rectly related to their training, study, or orienta-tion, including income from their employer abroad.

PhilippinesAn individual who is a resident of the Philip-pines on the date of arrival in the United States and who is temporarily in the United States pri-marily to study at a university or other recog-nized educational institution in the United States, obtain professional training, or study or do research as a recipient of a grant, allowance, or award from a governmental, religious, chari-table, scientific, literary, or educational organi-zation is exempt from U.S. income tax on the following amounts.

Gifts from abroad for maintenance, educa-tion, study, research, or training.The grant, allowance, or award.Income from personal services performed in the United States of up to $3,000 each tax year.

Page 24 of 61 Fileid: … ons/P901/201304/A/XML/Cycle02/source 10:02 - 11-Mar-2013The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

Page 24 Publication 901 (April 2013)

Page 25: Treaties U.S. TaxTurkmenistan, and Uzbekistan. That treaty will remain in effect until new treaties with these in-dividual countries are negotiated and ratified. Provisions of the

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

An individual who is a resident of the Philip-pines on the date of arrival in the United States and who is temporarily in the United States as an employee of, or under contract with, a resi-dent of the Philippines is exempt from U.S. in-come tax for a period of 12 consecutive months on up to $7,500 received for personal services if the individual is in the United States primarily to:

Acquire technical, professional, or busi-ness experience from a person other than that resident of the Philippines or other than a person related to that resident, orStudy at an educational institution.

An individual who is a resident of the Philip-pines on the date of arrival in the United States, and who is temporarily in the United States (for no more than 1 year as a participant in a pro-gram sponsored by the U.S. Government) pri-marily to train, research, or study is exempt from U.S. income tax on income received for personal services for the training, research, or study, up to a maximum of $10,000.

PolandAn individual who is a resident of Poland on the date of arrival in the United States and who is temporarily in the United States primarily to study at a university or other recognized educa-tional institution in the United States, obtain pro-fessional training, or study or do research as a recipient of a grant, allowance, or award from a governmental, religious, charitable, scientific, literary, or educational organization is exempt from U.S. income tax on the following amounts.

Gifts from abroad for maintenance, educa-tion, study, research, or training.The grant, allowance, or award.Any other payments received from Poland, except income from performing personal services.Income from personal services performed in the United States of up to $2,000 each tax year.

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

An individual who is a resident of Poland on the date of arrival in the United States and who is temporarily in the United States as an em-ployee of, or under contract with, a resident of Poland is exempt from U.S. income tax for 1 year on up to $5,000 received for personal serv-ices if the individual is in the United States pri-marily to:

Acquire technical, professional, or busi-ness experience from a person other than that resident of Poland or other than a per-son related to that resident, orStudy at an educational institution.

An individual who is a resident of Poland on the date of arrival in the United States and who is temporarily in the United States for not longer than 1 year as a participant in a program spon-sored by the U.S. Government primarily to train, research, or study is exempt from U.S. income

tax on up to $10,000 of income received for per-sonal services for the training, research, or study.

PortugalAn individual who is a resident of Portugal on the date of arrival in the United States and who is temporarily in the United States primarily to study at a university or other accredited educa-tional institution in the United States, obtain pro-fessional training, or study, or do research as a recipient of a grant, allowance, or award from a governmental, religious, charitable, scientific, literary, or educational organization is exempt from U.S. income tax on the following amounts.

Payments from abroad for maintenance, education, study, research, or training.The grant, allowance, or award.Income from personal services performed in the United States of up to $5,000 each tax year.

An individual is entitled to the benefit of this exemption for a maximum of 5 tax years from the date of arrival in the United States. The ben-efits provided here and the benefits described earlier under Professors, Teachers, and Re­searchers cannot be claimed simultaneously or consecutively.

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

Acquire technical, professional, or busi-ness experience from a person other than that resident of Portugal, orStudy at an educational institution.

RomaniaAn individual who is a resident of Romania on the date of arrival in the United States and who is temporarily in the United States primarily to study at a university or other recognized educa-tional institution in the United States, obtain pro-fessional training, or study or do research as a recipient of a grant, allowance, or award from a governmental, religious, charitable, scientific, literary, or educational organization is exempt from U.S. income tax on the following amounts.

Gifts from abroad for maintenance, educa-tion, study, research, or training.The grant, allowance, or award.Income from personal services performed in the United States of up to $2,000 each tax year.

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

An individual who is a resident of Romania on the date of arrival in the United States and who is temporarily in the United States as an employee of, or under contract with, a resident of Romania is exempt from U.S. income tax for 1 year on up to $5,000 received for personal

services if the individual is in the United States primarily to:

Acquire technical, professional, or busi-ness experience from a person other than that resident of Romania or other than a person related to that resident, orStudy at an educational institution.

An individual who is a resident of Romania on the date of arrival in the United States and who is temporarily in the United States for not longer than 1 year as a participant in a program sponsored by the U.S. Government primarily to train, research, or study is exempt from U.S. in-come tax on up to $10,000 of income received for personal services for the training, research, or study.

RussiaAn individual who is a resident of Russia at the beginning of his or her visit to the United States is exempt from U.S. tax on payments from abroad for maintenance, education, study, re-search, or training and on any grant, allowance, or other similar payments. To be entitled to the exemption, the individual must be temporarily present in the United States primarily to:

Study at a university or other accredited educational institution,Obtain training required to qualify him or her to practice a profession or professional specialty, orStudy or do research as a recipient of a grant, allowance, or other similar payments from a governmental, religious, charitable, scientific, literary, or educational organiza-tion.

The individual is entitled to this exemption only for a period of time necessary to complete the study, training, or research, but the exemp-tion for training or research may not extend for a period exceeding 5 years.

These exemptions do not apply to income from research if it is undertaken primarily for the private benefit of a specific person or persons.

Slovak RepublicAn individual who is a resident of the Slovak Republic at the beginning of his or her visit to the United States and who is temporarily present in the United States is exempt from U.S. income tax on certain amounts for a period of up to 5 years. To be entitled to the exemp-tion, the individual must be in the United States for the primary purpose of:

Studying at a university or other accredited educational institution in the United States,Obtaining training required to qualify him or her to practice a profession or professional specialty, orStudying or doing research as a recipient of a grant, allowance, or award from a gov-ernmental, religious, charitable, scientific, literary, or educational organization.

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

The payments from abroad, other than compensation for personal services, for

Page 25 of 61 Fileid: … ons/P901/201304/A/XML/Cycle02/source 10:02 - 11-Mar-2013The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

Publication 901 (April 2013) Page 25

Page 26: Treaties U.S. TaxTurkmenistan, and Uzbekistan. That treaty will remain in effect until new treaties with these in-dividual countries are negotiated and ratified. Provisions of the

the purpose of maintenance, education, study, research, or training.The grant, allowance, or award.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 at the beginning of the visit to the United States and who is temporarily present in the United States as an employee of, or under contract with, a Slovak resident is exempt from U.S. income tax for a period of 12 consecutive months on up to $8,000 received from personal services if the individual is in the United States primarily to:

Acquire technical, professional, or busi-ness experience from a person other than the Slovak resident, orStudy at a university or other accredited educational institution in the United States.

An individual who is a Slovak resident at the time he or she becomes temporarily present in the United States and who is temporarily present in the United States for a period not lon-ger than 1 year as a participant in a program sponsored by the U.S. government for the pri-mary purpose of training, research, or study is exempt from U.S. income tax on up to $10,000 of income from personal services for that train-ing, research, or study.

These exemptions do not apply to income from research undertaken primarily for the pri-vate benefit of a specific person or persons.

SloveniaAn individual who is a resident of Slovenia at the beginning of the visit to the United States and who is temporarily in the United States pri-marily to study at a U.S. university or other rec-ognized educational institution, to obtain train-ing to become qualified to practice a profession or professional specialty, or to study or do re-search as a recipient of a grant, allowance, or award from a governmental, religious, charita-ble, scientific, literary, or educational organiza-tion is exempt from U.S. income tax on the fol-lowing amounts.

Payments from abroad (other than com-pensation for personal services) for main-tenance, education, study, research, or training.The grant, allowance, or award.Income from personal services performed in the United States of up to $5,000 for each tax year.

An individual is entitled to the benefit of this ex-emption for a maximum of 5 tax years and for any additional period of time needed to com-plete, as a full-time student, educational re-quirements as a candidate for a postgraduate or professional degree from a recognized edu-cational institution.

An individual who is a resident of Slovenia on the date of arrival in the United States and who is temporarily in the United States as an employee of, or under contract with, a resident of Slovenia is exempt from U.S. income tax for a period not exceeding 12 months on up to

$8,000 received for personal services if the individual is in the United States primarily to:

Acquire technical, professional, or busi-ness experience from a person other than that resident of Slovenia, orStudy at a university or other recognized educational institution.

These provisions do not apply to income from research carried on mainly for the private benefit of any person rather than in the public interest.

South AfricaA student, apprentice, or business trainee who is a resident of South Africa immediately before visiting the United States and is in the United States for the purpose of full-time education or training is exempt from U.S. income tax on amounts received from sources outside the Uni-ted States for the individual's maintenance, ed-ucation, or training.

Apprentices and business trainees are enti-tled to the benefit of this exemption for a maxi-mum period of 1 year.

SpainAn individual who is a resident of Spain at the beginning of the visit to the United States and who is temporarily in the United States primarily to study at a U.S. university or other accredited educational institution, to obtain training to be-come qualified to practice a profession or pro-fessional specialty, or to study or do research as a recipient of a grant, allowance, or award from a governmental, religious, charitable, sci-entific, literary, or educational organization is exempt from U.S. income tax on the following amounts.

Payments from abroad (other than com-pensation for personal services) for main-tenance, education, study, research, or training.The grant, allowance, or award.Income from personal services performed in the United States of up to $5,000 for each tax year.

An individual is entitled to the benefit of this ex-emption for a maximum of 5 years.

An individual who is a resident of Spain at the beginning of the visit to the United States and is temporarily in the United States as an employee of, or under contract with, a resident of Spain is exempt from U.S. income tax for a period of 12 consecutive months on up to $8,000 received for personal services if the indi-vidual is in the United States primarily to:

Acquire technical, professional, or busi-ness experience from a person other than that Spanish resident, orStudy at a university or other accredited educational institution in the United States.

Both the $5,000 and $8,000 exemptions in-clude any amount excluded or exempted from tax under U.S. tax law.

These exemptions do not apply to income from research carried on mainly for the private

benefit of any person rather than in the public interest.

Sri LankaA student, apprentice, or business trainee, who is a resident of Sri Lanka resident immediately before visiting the United States and is in the United States for the purpose of full-time educa-tion or training, is exempt from U.S. income tax on amounts received from sources outside the United States for the individual's maintenance, education, or training.

An individual who is a resident of Sri Lanka on the date of arrival in the United States and who is temporarily in the United States as an employee of, or under contract with, a resident of Sri Lanka, or as a participant in a program sponsored by the United States or by any inter-national organization, is exempt from U.S. in-come tax for a period not exceeding 1 year on up to $6,000 received for personal services if the individual is in the United States primarily to:

Acquire technical, professional, or busi-ness experience from a person other than that resident of Sri Lanka or other than a person related to that resident, orStudy at a university or other recognized educational institution.

SwedenA student, apprentice, or business trainee who is a resident of Sweden immediately before vis-iting the United States and is in the United States for the purpose of full-time education or training is exempt from U.S. tax on amounts re-ceived from sources outside the United States for the individual's maintenance, education, and training.

SwitzerlandA student, apprentice, or business trainee who is a resident of Switzerland immediately before visiting the United States and is in the United States for the purpose of full-time education or training is exempt from U.S. income tax on amounts received from sources outside the Uni-ted States for the individual's maintenance, ed-ucation, or training.

ThailandAn individual who is a resident of Thailand at the beginning of his or her visit to the United States and who is temporarily present in the United States is exempt from U.S. income tax on certain amounts for a period of up to 5 years. To be entitled to the exemption, the individual must be in the United States for the primary pur-pose of:

Studying at a university or other recog-nized educational institution in the United States,Obtaining training required to qualify him or her to practice a profession or professional specialty, orStudying or doing research as a recipient of a grant, allowance, or award from a gov-ernmental, religious, charitable, scientific, literary, or educational organization.

Page 26 of 61 Fileid: … ons/P901/201304/A/XML/Cycle02/source 10:02 - 11-Mar-2013The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

Page 26 Publication 901 (April 2013)

Page 27: Treaties U.S. TaxTurkmenistan, and Uzbekistan. That treaty will remain in effect until new treaties with these in-dividual countries are negotiated and ratified. Provisions of the

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

Gifts from abroad for the purpose of main-tenance, education, study, research, or training.The grant, allowance, or award.Income from personal services performed in the United States of up to $3,000 for the tax year.

An individual who is a resident of Thailand at the beginning of the visit to the United States and who is temporarily present in the United States as an employee of, or under contract with, a resident of Thailand is exempt from U.S. income tax for a period of 12 consecutive months on up to $7,500 received from personal services if the individual is in the United States primarily to:

Acquire technical, professional, or busi-ness experience from a person other than the Thai resident, orStudy at a university or other recognized educational institution in the United States.

An individual who is a resident of Thailand at the time he or she becomes temporarily present in the United States and who is temporarily present in the United States for a period not lon-ger than 1 year as a participant in a program sponsored by the U.S. government for the pri-mary purpose of training, research, or study is exempt from U.S. income tax on up to $10,000 of income from personal services for that train-ing, research, or study.

Trinidad and TobagoAn individual who is a resident of Trinidad and Tobago on the date of arrival in the United States and who is temporarily in the United States primarily to study at a university or other accredited educational institution in the United States, obtain professional training, or study or do research as a recipient of a grant, allowance, or award from a governmental, religious, chari-table, scientific, literary, or educational organi-zation is exempt from U.S. income tax on the following amounts.

Gifts from abroad for maintenance, educa-tion, study, research, or training.The grant, allowance, or award.Income from personal services performed in the United States of up to $2,000 each tax year, or, if the individual is obtaining training required to qualify to practice a profession or a professional specialty, a maximum of $5,000 for any tax year.

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

An individual who is a resident of Trinidad and Tobago on the date of arrival in the United States and who is in the United States as an employee of, or under contract with, a resident or corporation of Trinidad and Tobago is ex-empt from U.S. income tax for 1 tax year on up to $5,000 received for personal services if the individual is in the United States primarily to:

Study at an educational institution, or

Acquire technical, professional, or busi-ness experience from a person other than that resident or corporation of Trinidad and Tobago.

Also exempt is a resident of Trinidad and Tobago who is present in the United States for not longer than 1 year as a participant in a pro-gram sponsored by the U.S. Government pri-marily to train, research, or study. The individual is exempt from tax on income from personal services performed in the United States and re-ceived for the training, research, or study for up to a maximum of $10,000.

TunisiaAn individual who is a resident of Tunisia imme-diately before visiting the United States and who is in the United States for full-time study or training is exempt from U.S. income tax on the following amounts.

Payments from abroad for full-time study or training.A grant, allowance, or award from a gov-ernmental, religious, charitable, scientific, literary, or educational organization to study or engage in research.Income from personal services performed in the United States of up to $4,000 in any tax year.

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

TurkeyA student, apprentice, or business trainee who is a resident of Turkey immediately before visit-ing the United States and is in the United States for the purpose of full-time education or training is exempt from U.S. income tax on amounts re-ceived from sources outside the United States for the individual's maintenance, education, or training.

UkraineAn individual who is a resident of Ukraine at the beginning of his or her visit to the United States is exempt from U.S. tax on payments from abroad for maintenance, education, study, re-search, or training and on any grant, allowance, or other similar payments. To be entitled to the exemption, the individual must be temporarily present in the United States primarily to:

Study at a university or other accredited educational institution,Obtain training required to qualify him or her to practice a profession or professional specialty, orStudy or do research as a recipient of a grant, allowance, or other similar payments from a governmental, religious, charitable, scientific, literary, or educational organiza-tion.

The individual is entitled to this exemption only for a period of time necessary to complete the study, training, or research, but the exemp-tion for training or research may not extend for a period exceeding 5 years.

These exemptions do not apply to income from research if it is undertaken primarily for the private benefit of a specific person or persons.

United KingdomA student or business apprentice who is a resi-dent of the United Kingdom immediately before visiting the United States and is in the United States for the purpose of full-time education at a recognized educational institution or full-time training is exempt from U.S. income tax on amounts received from abroad for the individu-al's maintenance, education, or training.

Apprentices and business trainees are enti-tled to the benefit of this exemption for a maxi-mum period of 1 year.

VenezuelaAn individual who is a resident of Venezuela on the date of arrival in the United States and who is temporarily in the United States primarily to study at a university or other recognized educa-tional institution in the United States, obtain pro-fessional training, or study or do research as a recipient of a grant, allowance, or award from a governmental, religious, charitable, scientific, literary, or educational organization is exempt from U.S. income tax on the following amounts.

Payments from abroad, other than com-pensation for personal services, for main-tenance, education, study, research, or training.The grant, allowance, or award.Income from personal services performed in the United States of up to $5,000 for each tax year.

An individual is generally entitled to the ben-efit of this exemption for a maximum of 5 years from the date of arrival in the United States. This exemption will also apply to any additional period of time that a full-time student needs to complete the educational requirements as a candidate for a postgraduate or professional degree from a recognized educational institu-tion.

An individual who is a resident of Venezuela on the date of arrival in the United States and who is in the United States as an employee of, or under contract with, a resident of Venezuela is exempt from U.S. income tax for a period of 12 months on up to $8,000 received for per-sonal services if the individual is in the United States primarily to:

Acquire technical, professional, or busi-ness experience from a person other than that resident of Venezuela, orStudy at an educational institution.

These provisions do not apply to income from research carried on mainly for the private benefit of any person rather than in the public interest.

Page 27 of 61 Fileid: … ons/P901/201304/A/XML/Cycle02/source 10:02 - 11-Mar-2013The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

Publication 901 (April 2013) Page 27

Page 28: Treaties U.S. TaxTurkmenistan, and Uzbekistan. That treaty will remain in effect until new treaties with these in-dividual countries are negotiated and ratified. Provisions of the

Wages and PensionsPaid by a ForeignGovernmentWages, salaries, pensions, and annuities paid by the governments of the following countries to their residents who are present in the United States as nonresident aliens generally are ex-empt from U.S. income tax. The conditions un-der which the income is exempt are stated for each of the countries listed.

Exemption under U.S. tax law. Employees of foreign countries who do not qualify under a tax treaty provision and employees of international organizations should see if they can qualify for exemption under U.S. tax law.

If you work for a foreign government in the United States, your foreign government salary is exempt from U.S. tax if you perform services similar to those performed by U.S. government employees in that foreign country and that for-eign government grants an equivalent exemp-tion. If you work for an international organization in the United States, your salary from that source is exempt from U.S. tax. See chapter 10 of Publication 519 for more information.

AustraliaSalaries, wages, and similar income, including pensions, paid by Australia, its political subdivi-sions, agencies, or authorities to its citizens (other than U.S. citizens) for performing govern-mental functions as an employee of any of the above entities are exempt from U.S. income tax.

AustriaWages, salaries, similar income, and pensions and annuities paid from public funds of Austria, its political subdivisions, or its local authorities, to citizens of Austria for performing governmen-tal functions as an employee are exempt from U.S. tax.

However, this exemption does not apply to payments for services performed in connection with a trade or business carried on by Austria or its political subdivisions or local authorities.

BangladeshIncome, other than a pension, paid by Bangla-desh, its political subdivisions, or local authori-ties to an individual for services performed for the paying governmental body is exempt from U.S. income tax. However, the exemption does not apply if the services are performed in the United States by a resident of the United States who either:

Is a U.S. citizen, orDid not become a U.S. resident only to perform the services.

Pensions paid from the public funds of Ban-gladesh, its political subdivisions, or local au-thorities for services performed for Bangladesh, its political subdivisions, or local authorities to an individual for services performed for the pay-ing governmental body are exempt from U.S.

income tax unless the recipient is both a resi-dent and citizen of the United States.

This exemption does not apply to income or pensions for services performed in connection with a business carried on by Bangladesh, its political subdivisions, or local authorities.

BarbadosIncome, including a pension, paid from the pub-lic funds of Barbados, or its political subdivi-sions or local authorities, to a citizen of Barba-dos for performing governmental functions is exempt from U.S. income tax.

However, this exemption does not apply to payments for services in connection with a busi-ness carried on by Barbados or its political sub-divisions or local authorities.

BelgiumWages, salaries, and similar income, other than a pension, paid by Belgium, its political subdivi-sions, or local authorities to an individual for services performed for the paying governmental body is exempt from U.S. income tax. However, the exemption does not apply if the services are performed in the United States by a resident of the United States who either:

Is a U.S. national, orDid not become a U.S. resident only to perform the services.

Pensions paid by, or out of funds created by, Belgium, its political subdivisions, or local authorities for services performed for Belgium, its political subdivisions, or local authorities to an individual for services performed for the pay-ing governmental body are exempt from U.S. in-come tax unless the recipient is both a resident and national of the United States.

However, these exemptions do not apply to payments for services performed in connection with a business carried on by Belgium, its politi-cal subdivisions, or local authorities.

BulgariaWages, salaries, and similar income, other than a pension, paid by Bulgaria, its political subdivi-sions, or local authorities to an individual for services performed for the paying governmental body are exempt from U.S. income tax. How-ever, the exemption does not apply if the serv-ices are performed in the United States by a resident of the United States who either:

Is a U.S. national, orDid not become a U.S. resident only to perform the services.

Pensions paid by, or out of funds created by, Bulgaria, its political subdivisions, or local authorities for services performed for Bulgaria, its political subdivisions, or local authorities to an individual for services performed for the pay-ing governmental body are exempt from U.S. in-come tax unless the recipient is both a resident and national of the United States.

However, these exemptions do not apply to payments for services performed in connection with a business carried on by Bulgaria, its politi-cal subdivisions, or local authorities.

CanadaWages, salaries, and similar income (other than pensions) paid by Canada or by a Canadian po-litical subdivision or local authority to a citizen of Canada for performing governmental functions are exempt from U.S. income tax. This exemp-tion does not apply, however, to payments for services performed in connection with a trade or business carried on by Canada or its political subdivisions or local authorities.

Also see Publication 597, Information on the United States–Canada Income Tax Treaty.

China, People's Republic ofIncome, other than a pension, paid by the Peo-ple's Republic of China or its political subdivi-sions or local authorities to an individual for services performed for the paying governmental body is exempt from U.S. income tax. However, the exemption does not apply to payments for services performed in the United States by a resident of the United States who either:

Is a U.S. citizen, orDid not become a U.S. resident only to perform the services.

Pensions paid by the People's Republic of China for services performed for China are ex-empt from U.S. income tax unless the recipient is both a citizen and a resident of the United States.

These exemptions do not apply to income or pensions for services performed in connection with a business carried on by the People's Re-public of China or its subdivisions or local au-thorities.

Commonwealth ofIndependent States (C.I.S.)Wages, salaries, and similar income paid by the C.I.S. or a member of the C.I.S. to its citizens for personal services performed as an em-ployee of a governmental agency or institution of the C.I.S. or a member of the C.I.S. (exclud-ing local government employees) in the dis-charge of governmental functions are exempt from U.S. income tax. For this purpose, persons engaged in commercial activities are not con-sidered engaged in the discharge of govern-mental functions.

CyprusWages, salaries, and similar income, including pensions, annuities, and similar benefits, paid from public funds of Cyprus to a citizen of Cy-prus for labor or personal services performed as an employee of Cyprus in the discharge of governmental functions are exempt from U.S. income tax.

Page 28 of 61 Fileid: … ons/P901/201304/A/XML/Cycle02/source 10:02 - 11-Mar-2013The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

Page 28 Publication 901 (April 2013)

Page 29: Treaties U.S. TaxTurkmenistan, and Uzbekistan. That treaty will remain in effect until new treaties with these in-dividual countries are negotiated and ratified. Provisions of the

Czech RepublicIncome, including a pension, paid from the pub-lic funds of the Czech Republic, its political sub-divisions, or local authorities to a Czech citizen for services performed in the discharge of gov-ernmental functions is exempt from U.S. in-come tax. This exemption does not apply to in-come paid for services performed in connection with a business carried on by the Czech Repub-lic, its political subdivisions, or local authorities.

DenmarkIncome, other than a pension, paid from public funds of Denmark, its political subdivisions, or local authorities to an individual for services performed for the paying governmental body in the discharge of governmental functions is ex-empt from U.S. income tax. However, the ex-emption does not apply if the services are per-formed in the United States by a resident of the United States who either:

Is a U.S. national, orDid not become a U.S. resident only to perform the services.

Pensions paid from the public funds of Den-mark, its political subdivisions, or local authori-ties for services performed for Denmark are ex-empt from U.S. income tax unless the recipient is a resident and a national of the United States.

These exemptions do not apply to income or pensions for services performed in connection with a trade or business carried on by Denmark, its political subdivisions, or local authorities.

EgyptWages, salaries, and similar income, including pensions, annuities, and similar benefits, paid from public funds of the Arab Republic of Egypt to a citizen of Egypt (or to a citizen of another country who comes to the United States specifi-cally to work for the Government of Egypt) for labor or personal services performed as an em-ployee of the national Government of Egypt, or any of its agencies, in the discharge of govern-mental functions are exempt from U.S. income tax.

This exemption does not apply to U.S. citi-zens or to alien residents of the United States. The exemption also does not apply to payments for services performed in connection with a trade or business carried on by Egypt or any of its agencies.

EstoniaIncome, other than a pension, paid by or from public funds of Estonia, its political subdivi-sions, or local authorities to an individual for services performed as an employee for the pay-ing governmental body in the discharge of gov-ernmental functions is exempt from U.S. in-come tax. However, the exemption does not apply if the services are performed in the United States by a resident of the United States who either:

Is a U.S. citizen, or

Did not become a U.S. resident only to perform the services.

Pensions paid by or from the public funds of Estonia, its political subdivisions, or local au-thorities for services performed for Estonia are exempt from U.S. income tax unless the recipi-ent is both a resident and citizen of the United States.

FinlandIncome, other than a pension, paid by Finland, its political subdivisions, statutory bodies, or lo-cal authorities to an individual for services per-formed for the paying governmental body is ex-empt from U.S. income tax. However, the exemption does not apply to payments for serv-ices performed in the United States by a U.S. resident who either:

Is a U.S. citizen, orDid not become a U.S. resident only to perform the services.

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

These exemptions do not apply to income or pensions for services performed in connection with a trade or business carried on by Finland or its political subdivisions, statutory bodies, or lo-cal authorities.

FranceIncome, other than a pension, paid by the French Government or a local authority thereof to an individual in the United States for services performed for France (or for a local authority of France) in the discharge of governmental func-tions is exempt from U.S. tax. This exemption does not apply to a person who is both a resi-dent and citizen of the United States or a green card holder.

This exemption does not apply to any in-come paid because of services (or past serv-ices) performed in connection with a business carried on by the French Government (or a local authority thereof).

GermanyWages, salaries, and similar income, other than a pension, paid by Germany, its political subdi-visions, local authorities, or instrumentalities to an individual for services performed for the pay-ing governmental body is exempt from U.S. in-come tax. However, the exemption does not apply if the services are performed in the United States by a resident of the United States who either:

Is a U.S. national, orDid not become a U.S. resident only to perform the services.

Pensions paid by, or out of funds created by, Germany, its political subdivisions, local au-thorities, or instrumentalities for services per-formed for the paying governmental body are

exempt from U.S. income tax unless the recipi-ent is both a resident and a national of the Uni-ted States.

This exemption does not apply to income or pensions for services performed in connection with a business carried on by Germany, its polit-ical subdivisions, local authorities, or instrumen-talities.

GreeceWages, salaries, and similar income and pen-sions paid by Greece or its subdivisions to indi-viduals living in the United States for services rendered to Greece or its subdivisions are ex-empt from U.S. income tax. This exemption does not apply to citizens of the United States or alien residents of the United States.

HungaryIncome (other than a pension) paid by the Re-public of Hungary or its political subdivisions for labor or personal services performed for the paying governmental body is exempt from U.S. tax. However, the exemption does not apply to payments for services performed in the United States by a resident of the United States who either:

Is a U.S. citizen, orDid not become a resident of the United States only to perform the services.

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

These exemptions do not apply to income or pensions for services performed in connection with a trade or business carried on by Hungary or its subdivisions.

IcelandWages, salaries, and similar income, other than a pension, paid by Iceland, its political subdivi-sions, or local authorities to an individual for services performed for the paying governmental body are exempt from U.S. income tax. How-ever, the exemption does not apply if the serv-ices are performed in the United States by a resident of the United States who either:

Is a U.S. national, orDid not become a U.S. resident only to perform the services.

Pensions paid by, or out of funds created by, Iceland, its political subdivisions, or local au-thorities for services performed for Iceland, its political subdivisions, or local authorities to an individual for services performed for the paying governmental body are exempt from U.S. in-come tax unless the recipient is both a resident and national of the United States.

However, these exemptions do not apply to payments for services performed in connection with a business carried on by Iceland, its politi-cal subdivisions, or local authorities.

Page 29 of 61 Fileid: … ons/P901/201304/A/XML/Cycle02/source 10:02 - 11-Mar-2013The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

Publication 901 (April 2013) Page 29

Page 30: Treaties U.S. TaxTurkmenistan, and Uzbekistan. That treaty will remain in effect until new treaties with these in-dividual countries are negotiated and ratified. Provisions of the

IndiaIncome, other than a pension, paid by India, its political subdivisions, or local authorities to an individual for services performed for the paying governmental body is exempt from U.S. income tax. However, the exemption does not apply if the services are performed in the United States by a U.S. resident who either:

Is a U.S. citizen, orDid not become a U.S. resident only to perform the services.

Pensions paid by India for services per-formed for India are exempt from U.S. tax un-less the individual is both a resident and citizen of the United States.

These exemptions do not apply to income or pensions for services performed in connection with a business carried on by India, its subdivi-sions, or local authorities.

IndonesiaIncome, other than a pension, paid by Indone-sia, its political subdivisions, or local authorities to an individual for services performed for the paying governmental body is exempt from U.S. income tax. However, the exemption does not apply if the services are performed in the United States by a U.S. resident who either:

Is a U.S. citizen, orDid not become a U.S. resident only to perform the services.

Pensions paid by Indonesia for services per-formed for Indonesia are exempt from U.S. tax.

These exemptions do not apply to income or pensions for services performed in connection with a trade or business carried on by Indone-sia, its subdivisions, or local authorities.

IrelandIncome, other than a pension, paid by Ireland or its political subdivisions or local authorities to an individual for services performed for the paying governmental body is exempt from U.S. income tax. However, the exemption does not apply to payments for services performed in the United States by a resident of the United States who either:

Is a U.S. citizen, orDid not become a U.S. resident only to perform the services.

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

These exemptions do not apply to income or pensions for services performed in connection with a business carried on by Ireland or its sub-divisions or local authorities.

IsraelWages, salaries, and similar income, including pensions and similar benefits, paid from public

funds by the national government of Israel or its agencies, for services performed in the dis-charge of governmental functions, are exempt from U.S. income tax. This exemption does not apply to citizens of the United States or alien residents of the United States.

ItalyIncome, other than a pension, paid by Italy or by an Italian political or administrative subdivision or local authority to an individual for services performed for the paying governmental body is exempt from U.S. income tax. However, the ex-emption does not apply to payments for serv-ices performed in the United States by a resi-dent of the United States who either:

Is a U.S. national and not a national of Italy, orDid not become a U.S. resident only to perform the services.

The spouse and dependent children of an indi-vidual, however, are not subject to the second restriction if that individual is receiving exempt income for governmental services performed for Italy and that individual does not come under either of the restrictions.

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

These exemptions do not apply to income or pensions for services performed in connection with a trade or business carried on by Italy or its subdivisions or local authorities.

JamaicaIncome, other than a pension, paid by the Gov-ernment of Jamaica or its political subdivisions or local authorities for personal services per-formed for the paying governmental body is ex-empt from U.S. income tax.

This exemption does not apply to payments for services performed in the United States by an individual who is a citizen and resident of the United States.

Pensions paid by Jamaica for services per-formed for Jamaica generally are exempt from U.S. income tax. However, if the recipient of the pension is a citizen and resident of the United States and was a U.S. citizen at the time the services were performed, the pension is taxable in the United States.

These exemptions do not apply to income or pensions for services performed in connection with a trade or business carried on by Jamaica or its subdivisions or local authorities.

JapanIncome, other than a pension, paid by Japan, its political subdivisions, or local authorities to an individual for services performed for the paying governmental body is exempt from U.S. income tax. However, the exemption does not apply if

the services are performed in the United States by a resident of the United States who either:

Is a U.S. citizen, orDid not become a U.S. resident only to perform the services.

Pensions paid by, or out of funds to which contributions are made by, Japan, its political subdivisions, or local authorities for services performed for Japan are exempt from U.S. in-come tax unless the recipient is a resident and citizen of the United States.

These exemptions do not apply to income or pensions for services performed in connection with a business carried on by Japan, its political subdivisions, or local authorities.

KazakhstanIncome, other than a pension, paid by Kazakh-stan, or its subdivisions or local authorities to an individual for government services is exempt from U.S. tax. However, the exemption does not apply if the services are performed in the United States by a U.S. resident who either:

Is a U.S. citizen, orDid not become a U.S. resident solely for the purpose of performing the services.

These exemptions do not apply to income for services performed in connection with a busi-ness.

Pensions paid by Kazakhstan, or its subdivi-sions or local authorities for services performed for Kazakhstan is exempt from U.S. tax unless the individual is both a resident and citizen of the United States.

Korea, SouthWages, salaries, and similar income, including pensions and similar benefits, paid from public funds of South Korea to a citizen of Korea (other than a U.S. citizen or an individual admit-ted to the United States for permanent resi-dence) for services performed as an employee of Korea discharging government functions are exempt from U.S. income tax.

LatviaIncome, other than a pension, paid by or from public funds of Latvia, its political subdivisions, or local authorities to an individual for services performed as an employee for the paying gov-ernmental body in the discharge of governmen-tal functions is exempt from U.S. income tax. However, the exemption does not apply if the services are performed in the United States by a resident of the United States who either:

Is a U.S. citizen, orDid not become a U.S. resident only to perform the services.

Pensions paid by or from the public funds of Latvia, its political subdivisions, or local authori-ties for services performed for Latvia are ex-empt from U.S. income tax unless the recipient is both a resident and citizen of the United States.

Page 30 of 61 Fileid: … ons/P901/201304/A/XML/Cycle02/source 10:02 - 11-Mar-2013The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

Page 30 Publication 901 (April 2013)

Page 31: Treaties U.S. TaxTurkmenistan, and Uzbekistan. That treaty will remain in effect until new treaties with these in-dividual countries are negotiated and ratified. Provisions of the

LithuaniaIncome, other than a pension, paid by or from public funds of Lithuania, its political subdivi-sions, or local authorities to an individual for services performed as an employee for the pay-ing governmental body in the discharge of gov-ernmental functions is exempt from U.S. in-come tax. However, the exemption does not apply if the services are performed in the United States by a resident of the United States who either:

Is a U.S. citizen, orDid not become a U.S. resident only to perform the services.

Pensions paid by or from the public funds of Lithuania, its political subdivisions, or local au-thorities for services performed for Lithuania are exempt from U.S. income tax unless the recipi-ent is both a resident and citizen of the United States.

LuxembourgIncome, other than a pension, paid by Luxem-bourg, its political subdivisions, or local authori-ties to an individual for services performed for the paying governmental body is exempt from U.S. income tax. However, the exemption does not apply if the services are performed in the United States by a resident of the United States who either:

Is a U.S. citizen, orDid not become a U.S. resident only to perform the services.

Pensions paid by Luxembourg, its political subdivisions, or local authorities for services performed for Luxembourg are exempt from U.S. income tax unless the recipient is both a resident and citizen of the United States.

These exemptions do not apply to income or pensions for services performed in connection with a trade or business carried on by Luxem-bourg, its political subdivisions, or local authori-ties.

MaltaIncome, other than a pension, paid by Malta, its political subdivisions, or local authorities to an individual for services performed for the paying governmental body is exempt from U.S. income tax. However, the exemption does not apply if the services are performed in the United States by a U.S. resident who either:

Is a U.S. national, orDid not become a resident of the United States solely for purposes of performing the services.

Pensions paid by Malta, its political subdivi-sions, or local authorities for services performed for the paying governmental body are exempt from U.S. income tax unless the individual is both a resident and national of the United States.

These exemptions do not apply to income or pensions for services performed in connection

with a business carried on by Malta, its political subdivisions, or local authorities.

MexicoIncome, other than a pension, paid by Mexico, its political subdivisions, or local authorities to an individual for services performed for the pay-ing governmental body is exempt from U.S. in-come tax. However, the exemption does not apply if the services are performed in the United States by a U.S. resident who either:

Is a U.S. national, orDid not become a resident of the United States solely for purposes of performing the services.

Pensions paid by Mexico, its political subdi-visions, or local authorities for services per-formed for the paying governmental body are exempt from U.S. income tax unless the individ-ual is both a resident and national of the United States.

These exemptions do not apply to income or pensions connected with commercial or indus-trial activities carried on by Mexico, its political subdivisions, or local authorities.

MoroccoWages, salaries, and similar income, including pensions and similar benefits, paid from public funds of the Kingdom of Morocco to a citizen of Morocco (other than a U.S. citizen or an individ-ual admitted to the United States for permanent residence) for labor or personal services per-formed for Morocco or for any of its political subdivisions or local authorities in the discharge of governmental functions are exempt from U.S. income tax.

NetherlandsIncome, other than a pension, paid by the Neth-erlands, its political subdivisions, or local au-thorities to an individual for services performed for the paying governmental body is exempt from U.S. income tax. However, the exemption does not apply if the services are rendered in the United States and the individual is a U.S. resident who either:

Is a U.S. national, orDid not become a U.S. resident solely for the purpose of performing the services.

Pensions paid by the Netherlands for serv-ices performed for the Netherlands are exempt from U.S. income tax unless the individual is both a resident and national of the United States.

These exemptions do not apply to income or pensions for services performed in connection with a business carried on by the Netherlands, its political subdivisions, or local authorities.

New ZealandIncome (other than pensions) paid by the Gov-ernment of New Zealand, its political subdivi-sions, or local authorities for services performed

in the discharge of governmental functions is exempt from U.S. income tax. However, the in-come is not exempt if the services are per-formed in the United States by a U.S. citizen resident in the United States or by a resident of the United States who did not become a resi-dent only to perform the services.

Pensions paid by New Zealand in consider-ation for past governmental services are ex-empt from U.S. income tax unless paid to U.S. citizens resident in the United States.

These exemptions do not apply to payments for services performed in connection with a business carried on by New Zealand, its politi-cal subdivisions, or local authorities.

NorwayWages, salaries, and similar income, including pensions and similar benefits paid by or from public funds of Norway or its political subdivi-sions or local authorities to a citizen of Norway for labor or personal services performed for Norway or any of its political subdivisions or lo-cal authorities in the discharge of governmental functions are exempt from U.S. income tax.

PakistanIncome, including pensions and annuities, paid to certain individuals by or on behalf of the Gov-ernment of Pakistan or the Government of a Province in Pakistan or one of its local authori-ties for services performed in the discharge of functions of that Government or local authority is exempt from U.S. income tax. To be exempt from tax, these payments must be made to citi-zens of Pakistan who do not have immigrant status in the United States. This exemption does not apply to payments for services per-formed in connection with any trade or business carried on for profit.

PhilippinesWages, salaries, and similar income, including pensions, annuities, and similar benefits, paid from public funds of the Republic of the Philip-pines to a citizen of the Philippines (or to a citi-zen of another country other than the United States who comes to the United States specifi-cally to work for the Government of the Philip-pines) for labor or personal services performed as an employee of the national Government of the Philippines or any of its agencies in the dis-charge of governmental functions are exempt from U.S. income tax.

PolandWages, salaries, and similar income, including pensions, annuities, and similar benefits, paid from public funds of Poland to a citizen of Po-land (other than a U.S. citizen or one admitted to the United States for permanent residence) for labor or personal services performed as an employee of the national Government of Poland in the discharge of governmental functions are exempt from U.S. income tax.

Page 31 of 61 Fileid: … ons/P901/201304/A/XML/Cycle02/source 10:02 - 11-Mar-2013The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

Publication 901 (April 2013) Page 31

Page 32: Treaties U.S. TaxTurkmenistan, and Uzbekistan. That treaty will remain in effect until new treaties with these in-dividual countries are negotiated and ratified. Provisions of the

PortugalIncome, other than a pension, paid by Portugal, its political or administrative subdivisions, or lo-cal authorities to an individual for services per-formed for the paying governmental body is ex-empt from U.S. income tax. However, the exemption does not apply to payments for serv-ices performed in the United States by a U.S. resident who either:

Is a U.S. national, orDid not become a U.S. resident only to perform the services.

Pensions paid by Portugal for services per-formed for Portugal are exempt from U.S. in-come tax unless the recipient is a resident and national of the United States.

These exemptions do not apply to income or pensions for services performed in connection with a business carried on by Portugal or its po-litical or administrative subdivisions, or local au-thorities.

RomaniaWages, salaries, and similar income, including pensions, annuities, and similar benefits, paid from public funds of Romania to a citizen of Ro-mania (other than a U.S. citizen or one admitted to the United States for permanent residence) for labor or personal services performed as an employee of the national Government of Roma-nia in the discharge of governmental functions are exempt from U.S. income tax.

RussiaIncome, other than a pension, paid by Russia, its republics, or local authorities to an individual for government services is exempt from U.S. tax. However, the exemption does not apply if the services are performed in the United States by a U.S. resident who either:

Is a U.S. citizen, orDid not become a U.S. resident solely for the purpose of performing the services.

Pensions paid by Russia, its republics, or lo-cal authorities for services performed for Russia are exempt from U.S. tax unless the individual is both a resident and citizen of the United States.

These exemptions do not apply to income or pensions for services performed in connection with a business.

Slovak RepublicIncome, including a pension, paid from the pub-lic funds of the Slovak Republic, its political subdivisions, or local authorities to a Slovak citi-zen for services performed in the discharge of governmental functions is exempt from U.S. in-come tax. This exemption does not apply to in-come paid for services performed in connection with a business carried on by the Slovak Re-public, its political subdivisions, or local authori-ties.

SloveniaIncome, other than a pension, paid from public funds of Slovenia, its political subdivisions, or local authorities to an individual for services performed for the paying governmental body in the discharge of governmental functions is ex-empt from U.S. income tax. However, the ex-emption does not apply if the services are per-formed in the United States by a resident of the United States who either:

Is a U.S. citizen, orDid not become a U.S. resident only to perform the services.

Pensions paid from the public funds of Slov-enia, its political subdivisions, or local authori-ties for services performed for Slovenia in the discharge of governmental functions are ex-empt from U.S. income tax unless the recipient is both a resident and citizen of the United States.

South AfricaIncome, other than a pension, paid by South Af-rica or its political subdivisions or local authori-ties to an individual for services performed for the paying governmental body is exempt from U.S. income tax. However, the exemption does not apply to payments for services performed in the United States by a resident of the United States who either:

Is a U.S. citizen, orDid not become a U.S. resident only to perform the services.

Pensions paid by South Africa for services performed for South Africa are exempt from U.S. income tax unless the recipient is both a resident and citizen of the United States.

These exemptions do not apply to income or pensions for services performed in connection with a business carried on by South Africa or its subdivisions or local authorities.

SpainIncome, other than a pension, paid by Spain, its political subdivisions, or local authorities to an individual for services performed for the paying governmental body is exempt from U.S. income tax. However, the exemption does not apply to payments for services performed in the United States by a resident of the United States who either:

Is a U.S. citizen, orDid not become a U.S. resident only to perform the services.

Pensions paid by Spain, its political subdivi-sions, or local authorities for services performed for Spain are exempt from U.S. tax unless the individual is both a citizen and resident of the United States.

These exemptions do not apply to income or pensions for services performed in connection with a trade or business carried on by Spain, its subdivisions, or local authorities.

Sri LankaIncome, including a pension, paid from the pub-lic funds of Sri Lanka, its political subdivisions, or local authorities to a citizen or national of Sri Lanka for services performed for Sri Lanka in the discharge of functions of a governmental nature is exempt from U.S. income tax. This ex-emption does not apply to income paid for serv-ices performed in connection with a business carried on by Sri Lanka, its political subdivi-sions, or local authorities.

SwedenIncome, other than a pension, paid by Sweden, its political subdivisions, or local authorities to an individual for services performed for the pay-ing governmental body is exempt from U.S. in-come tax. However, the exemption does not apply if the services are performed in the United States by a U.S. resident who either:

Is a U.S. citizen, orDid not become a U.S. resident solely for the purpose of performing the services.

Pensions paid by Sweden, its political subdi-visions, or local authorities for services per-formed for Sweden are exempt from U.S. tax unless the individual is both a resident and citi-zen of the United States.

These exemptions do not apply to income or pensions for services performed in connection with a business carried on by Sweden, its politi-cal subdivisions, or local authorities.

SwitzerlandIncome, other than a pension, paid by Switzer-land or its political subdivisions or local authori-ties to an individual for services performed for the paying governmental body is exempt from U.S. income tax. However, the exemption does not apply to payments for services performed in the United States by a resident of the United States who either:

Is a U.S. citizen, orDid not become a U.S. resident only to perform the services.

Pensions paid by Switzerland for services performed for Switzerland are exempt from U.S. income tax unless the recipient is both a resi-dent and citizen of the United States.

These exemptions do not apply to income or pensions for services performed in connection with a business carried on by Switzerland or its subdivisions or local authorities.

ThailandIncome, other than a pension, paid by Thailand or its political subdivisions or local authorities to an individual for services performed for the pay-ing governmental body is exempt from U.S. in-come tax. However, the exemption does not apply to payments for services performed in the United States by a resident of the United States who either:

Is a U.S. citizen, or

Page 32 of 61 Fileid: … ons/P901/201304/A/XML/Cycle02/source 10:02 - 11-Mar-2013The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

Page 32 Publication 901 (April 2013)

Page 33: Treaties U.S. TaxTurkmenistan, and Uzbekistan. That treaty will remain in effect until new treaties with these in-dividual countries are negotiated and ratified. Provisions of the

Did not become a U.S. resident only to perform the services.

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

These exemptions do not apply to income or pensions for services performed in connection with a business carried on by Thailand or its subdivisions or local authorities.

Trinidad and TobagoWages, salaries, and similar income and pen-sions, annuities, and similar benefits paid by or from the public funds of the Government of Tri-nidad and Tobago to a national of that country for services performed for Trinidad and Tobago in the discharge of governmental functions are exempt from U.S. tax.

TunisiaIncome, other than a pension, paid by Tunisia, its political subdivisions, or local authorities to a Tunisian citizen for personal services per-formed in the discharge of governmental func-tions is exempt from U.S. income tax.

Pensions paid by Tunisia, its political subdi-visions, or local authorities for services per-formed for Tunisia are exempt from U.S. in-come tax unless the recipient is a U.S. citizen.

These exemptions do not apply to income or pensions for services performed in connection with a trade or business carried on by Tunisia, its political subdivisions, or local authorities.

TurkeyIncome, other than a pension, paid by Turkey or its political subdivisions or local authorities to an individual for services performed for the paying governmental body is exempt from U.S. income tax. However, the exemption does not apply to payments for services performed in the United States by a resident of the United States who either:

Is a U.S. citizen, orDid not become a U.S. resident only to perform the services.

Pensions paid by Turkey for services per-formed for Turkey are exempt from U.S. income tax unless the recipient is both a resident and citizen of the United States.

These exemptions do not apply to income or pensions for services performed in connection with a business carried on by Turkey or its sub-divisions or local authorities.

UkraineIncome, other than a pension, paid from public funds of Ukraine, its political subdivisions, or lo-cal authorities to an individual for services per-formed in the discharge of governmental func-tions is exempt from U.S. income tax. However, the exemption does not apply if the services are

performed in the United States by a resident of the United States who either:

Is a U.S. citizen, orDid not become a U.S. resident only to perform the services.

Pensions paid by, or by funds created by, Ukraine, its political subdivisions, or local au-thorities for services performed for Ukraine are exempt from U.S. income tax unless the recipi-ent is both a resident and citizen of the United States.

These exemptions do not apply to income or pensions for services performed in connection with a trade or business carried on by Ukraine, its political subdivisions, or local authorities.

United KingdomIncome, other than a pension, paid from the public funds of the United Kingdom, its political subdivisions, or local authorities to an individual for services performed for the paying govern-mental body is exempt from U.S. income tax. However, the exemption does not apply if the services are performed in the United States by a resident of the United States who either:

Is a U.S. citizen, orDid not become a U.S. resident only to perform the services.

Pensions paid by, or funds created by, the United Kingdom, its political subdivisions, or lo-cal authorities for services performed for the United Kingdom are exempt from U.S. income tax unless the recipient is both a resident and citizen of the United States.

These exemptions do not apply to income or pensions for services performed in connection with a business carried on by the United King-dom, its political subdivisions, or local authori-ties.

VenezuelaIncome, other than a pension, paid by Vene-zuela, its political subdivisions, or local authori-ties to an individual for services performed for the paying governmental body is exempt from U.S. income tax. However, the exemption does not apply to payments for services performed in the United States by a resident of the United States who either:

Is a U.S. citizen, orDid not become a U.S. resident only to perform the services.

Pensions paid by Venezuela, its political subdivisions, or local authorities for services performed for Venezuela are exempt from U.S. income tax unless the recipient is both a resi-dent and citizen of the United States.

These exemptions do not apply to payments or pensions for services performed in connec-tion with a business carried on by Venezuela, its political subdivisions, or local authorities.

Explanationof TablesThe paragraphs below describe the tables that follow and provide additional information that may make the tables more useful to you.

These tables are not meant to be a complete guide to all provisions of ev­ery income tax treaty. For detailed in­

formation, you must consult the provisions of the tax treaty that apply.

Table 1This table lists the income tax rates on such in-come as interest, dividends, and royalties. The income code numbers shown in this table are the same as the income codes on Form 1042-S, Foreign Person's U.S. Source Income Subject to Withholding.

Interest. If you are a nonresident alien who re-ceives interest that is not effectively connected with the conduct of a U.S. trade or business, you do not include the interest in income if it is paid on deposits with banks, on accounts or de-posits with certain financial institutions, or on certain amounts held by insurance companies. These amounts are exempt from U.S. tax even though they are considered to be income from a U.S. source. Also exempt from U.S. tax (al-though considered from U.S. sources) is certain portfolio interest on obligations issued after July 18, 1984. See Publication 519 for more informa-tion.

Table 2This table lists the different kinds of personal service income that may be fully or partly ex-empt from U.S. income tax. You must meet all of the treaty requirements before the item of in-come can be exempt from U.S. income tax. The income code numbers shown in this table are the same as the income codes on Form 1042-S, Foreign Person's U.S. Source Income Subject to Withholding.

Independent personal services. The term “independent personal services” generally means services you perform for your own ac-count if you receive the income and bear the losses arising from those services. Examples of these services are those provided by physi-cians, lawyers, engineers, dentists, and ac-countants who perform personal services as sole proprietors or partners.

Dependent personal services. Dependent personal services usually are those you perform for someone else as an employee.

Table 3This table lists the countries that have tax trea-ties with the United States. Some treaties are published in the Cumulative Bulletins (C.B.), which contain official matters of the Internal Revenue Service. The column headed Citation

CAUTION!

Page 33 of 61 Fileid: … ons/P901/201304/A/XML/Cycle02/source 10:02 - 11-Mar-2013The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

Publication 901 (April 2013) Page 33

Page 34: Treaties U.S. TaxTurkmenistan, and Uzbekistan. That treaty will remain in effect until new treaties with these in-dividual countries are negotiated and ratified. Provisions of the

shows the number of the C.B. and the page on which a particular treaty may be found.

Regulations implementing some treaties were issued as Treasury Decisions (T.D.). Other treaties are explained by Treasury ex-planation. The fifth column lists the T.D. num-bers and the C.B. in which each T.D. or Treas-ury explanation is printed.

You can buy volumes of the C.B. from the Government Printing Office or you are welcome to read them in most Internal Revenue Service offices. Many public libraries and business or-ganizations subscribe to a commercial tax serv-ice that publishes the treaties and regulations or explanations.

Page 34 of 61 Fileid: … ons/P901/201304/A/XML/Cycle02/source 10:02 - 11-Mar-2013The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

Page 34 Publication 901 (April 2013)

Page 35: Treaties U.S. TaxTurkmenistan, and Uzbekistan. That treaty will remain in effect until new treaties with these in-dividual countries are negotiated and ratified. Provisions of the

Table 1.Tax Rates on Income Other Than Personal Service Income Under Chapter 3, Internal Revenue Code, and Income Tax Treaties▶Taxpayers must meet the limitation on benefits provisions in the treaty, if any, to qualify for reduced withholding rates.▶In most cases, the Business Profits article, rather than a reduced withholding tax rate, applies if the income is attributable to a permanent establishment of the taxpayer in the United States.

Income Code Number 1 6 7 14 21Interest Dividends

Name Code

Paid by U.S. Obligors

— General

Paid by U.S. Corporations

—GeneralaQualifying for

Direct Dividend Ratea, b

Pensions and Annuities d

Social Security

Paymentsqq

Australia . . . . . . . . . . . . . . . . . . . AS 10 g,k,nn 15 mm  5 mm,oo  0 30Austria . . . . . . . . . . . . . . . . . . . . AU  0 g,jj 15 w  5 w  0 30Bangladesh . . . . . . . . . . . . . . . . BG 10 g,bb,jj 15 mm 10 mm  0 f,q 30

Barbados . . . . . . . . . . . . . . . . . . BB  5 15 w  5 w  0 f 30Belgium . . . . . . . . . . . . . . . . . . . BE  0 g,jj 15 dd,mm  5 dd,mm,oo  0 f 30Bulgaria . . . . . . . . . . . . . . . . . . . BU  5 g,dd,jj,nn 10 dd,mm  5 dd,mm  0 f 30Canada . . . . . . . . . . . . . . . . . . . . CA  0 g,jj 15 mm  5 mm 15 0China, People's Rep. of . . . . . . . CH 10 10 10  0 t 30Comm. of Independent States* . . . . . . . . .  0 n 30 30 30 30Cyprus . . . . . . . . . . . . . . . . . . . . CY 10 nn 15  5  0 f 30Czech Republic . . . . . . . . . . . . . EZ  0 g 15 w  5 w  0 f 30Denmark . . . . . . . . . . . . . . . . . . . DA  0 g,kk 15 dd,mm  5 dd,mm,oo 30 c,t 30Egypt . . . . . . . . . . . . . . . . . . . . . EG 15 15  5  0 f 0Estonia . . . . . . . . . . . . . . . . . . . . EN 10 g,kk 15 w  5 w  0 f 30Finland . . . . . . . . . . . . . . . . . . . . FI  0 g,kk 15 dd,mm  5 dd,mm,oo  0 f 30France . . . . . . . . . . . . . . . . . . . . FR  0 g,k 15 mm  5 mm,oo 30 t 30Germany . . . . . . . . . . . . . . . . . . GM  0 g,jj 15 dd,mm  5 dd,mm,oo  0 f 0Greece . . . . . . . . . . . . . . . . . . . . GR  0 r 30 30  0 30Hungary . . . . . . . . . . . . . . . . . . . HU  0 15  5  0 t 30Iceland . . . . . . . . . . . . . . . . . . . . IC  0 g,kk 15 dd,mm  5 dd,mm  0 30India . . . . . . . . . . . . . . . . . . . . . . IN 15 z 25 w 15 w  0 f 30Indonesia . . . . . . . . . . . . . . . . . . ID 10 15 10 15 q 30Ireland . . . . . . . . . . . . . . . . . . . . EI  0 g,k 15 mm  5 mm  0 f 0Israel . . . . . . . . . . . . . . . . . . . . . . IS 171 2 z 25 w 121 2 w  0 f 0Italy . . . . . . . . . . . . . . . . . . . . . . IT 10 g,h 15 mm  5 mm  0 f 0Jamaica . . . . . . . . . . . . . . . . . . . JM 121 2 15 10  0 f,p 30Japan . . . . . . . . . . . . . . . . . . . . . JA 10 e,g,dd,ee 10 dd,ee,mm  5 dd,ee,mm,oo  0 0Kazakhstan . . . . . . . . . . . . . . . . KZ 10 g 15 ff  5 ff  0 f 30Korea, South . . . . . . . . . . . . . . . KS 12 15 10  0 f 30Latvia . . . . . . . . . . . . . . . . . . . . . LG 10 g,kk 15 w  5 w  0 f 30

 * Those countries to which the U.S.-U.S.S.R. income tax treaty still applies: Armenia, Azerbaijan, Belarus, Georgia, Kyrgyzstan, Moldova, Tajikistan, Turkmenistan, and Uzbekistan.

Page 35 of 61 Fileid: … ons/P901/201304/A/XML/Cycle02/source 10:02 - 11-Mar-2013The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

Publication 901 (April 2013) Page 35

Page 36: Treaties U.S. TaxTurkmenistan, and Uzbekistan. That treaty will remain in effect until new treaties with these in-dividual countries are negotiated and ratified. Provisions of the

Table 1.Tax Rates on Income Other Than Personal Service Income Under Chapter 3, Internal Revenue Code, and Income Tax Treaties▶Taxpayers must meet the limitation on benefits provisions in the treaty, if any, to qualify for reduced withholding rates.▶In most cases, the Business Profits article, rather than a reduced withholding tax rate, applies if the income is attributable to a permanent establishment of the taxpayer in the United States.

Income Code Number 10 11 12 Royalties

Name CodeIndustrial Equipment

Know-How/ Other Industrial

Royalties Patents Film & TV CopyrightsAustralia . . . . . . . . . . . . . . . . . AS 30 u  5  5  5  5 Austria . . . . . . . . . . . . . . . . . . . AU 30 u  0  0 10 0 Bangladesh . . . . . . . . . . . . . . . BG 30 u 10 10 10 10 Barbados . . . . . . . . . . . . . . . . . BB 30 u  5  5  5  5 Belgium . . . . . . . . . . . . . . . . . BE 30 u  0  0  0  0 Bulgaria . . . . . . . . . . . . . . . . . BU 30 u  5  5  5  5 Canada . . . . . . . . . . . . . . . . . . CA 30 u  0  0 10 0 China, People's Rep. of . . . . . CH 10 v 10 10 10 10 Comm. of Independent States . . . . . . . .  0  0  0  0  0Cyprus . . . . . . . . . . . . . . . . . . . CY 30 u  0  0  0  0 Czech Republic . . . . . . . . . . . . EZ 10 10 10  0  0 Denmark . . . . . . . . . . . . . . . . . DA 30 u  0  0  0  0 Egypt . . . . . . . . . . . . . . . . . . . . EG 30 u 30 u 15  0 15 Estonia . . . . . . . . . . . . . . . . . . EN  5 10 10 10 10 Finland . . . . . . . . . . . . . . . . . . . FI 30 u  0  0  0  0 France . . . . . . . . . . . . . . . . . . . FR 30 u  0  0  0  0 Germany . . . . . . . . . . . . . . . . . GM 30 u  0  0  0 0 Greece . . . . . . . . . . . . . . . . . . . GR  0  0  0 30 u 0 Hungary . . . . . . . . . . . . . . . . . . HU 30 u  0  0  0  0 Iceland . . . . . . . . . . . . . . . . . . . IC 30 u  5  0  5  0 India . . . . . . . . . . . . . . . . . . . . . IN 10 15 15 15 15 Indonesia . . . . . . . . . . . . . . . . . ID 10 10 10 10 10 Ireland . . . . . . . . . . . . . . . . . . . EI 30 u  0  0  0  0 Israel . . . . . . . . . . . . . . . . . . . . IS 30 u 15 u 15 10 10Italy . . . . . . . . . . . . . . . . . . . . . IT  5  8  8  8  0 Jamaica . . . . . . . . . . . . . . . . . . JM 30 u 10 10 10 10 Japan . . . . . . . . . . . . . . . . . . . . JA 30 u  0 ee  0 ee  0 ee  0 eeKazakhstan . . . . . . . . . . . . . . . KZ 10 10 10 10 10 Korea, South . . . . . . . . . . . . . . KS 30 u 15 15 10 10 Latvia . . . . . . . . . . . . . . . . . . . . LG  5 10 10 10 10

Page 36 of 61 Fileid: … ons/P901/201304/A/XML/Cycle02/source 10:02 - 11-Mar-2013The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

Page 36 Publication 901 (April 2013)

Page 37: Treaties U.S. TaxTurkmenistan, and Uzbekistan. That treaty will remain in effect until new treaties with these in-dividual countries are negotiated and ratified. Provisions of the

Table 1.Tax Rates on Income Other Than Personal Service Income Under Chapter 3, Internal Revenue Code, and Income Tax Treaties▶Taxpayers must meet the limitation on benefits provisions in the treaty, if any, to qualify for reduced withholding rates.▶In most cases, the Business Profits article, rather than a reduced withholding tax rate, applies if the income is attributable to a permanent establishment of the taxpayer in the United States.

Income Code Number 1 6 7 14 21Interest Dividends

Name Code

Paid by U.S. Obligors

— General

Paid by U.S. Corporations

—GeneralaQualifying for

Direct Dividend Ratea,b

Pensions and Annuities

Social Security

Paymentsqq

Lithuania . . . . . . . . . . . . . . . . . . . . . . . . . LH 10 g,kk 15 w  5 w  0 f 30Luxembourg . . . . . . . . . . . . . . . . . . . . . . LU  0 g,k 15 w  5 w  0 30Malta . . . . . . . . . . . . . . . . . . . . . . . . . . . . MT 10 g,jj 15 dd,mm 5 dd,mm  0 f 30Mexico . . . . . . . . . . . . . . . . . . . . . . . . . . . MX 15 g,dd,ee,hh 10 dd,mm  5 dd,mm,oo  0 30Morocco . . . . . . . . . . . . . . . . . . . . . . . . . . MO 15 15 10  0 f 30Netherlands . . . . . . . . . . . . . . . . . . . . . . . NL  0 g 15 pp  5 gg,oo,pp  0 f,pp 30New Zealand . . . . . . . . . . . . . . . . . . . . . . NZ 10 g,jj,nn 15 mm  5 mm,oo  0 30Norway . . . . . . . . . . . . . . . . . . . . . . . . . . NO 10 z 15 15  0 f 30Pakistan . . . . . . . . . . . . . . . . . . . . . . . . . . PK 30 30 15  0 j 30Philippines . . . . . . . . . . . . . . . . . . . . . . . . RP 15 25 20 30 q 30Poland . . . . . . . . . . . . . . . . . . . . . . . . . . . PL  0 15  5 30 30Portugal . . . . . . . . . . . . . . . . . . . . . . . . . . PO 10 g,k 15 w  5 w  0 f 30Romania . . . . . . . . . . . . . . . . . . . . . . . . . RO 10 10 10  0 f 0Russia . . . . . . . . . . . . . . . . . . . . . . . . . . . RS  0 g 10 ff  5 ff  0 t 30Slovak Republic . . . . . . . . . . . . . . . . . . . LO  0 g 15 w  5 w  0 f 30Slovenia . . . . . . . . . . . . . . . . . . . . . . . . . . SI  5 g 15 mm  5 mm  0 f 30South Africa . . . . . . . . . . . . . . . . . . . . . . . SF  0 g,jj 15 w  5 w 15 l 30Spain . . . . . . . . . . . . . . . . . . . . . . . . . . . . SP 10 15 w 10 w  0 f 30Sri Lanka . . . . . . . . . . . . . . . . . . . . . . . . . CE 10 g,jj 15 gg 15 gg  0 t 30Sweden . . . . . . . . . . . . . . . . . . . . . . . . . . SW  0 g 15 dd,mm  5 dd,mm,oo  0 30Switzerland . . . . . . . . . . . . . . . . . . . . . . . SZ  0 g,jj 15 w  5 w  0 15Thailand . . . . . . . . . . . . . . . . . . . . . . . . . . TH 15 g,z 15 w 10 w  0 f 30Trinidad & Tobago . . . . . . . . . . . . . . . . . TD 30 30 30  0 f 30Tunisia . . . . . . . . . . . . . . . . . . . . . . . . . . . TS 15 20 w 14 w  0 f 30Turkey . . . . . . . . . . . . . . . . . . . . . . . . . . . TU 15 g, m,z 20 w 15 w  0 30Ukraine . . . . . . . . . . . . . . . . . . . . . . . . . . UP  0 g 15 ff  5 ff  0 30United Kingdom . . . . . . . . . . . . . . . . . . . UK  0 g,ee,kk 15 ee,mm  5 ee,mm,oo  0 f 0Venezuela . . . . . . . . . . . . . . . . . . . . . . . . VE 10 g,kk,ll 15 mm  5 mm  0 t 30Other Countries . . . . . . . . . . . . . . . . . . . . 30 30 30 30 30

Page 37 of 61 Fileid: … ons/P901/201304/A/XML/Cycle02/source 10:02 - 11-Mar-2013The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

Publication 901 (April 2013) Page 37

Page 38: Treaties U.S. TaxTurkmenistan, and Uzbekistan. That treaty will remain in effect until new treaties with these in-dividual countries are negotiated and ratified. Provisions of the

Table 1.Tax Rates on Income Other Than Personal Service Income Under Chapter 3, Internal Revenue Code, and Income Tax Treaties▶Taxpayers must meet the limitation on benefits provisions in the treaty, if any, to qualify for reduced withholding rates.▶In most cases, the Business Profits article, rather than a reduced withholding tax rate, applies if the income is attributable to a permanent establishment of the taxpayer in the United States.

Income Code Number 10 11 12 Royalties

Name CodeIndustrial Equipment

Know-how/ Other Industrial Royalties Patents Film & TV Copyrights

Lithuania . . . . . . . . . . . . . LH  5 10 10 10 10 Luxembourg . . . . . . . . . . LU 30 u  0  0  0  0 Malta . . . . . . . . . . . . . . . . MT 30 u 10 10 10 10 Mexico . . . . . . . . . . . . . . . MX 10 10 10 10 10 Morocco . . . . . . . . . . . . . . MO 30 u 10 10 10 10 Netherlands . . . . . . . . . . . NL 30 u  0  0  0  0 New Zealand . . . . . . . . . . NZ 30 u  5  5  5  5 Norway . . . . . . . . . . . . . . NO 30 u  0  0  0  0 Pakistan . . . . . . . . . . . . . . PK 30 u  0  0 30 u  0 Philippines . . . . . . . . . . . . RP 30 u 15 15 15 15 Poland . . . . . . . . . . . . . . . PL 30 u 10 10 10 10 Portugal . . . . . . . . . . . . . . PO 10 10 10 10 10 Romania . . . . . . . . . . . . . RO 30 u 15 15 10 10 Russia . . . . . . . . . . . . . . . RS 30 u  0  0  0  0 Slovak Republic . . . . . . . LO 10 10 10  0  0 Slovenia . . . . . . . . . . . . . . SI 30 u  5  5  5  5 South Africa . . . . . . . . . . . SF 30 u  0  0  0  0 Spain . . . . . . . . . . . . . . . . SP  8 10 10  8  5 aaSri Lanka . . . . . . . . . . . . . CE 30 u,y 10 10 10 10 Sweden . . . . . . . . . . . . . . SW 30 u  0  0  0  0 Switzerland . . . . . . . . . . . SZ 30 u  0  0 30 u  0 Thailand . . . . . . . . . . . . . . TH  8 15 15  5  5 Trinidad & Tobago . . . . . . TD 30 u 15 15 30 u  0 ccTunisia . . . . . . . . . . . . . . . TS 10 15 15 15 15 Turkey . . . . . . . . . . . . . . . TU  5 10 10 10 10 Ukraine . . . . . . . . . . . . . . UP 30 u 10 10 10 10 United Kingdom . . . . . . . . UK 30 u  0 ee  0 ee  0 ee  0 eeVenezuela . . . . . . . . . . . . VE  5 10 10 10 10 Other Countries . . . . . . . . 30 30 30 30 30

a No U.S. tax is imposed on a percentage of any dividend paid by a U.S. corporation in existence on January 1, 2011, that received at least 80% of its gross income from an active foreign business for the 3-year period before the dividend is declared. (See sections 871(i)(2)(B) and 881(d) of the Internal Revenue Code.)

b The reduced rate applies to dividends paid by a subsidiary to a foreign parent corporation that has the required percentage of stock ownership. In some cases, the income of the subsidiary must meet certain requirements (e.g., a certain percentage of its total income must consist of income other than dividends and interest).

c In most cases, if the person was receiving pension distributions before March 31, 2000, the distributions continue to be exempt from U.S. tax. d In most cases, this rate applies only to pensions not paid by a government. See specific treaty rules for government pensions.e Interest is exempt if (a) paid to certain financial institutions or (b) paid on indebtedness from the sale on credit of equipment or merchandise.f Includes alimony.g Exemption or reduced rate does not apply to an excess inclusion for a residual interest in a real estate mortgage investment conduit (REMIC).h Interest paid or accrued on the sale of goods, merchandise, or services between enterprises is exempt. Interest paid or accrued on the sale on credit of

industrial, commercial, or scientific property is exempt.i The rate is 5% for trademarks and any information for rentals of industrial, commercial, or scientific equipment.

Page 38 of 61 Fileid: … ons/P901/201304/A/XML/Cycle02/source 10:02 - 11-Mar-2013The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

Page 38 Publication 901 (April 2013)

Page 39: Treaties U.S. TaxTurkmenistan, and Uzbekistan. That treaty will remain in effect until new treaties with these in-dividual countries are negotiated and ratified. Provisions of the

j Exemption is not available when paid from a fund under an employees' pension or annuity plan, if contributions to it are deductible under U.S. tax laws in determining taxable income of the employer.

k The rate is 15% for interest determined with reference to the profits of the issuer or one of its associated enterprises.l Annuities purchased while the annuitant was not a resident of the United States are not taxable. The reduced rate applies if the distribution is not subject

to a penalty for early withdrawal.m Contingent interest that does not qualify as portfolio interest is treated as a dividend and is subject to the rate under column 6 or 7. n The exemption applies only to interest on credits, loans, and other indebtedness connected with the financing of trade between the United States and

the C.I.S. member. It does not include interest from the conduct of a general banking business.o The exemption applies only to gains from the sale or other disposition of property acquired by gift or inheritance.p The exemption does not apply if the applicable past employment was performed in the United states while such person was a resident of the United

States, or if the annuity was purchased in the United States while such person was a resident of the United States.q Annuities paid in return for other than the recipient's services are exempt. For Bangladesh, exemption does not apply to annuity received for services

rendered.r Exemption does not apply to such interest paid by a U.S. corporation to a Greek corporation controlling, directly or indirectly, more than 50 percent of

the entire voting power in the paying corporation.s The rate for royalties with respect to tangible personal property is 7%. t Does not apply to annuities. For Denmark, annuities are exempt.u Depending on the facts, the rate may be determined by either the Business Profits article or the Other Income article. v Tax imposed on 70% of gross royalties for rentals of industrial, commercial, or scientific equipment.w The rate in column 6 applies to dividends paid by a regulated investment company (RIC) or a real estate investment trust (REIT). However, that rate

applies to dividends paid by a REIT only if the beneficial owner of the dividends is an individual holding less than a 10% interest (25% in the case of Portugal, Spain, Thailand, and Tunisia) in the REIT.

x Royalties not taxed at the 5% or 8% rate are taxed at a 10% rate, unless the royalty is attributable to a permanent establishment of the taxpayer in the United States.

y The rate is 5% for the rental of tangible personal property.z The rate is 10% if the interest is paid on a loan granted by a bank or similar financial institution. For Norway, the interest described in the preceding

sentences is exempt. For Thailand, the 10% rate also applies to interest from an arm's length sale on credit of equipment, merchandise, or services. aa The rate is 8% for copyrights of scientific work.bb The rate is 5% for interest (a) beneficially owned by a bank or other financial institution (including an insurance company) or (b) paid due to a sale on

credit of any industrial, commercial, or scientific equipment, or of any merchandise to an enterprise.cc The rate is 15% for copyrights of scientific work.dd Amounts paid to a pension fund that are not derived from the carrying on of a business, directly or indirectly, by the fund are exempt. This includes

dividends paid by a REIT only if the conditions in footnote mm are met. For Sweden, to be entitled to the exemption, the pension fund must not sell or make a contract to sell the holding from which the dividend is derived within 2 months of the date the pension fund acquired the holding.

ee Exemption or reduced rate does not apply to amount paid under, or as part of, a conduit arrangement.ff The rate in column 6 applies to dividends paid by a regulated investment company (RIC). Dividends paid by a real estate investment trust (REIT) are

subject to a 30% rate.gg The rate applies to dividends paid by a real estate investment trust (REIT) only if the beneficial owner of the dividends is (a) an individual holding less

than a 10% interest in the REIT, (b) a person holding not more than 5% of any class of the REIT's stock and the dividends are paid on stock that is publicly traded, or (c) a person holding not more than a 10% interest in the REIT and the REIT is diversified.

hh The rate is 4.9% for interest derived from (1) loans granted by banks and insurance companies and (2) bonds or securities that are regularly and substantially traded on a recognized securities market. The rate is 10% for interest not described in the preceding sentence and paid (i) by banks or (ii) by the buyer of machinery and equipment to the seller due to a sale on credit.

ii 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 the United States, and (3) the amount is not a periodic payment, or is a lump-sum payment in lieu of a right to receive an annuity.

jj The rate is 15% (10% for Bulgaria; 30% for Austria, Germany and Switzerland) for contingent interest that does not qualify as portfolio interest. In most cases, this is interest based on receipts, sales, income, or changes in the value of property.

kk The rate is 15% for interest determined with reference to (a) receipts, sales, income, profits or other cash flow of the debtor or a related person, (b) any change in the value of any property of the debtor or a related person, or (c) any dividend, partnership distribution, or similar payment made by the debtor or related person.

ll The rate is 4.95% if the interest is beneficially owned by a financial institution (including an insurance company).

Page 39 of 61 Fileid: … ons/P901/201304/A/XML/Cycle02/source 10:02 - 11-Mar-2013The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

Publication 901 (April 2013) Page 39

Page 40: Treaties U.S. TaxTurkmenistan, and Uzbekistan. That treaty will remain in effect until new treaties with these in-dividual countries are negotiated and ratified. Provisions of the

mm The rate in column 6 applies to dividends paid by a regulated investment company (RIC) or real estate investment trust (REIT). However, that rate applies to dividends paid by a REIT only if the beneficial owner of the dividends is (a) an individual (or pension fund, in some cases) holding not more than a 10% interest in the REIT, (b) a person holding not more than 5% of any class of the REIT's stock and the dividends are paid on stock that is publicly traded, or (c) a person holding not more than a 10% interest in the REIT and the REIT is diversified.

nn Interest received by a financial institution is exempt. In some cases, the exemption does not apply if the interest is paid as part of an arrangement involving back-to-back loans or other arrangement that is economically equivalent and intended to have a similar effect to back-to-back loans.

oo Dividends received from an 80%-owned corporate subsidiary are exempt if certain conditions are met. For Japan, dividends received from a more than 50% owned corporate subsidiary are exempt if certain conditions are met.

pp The rate in column 6 applies to dividends paid by a regulated investment company (RIC) or real estate investment trust (REIT). However, that rate applies to dividends paid by a REIT only if the beneficial owner of the dividends is (a) an individual holding not more than a 25% interest in the REIT, (b) a person holding not more than 5% of any class of the REIT's stock and the dividends are paid on stock that is publicly traded, or (c) a person holding not more than a 10% interest in the REIT and the REIT is diversified, or (d) a Dutch belegginginstelling.

qq Applies to 85% of the social security payments received from the U.S. Government. The effective rate on the total social security payments received is 85% of the rate shown in the table. These rates also apply to the social security equivalent portion 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 (income code 23) are taxed as shown in column 14, “Pensions and Annuities.”

Page 40 of 61 Fileid: … ons/P901/201304/A/XML/Cycle02/source 10:02 - 11-Mar-2013The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

Page 40 Publication 901 (April 2013)

Page 41: Treaties U.S. TaxTurkmenistan, and Uzbekistan. That treaty will remain in effect until new treaties with these in-dividual countries are negotiated and ratified. Provisions of the

Tabl

e 2. C

ompe

nsat

ion fo

r Per

sona

l Ser

vices

Per

form

ed in

Unit

ed S

tate

s Exe

mpt f

rom

U.S.

Inco

me Ta

x Und

er In

come

Tax T

reat

iesCa

tego

ry of

Per

sona

l Ser

vices

Coun

try(1

)Co

de1

(2)

Purp

ose 22

(3)

Maxim

um

Pres

ence

in

U.S.

(4)

Requ

ired E

mploy

er or

Pay

er(5

)

Maxim

um

Amou

nt of

Comp

ensa

tion

(6)

Trea

ty Ar

ticle

Cita

tion

(7)

Austr

alia

16

Indep

ende

nt pe

rsona

l serv

ices7

....

....

....

...

18

3 day

s..

....

An

y con

tracto

r...

....

....

....

....

....

No

limit

....

....

...

14

17

Depe

nden

t pers

onal

servi

ces17

....

....

....

....

18

3 day

s..

....

An

y fore

ign re

siden

t...

....

....

....

....

No

limit

....

....

....

15

42

Publi

c ente

rtainm

ent.

....

....

....

....

....

....

No

limit

....

...

An

y U.S

. or fo

reign

resid

ent.

....

....

...

$1

0,000

p.a.

25..

...

17

19

Stud

ying a

nd tra

ining

:

Re

mitta

nces

or al

lowan

ces11

....

....

....

....

No

limit

....

...

An

y fore

ign re

siden

t...

....

....

....

....

No

limit

....

....

....

20

Austr

ia16

Ind

epen

dent

perso

nal s

ervice

s7..

....

....

....

.

No lim

it..

....

.

Any c

ontra

ctor.

....

....

....

....

....

..

No lim

it..

....

....

..

1417

De

pend

ent p

erson

al se

rvice

s17..

....

....

....

..

183 d

ays

....

..

Any f

oreign

resid

ent.

....

....

....

....

..

No lim

it..

....

....

..

1542

Pu

blic e

nterta

inmen

t...

....

....

....

....

....

..

No lim

it..

....

.

Any U

.S. o

r forei

gn re

siden

t...

....

....

.

$20,0

00 p.

a.25..

....

17

19

Stud

ying a

nd tra

ining

:

Re

mitta

nces

or al

lowan

ces11

....

....

....

....

3 y

ears45

....

..

Any f

oreign

resid

ent.

....

....

....

....

..

No lim

it..

....

....

..

20Ba

nglad

esh

15

Scho

larsh

ip or

fellow

ship

grant4

....

....

....

...

2 y

ears45

....

..

Any U

.S. o

r forei

gn re

siden

t5..

....

....

.

No lim

it..

....

....

..

21(2

)16

Ind

epen

dent

perso

nal s

ervice

s7..

....

....

....

.

183 d

ays

....

..

Any c

ontra

ctor.

....

....

....

....

....

..

No lim

it..

....

....

..

1517

De

pend

ent p

erson

al se

rvice

s17..

....

....

....

..

183 d

ays

....

..

Any f

oreign

resid

ent.

....

....

....

....

..

No lim

it..

....

....

..

1642

Pu

blic e

nterta

inmen

t...

....

....

....

....

....

..

No lim

it..

....

.

Any c

ontra

ctor.

....

....

....

....

....

..

$10,0

00 p.

a. 30

....

.

1818

Te

achin

g or r

esea

rch4

....

....

....

....

....

....

2 y

ears

....

...

An

y U.S

. or fo

reign

resid

ent.

....

....

...

No

limit

....

....

....

21

(1)

19

Stud

ying a

nd tra

ining

:4

Remi

ttanc

es or

allow

ance

s ..

....

....

....

...

2 y

ears45

....

..

Any f

oreign

resid

ent.

....

....

....

....

..

No lim

it..

....

....

..

21(2

)

Co

mpen

satio

n duri

ng st

udy o

r train

ing..

....

..

2 yea

rs45..

....

An

y U.S

. or fo

reign

resid

ent.

....

....

...

$8

,000 p

.a...

....

..

21(2

)Ba

rbad

os16

Ind

epen

dent

perso

nal s

ervice

s7, 8

....

....

....

..

89 da

ys..

....

.

Any f

oreign

contr

actor

....

....

....

....

.

No lim

it..

....

....

..

14

89 da

ys..

....

.

Any U

.S. c

ontra

ctor.

....

....

....

....

..

$5,00

0 p.a.

....

....

14

17

Depe

nden

t pers

onal

servi

ces8,

17..

....

....

....

.

183 d

ays

....

..

Any f

oreign

resid

ent.

....

....

....

....

..

$5,00

0 p.a.

....

....

15

42

Publi

c ente

rtainm

ent.

....

....

....

....

....

....

No

limit

....

...

An

y U.S

. or fo

reign

resid

ent.

....

....

...

$2

50 pe

r day

or

$4,00

0 p.a.

6, 50

....

...

17

19

Stud

ying a

nd tra

ining

:23

Remi

ttanc

es or

allow

ance

s11..

....

....

....

..

No lim

it..

....

.

Any f

oreign

resid

ent.

....

....

....

....

..

No lim

it..

....

....

..

20

Page 41 of 61 Fileid: … ons/P901/201304/A/XML/Cycle02/source 10:02 - 11-Mar-2013The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

Publication 901 (April 2013) Page 41

Page 42: Treaties U.S. TaxTurkmenistan, and Uzbekistan. That treaty will remain in effect until new treaties with these in-dividual countries are negotiated and ratified. Provisions of the

Cate

gory

of P

erso

nal S

ervic

es

Coun

try(1

)Co

de1

(2)

Purp

ose 22

(3)

Maxim

um

Pres

ence

in

U.S.

(4)

Requ

ired E

mploy

er or

Pay

er(5

)

Maxim

um

Amou

nt of

Comp

ensa

tion

(6)

Trea

ty Ar

ticle

Cita

tion

(7)

Belgi

um

16

Indep

ende

nt pe

rsona

l serv

ices53

....

....

....

...

....

....

....

....

....

....

....

....

....

....

...

....

....

....

..

717

De

pend

ent p

erson

al se

rvice

s12, 1

7..

....

....

....

18

3 day

s..

....

An

y fore

ign re

siden

t...

....

....

....

....

No

limit

....

....

....

14

42

Publi

c ente

rtainm

ent.

....

....

....

....

....

....

No

limit

....

...

An

y U.S

. or fo

reign

resid

ent.

....

....

...

$2

0,000

p.a.25

....

..

1618

Te

achin

g4..

....

....

....

....

....

....

....

....

2 y

ears

....

...

An

y U.S

. edu

catio

nal o

r res

earch

institu

tion

....

....

....

....

....

....

....

..

No lim

it..

....

....

..

19(2

)19

St

udyin

g and

traini

ng:11

Remi

ttanc

es or

allow

ance

s ..

....

....

....

...

2 y

ears45

....

..

Any f

oreign

resid

ent.

....

....

....

....

..

No lim

it..

....

....

..

19(1

)(a)

Comp

ensa

tion d

uring

stud

y or tr

aining

....

....

2 y

ears45

....

..

Any U

.S. o

r forei

gn re

siden

t...

....

....

.

$9,00

0 p.a.

....

....

19

(1)(b

)Bu

lgaria

16

Ind

epen

dent

perso

nal s

ervice

s53..

....

....

....

...

....

....

....

....

....

....

....

....

....

...

....

....

....

....

7

17

Depe

nden

t pers

onal

servi

ces8,

17..

....

....

....

.

183 d

ays

....

..

Any f

oreign

resid

ent.

....

....

....

....

..

No lim

it..

....

....

..

1442

Pu

blic e

nterta

inmen

t...

....

....

....

....

....

..

No lim

it..

....

.

Any U

.S. o

r forei

gn re

siden

t...

....

....

.

$15,0

00 p.

a.25..

....

16

18

Teac

hing4

....

....

....

....

....

....

....

....

..

2 yea

rs..

....

.

Any U

.S. e

duca

tiona

l or r

esea

rch

ins

titutio

n..

....

....

....

....

....

....

....

No

limit

....

....

....

19

(2)

19

Stud

ying a

nd tra

ining

:11

Remi

ttanc

es or

allow

ance

s ..

....

....

....

...

2 y

ears45

....

..

Any f

oreign

resid

ent.

....

....

....

....

..

No lim

it..

....

....

..

19(1

)(a)

Comp

ensa

tion d

uring

stud

y or tr

aining

....

....

2 y

ears45

....

..

Any U

.S. o

r forei

gn re

siden

t...

....

....

.

$9,00

0 p.a.

....

....

19

(1)(b

)Ca

nada

16

Indep

ende

nt pe

rsona

l serv

ices53

....

....

....

...

....

....

....

....

....

....

....

....

....

....

...

....

....

....

..

VII

17

Depe

nden

t pers

onal

servi

ces

....

....

....

....

.

No lim

it..

....

.

Any U

.S. o

r forei

gn re

siden

t...

....

....

.

$10,0

00 .

....

....

.

XV

183 d

ays

....

..

Any f

oreign

resid

ent17

....

....

....

....

.

No lim

it13..

....

....

XV

42

Publi

c ente

rtainm

ent54

....

....

....

....

....

....

No

limit

....

...

An

y U.S

. or fo

reign

resid

ent.

....

....

...

$1

5,000

p.a.25

....

..

XVI

19

Stud

ying a

nd tra

ining

:

Re

mitta

nces

or al

lowan

ces11

....

....

....

....

No

limit52

....

..

Any f

oreign

resid

ent.

....

....

....

....

..

No lim

it..

....

....

..

XXCh

ina,

Pe

ople'

s Rep

. of

15

Scho

larsh

ip or

fellow

ship

grant15

....

....

....

...

No

spec

ific

limit

....

....

....

An

y U.S

. or fo

reign

resid

ent5

....

....

...

No

limit

....

....

....

20

(b)

16

Indep

ende

nt pe

rsona

l serv

ices7

....

....

....

...

18

3 day

s..

....

An

y con

tracto

r...

....

....

....

....

....

No

limit

....

....

....

13

17

Depe

nden

t pers

onal

servi

ces8,

17..

....

....

....

.

183 d

ays

....

..

Any f

oreign

resid

ent.

....

....

....

....

..

No lim

it..

....

....

..

1442

Pu

blic e

nterta

inmen

t29

....

....

....

....

....

....

....

....

....

....

....

....

....

....

...

....

....

....

..

1618

Te

achin

g4..

....

....

....

....

....

....

....

....

3 y

ears

....

...

U.

S. ed

ucati

onal

or res

earch

insti

tute

....

No

limit

....

....

....

19

19

Stud

ying a

nd tra

ining

:

Re

mitta

nces

or al

lowan

ces

....

....

....

....

.

No sp

ecific

lim

it..

....

....

..

Any f

oreign

resid

ent.

....

....

....

....

..

No lim

it..

....

....

..

20(a)

Comp

ensa

tion d

uring

traini

ng or

whil

e gain

ing

ex

perie

nce

....

....

....

....

....

....

....

.

No sp

ecific

lim

it..

....

....

..

Any U

.S. o

r forei

gn re

siden

t...

....

....

.

$5,00

0 p.a.

....

....

20

(c)

Page 42 of 61 Fileid: … ons/P901/201304/A/XML/Cycle02/source 10:02 - 11-Mar-2013The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

Page 42 Publication 901 (April 2013)

Page 43: Treaties U.S. TaxTurkmenistan, and Uzbekistan. That treaty will remain in effect until new treaties with these in-dividual countries are negotiated and ratified. Provisions of the

Cate

gory

of P

erso

nal S

ervic

es

Coun

try(1

)Co

de1

(2)

Purp

ose 22

(3)

Maxim

um

Pres

ence

in

U.S.

(4)

Requ

ired E

mploy

er or

Pay

er(5

)

Maxim

um

Amou

nt of

Comp

ensa

tion

(6)

Trea

ty Ar

ticle

Cita

tion

(7)

Comm

onwe

alth o

f

Inde

pend

ent S

tate

s15

Sc

holar

ship

or fel

lowsh

ip gra

nt..

....

....

....

..

5 yea

rs..

....

.

Any U

.S. o

r forei

gn re

siden

t...

....

....

.

Limite

d19..

....

...

VI

(1)

16

Indep

ende

nt pe

rsona

l serv

ices

....

....

....

....

18

3 day

s..

....

An

y U.S

. or fo

reign

contr

actor

....

....

..

No lim

it..

....

....

.

VI(2

)17

De

pend

ent p

erson

al se

rvice

s..

....

....

....

...

18

3 day

s..

....

An

y U.S

. or fo

reign

resid

ent.

....

....

...

No

limit

....

....

...

VI

(2)

18

Teac

hing4,

20..

....

....

....

....

....

....

....

..

2 yea

rs..

....

.

Any U

.S. e

duca

tiona

l or s

cienti

fic

ins

titutio

n..

....

....

....

....

....

....

....

No

limit

....

....

...

VI

(1)

19

Stud

ying a

nd tra

ining

:

Re

mitta

nces

or al

lowan

ces

....

....

....

....

.

5 yea

rs..

....

.

Any U

.S. o

r forei

gn re

siden

t...

....

....

.

Limite

d..

....

....

.

VI(1

)

Co

mpen

satio

n whil

e gain

ing ex

perie

nce

....

..

1 yea

r...

....

.

C.I.S

. resid

ent.

....

....

....

....

....

...

No

limit21

....

....

.

VI(1

)

Co

mpen

satio

n und

er U.

S.

Go

vernm

ent p

rogram

....

....

....

....

....

1 y

ear.

....

...

An

y U.S

. or fo

reign

resid

ent.

....

....

...

No

limit

....

....

...

VI

(1)

Cypr

us15

Sc

holar

ship

or fel

lowsh

ip gra

nt 15

....

....

....

..

Gene

rally,

5

years

....

....

...

An

y U.S

. or fo

reign

resid

ent5

....

....

...

No

limit

....

....

...

21

(1)

16

Indep

ende

nt pe

rsona

l serv

ices7

....

....

....

...

18

2 day

s..

....

An

y con

tracto

r...

....

....

....

....

....

No

limit

....

....

...

17

17

Depe

nden

t pers

onal

servi

ces17

....

....

....

....

18

2 day

s..

....

An

y fore

ign re

siden

t...

....

....

....

....

No

limit

....

....

...

18

42

Publi

c ente

rtainm

ent.

....

....

....

....

....

....

No

limit

....

...

An

y U.S

. or fo

reign

resid

ent.

....

....

...

$5

00 pe

r day

or

$5,00

0 p.a.

6..

....

...

19

(1)

19

Stud

ying a

nd tra

ining

:

Re

mitta

nces

or al

lowan

ces

....

....

....

....

.

Gene

rally,

5

years

....

....

...

An

y fore

ign re

siden

t...

....

....

....

....

No

limit

....

....

...

21

(1)

Comp

ensa

tion d

uring

traini

ng..

....

....

....

.

Gene

rally,

5

years

....

....

...

An

y U.S

. or fo

reign

resid

ent.

....

....

...

$2

,000 p

.a...

....

.

21(1

)

Co

mpen

satio

n whil

e gain

ing ex

perie

nce2

....

.

1 yea

r...

....

.

Cypr

us re

siden

t...

....

....

....

....

...

$7

,500

....

....

...

21

(2)

Comp

ensa

tion u

nder

U.S.

Gove

rnmen

t prog

ram..

....

....

....

....

..

1 yea

r...

....

.

U.S.

Gov

ernme

nt or

its co

ntrac

tor..

....

.

$10,0

00..

....

....

21

(3)

Czec

h Rep

ublic

15

Scho

larsh

ip or

fellow

ship

grant

4, 15

....

....

....

.

5 yea

rs..

....

.

Any U

.S. o

r forei

gn re

siden

t5..

....

....

.

No lim

it..

....

....

.

21(1

)16

Ind

epen

dent

perso

nal s

ervice

s7..

....

....

....

.

183 d

ays

....

..

Any c

ontra

ctor.

....

....

....

....

....

..

No lim

it..

....

....

.

1417

De

pend

ent p

erson

al se

rvice

s8, 17

....

....

....

...

18

3 day

s..

....

An

y fore

ign re

siden

t...

....

....

....

....

No

limit

....

....

...

15

42

Publi

c ente

rtainm

ent.

....

....

....

....

....

....

No

limit

....

...

An

y U.S

. or fo

reign

resid

ent.

....

....

...

$2

0,000

p.a.30

....

.

1818

Te

achin

g4, 35

....

....

....

....

....

....

....

....

2 y

ears

....

...

An

y U.S

. edu

catio

nal o

r res

earch

institu

tion

....

....

....

....

....

....

....

..

No lim

it..

....

....

.

21(5

)19

St

udyin

g and

traini

ng:4

Remi

ttanc

es an

d allo

wanc

es .

....

....

....

..

5 yea

rs..

....

.

Any f

oreign

resid

ent.

....

....

....

....

..

No lim

it..

....

....

.

21(1

)

Co

mpen

satio

n duri

ng tra

ining

....

....

....

...

5 y

ears

....

...

An

y U.S

. or fo

reign

resid

ent.

....

....

...

$5

,000 p

.a...

....

.

21(1

)

Co

mpen

satio

n whil

e gain

ing ex

perie

nce2

....

.

12 co

nsec

. mo

s...

....

....

..

Czec

h res

ident

....

....

....

....

....

...

$8

,000

....

....

...

21

(2)

Comp

ensa

tion u

nder

U.S.

Gove

rnmen

t prog

ram..

....

....

....

....

..

1 yea

r...

....

.

U.S.

Gov

ernme

nt..

....

....

....

....

...

$1

0,000

....

....

..

21(3

)

Page 43 of 61 Fileid: … ons/P901/201304/A/XML/Cycle02/source 10:02 - 11-Mar-2013The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

Publication 901 (April 2013) Page 43

Page 44: Treaties U.S. TaxTurkmenistan, and Uzbekistan. That treaty will remain in effect until new treaties with these in-dividual countries are negotiated and ratified. Provisions of the

Cate

gory

of P

erso

nal S

ervic

es

Coun

try(1

)Co

de1

(2)

Purp

ose 22

(3)

Maxim

um

Pres

ence

in

U.S.

(4)

Requ

ired E

mploy

er or

Pay

er(5

)

Maxim

um

Amou

nt of

Comp

ensa

tion

(6)

Trea

ty Ar

ticle

Cita

tion

(7)

Denm

ark

16

Indep

ende

nt pe

rsona

l serv

ices7

....

....

....

...

No

limit

....

...

An

y con

tracto

r...

....

....

....

....

....

No

limit

....

....

...

14

17

Depe

nden

t pers

onal

servi

ces8,

17..

....

....

....

. 18

3 day

s..

....

An

y fore

ign re

siden

t...

....

....

....

....

No

limit

....

....

...

15

42

Publi

c ente

rtainm

ent.

....

....

....

....

....

....

No

limit

....

...

An

y U.S

. or fo

reign

resid

ent.

....

....

...

$2

0,000

p.a.25

....

.

1719

St

udyin

g and

traini

ng:4

Remi

ttanc

es or

allow

ance

s11..

....

....

....

..

3 yea

rs45..

....

An

y fore

ign re

siden

t...

....

....

....

....

No

limit

....

....

...

20

Egyp

t15

Sc

holar

ship

or fel

lowsh

ip gra

nt15..

....

....

....

.

Gene

rally,

5

years

....

....

...

An

y U.S

. or fo

reign

resid

ent5

....

....

...

No

limit

....

....

...

23

(1)

16

Indep

ende

nt pe

rsona

l serv

ices

....

....

....

....

89

days

....

...

An

y con

tracto

r...

....

....

....

....

....

No

limit

....

....

...

15

17

Depe

nden

t pers

onal

servi

ces16

, 17

....

....

....

..

89 da

ys..

....

.

Egyp

tian r

eside

nt..

....

....

....

....

...

No

limit

....

....

...

16

42

Publi

c ente

rtainm

ent.

....

....

....

....

....

....

No

limit

....

...

An

y U.S

. or fo

reign

resid

ent.

....

....

...

$4

00 pe

r day

46..

..

1718

Te

achin

g4, 13

....

....

....

....

....

....

....

....

2 y

ears

....

...

U.

S. ed

ucati

onal

institu

tion

....

....

....

.

No lim

it..

....

....

.

2219

St

udyin

g and

traini

ng:

Remi

ttanc

es or

allow

ance

s ..

....

....

....

...

Ge

neral

ly, 5

ye

ars..

....

....

.

Any f

oreign

resid

ent.

....

....

....

....

..

No lim

it..

....

....

.

23(1

)

Co

mpen

satio

n duri

ng tra

ining

...

....

....

....

Ge

neral

ly, 5

ye

ars..

....

....

.

U.S.

or an

y fore

ign re

siden

t...

....

....

.

$3,00

0 p.a.

....

...

23

(1)

Comp

ensa

tion w

hile g

aining

expe

rienc

e2..

...

12

cons

ec.

mos.

....

....

....

Eg

yptia

n res

ident

....

....

....

....

....

.

$7,50

0..

....

....

.

23(2

)

Co

mpen

satio

n und

er U.

S.

Go

vernm

ent p

rogram

....

....

....

....

....

1 y

ear.

....

...

U.

S. G

overn

ment

or its

contr

actor

....

...

$1

0,000

....

....

..

23(3

)Es

tonia

15

Scho

larsh

ip or

fellow

ship

grants

4..

....

....

....

5 y

ears

....

...

An

y U.S

. or fo

reign

resid

ent5

....

....

...

No

limit

....

....

...

20

(1)

16

Indep

ende

nt pe

rsona

l serv

ices7

....

....

....

...

18

3 day

s..

....

An

y con

tracto

r...

....

....

....

....

....

No

limit

....

....

...

14

17

Depe

nden

t pers

onal

servi

ces8,

17..

....

....

....

. 18

3 day

s..

....

An

y fore

ign re

siden

t...

....

....

....

....

No

limit

....

....

...

15

42

Publi

c ente

rtainm

ent.

....

....

....

....

....

....

No

limit

....

...

An

y U.S

. or fo

reign

resid

ent.

....

....

...

$2

0,000

p.a.

30..

..

1719

St

udyin

g and

traini

ng:4

Remi

ttanc

es or

allow

ance

s ..

....

....

....

...

5 y

ears

....

...

An

y fore

ign re

siden

t...

....

....

....

....

No

limit

....

....

...

20

(1)

Comp

ensa

tion d

uring

traini

ng..

....

....

....

.

12 co

nsec

. mo

s...

....

....

..

Eston

ian re

siden

t...

....

....

....

....

..

$8,00

0..

....

....

.

20(2

)

5 yea

rs..

....

.

Othe

r forei

gn or

U.S

. resid

ent.

....

....

.

$5,00

0 p.a.

....

...

20

(1)

Comp

ensa

tion w

hile g

aining

expe

rienc

e2..

...

12

cons

ec.

mos.

....

....

....

Es

tonian

resid

ent.

....

....

....

....

....

$8

,000

....

....

...

20

(2)

Comp

ensa

tion u

nder

U.S.

Gove

rnmen

t prog

ram..

....

....

....

....

..

1 yea

r...

....

.

U.S.

Gov

ernme

nt or

its co

ntrac

tor..

....

.

$10,0

00..

....

....

20

(3)

Finlan

d16

Ind

epen

dent

perso

nal s

ervice

s7..

....

....

....

.

No lim

it..

....

.

Any c

ontra

ctor.

....

....

....

....

....

..

No lim

it..

....

....

.

1417

De

pend

ent p

erson

al se

rvice

s17..

....

....

....

..

183 d

ays

....

..

Any f

oreign

resid

ent.

....

....

....

....

..

No lim

it..

....

....

.

1542

Pu

blic e

nterta

inmen

t...

....

....

....

....

....

..

No lim

it..

....

.

Any U

.S. o

r forei

gn re

siden

t...

....

....

.

$20,0

00 p.

a.25..

...

17

19

Stud

ying a

nd tra

ining

:

Re

mitta

nces

or al

lowan

ces11

....

....

....

....

No

limit

....

...

An

y fore

ign re

siden

t...

....

....

....

....

No

limit

....

....

...

20

Page 44 of 61 Fileid: … ons/P901/201304/A/XML/Cycle02/source 10:02 - 11-Mar-2013The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

Page 44 Publication 901 (April 2013)

Page 45: Treaties U.S. TaxTurkmenistan, and Uzbekistan. That treaty will remain in effect until new treaties with these in-dividual countries are negotiated and ratified. Provisions of the

Cate

gory

of P

erso

nal S

ervic

es

Coun

try(1

)Co

de1

(2)

Purp

ose 22

(3)

Maxim

um

Pres

ence

in

U.S.

(4)

Requ

ired E

mploy

er or

Pay

er(5

)

Maxim

um

Amou

nt of

Comp

ensa

tion

(6)

Trea

ty Ar

ticle

Cita

tion

(7)

Fran

ce15

Sc

holar

ship

or fel

lowsh

ip gra

nt15..

....

....

....

.

5 yea

rs43..

....

An

y U.S

. or fo

reign

resid

ent5

....

....

...

No

limit

....

....

..

21(1

)16

Ind

epen

dent

perso

nal s

ervice

s7..

....

....

....

.

No lim

it..

....

.

Any c

ontra

ctor.

....

....

....

....

....

..

No lim

it..

....

....

14

17

Depe

nden

t pers

onal

servi

ces8,

17..

....

....

....

. 18

3 day

s..

....

An

y fore

ign re

siden

t...

....

....

....

....

No

limit

....

....

..

1542

Pu

blic e

nterta

inmen

t...

....

....

....

....

....

..

No lim

it..

....

.

Any U

.S. o

r forei

gn re

siden

t...

....

....

.

$10,0

00 p.

a. 30

....

17

18

Teac

hing4,

44..

....

....

....

....

....

....

....

..

2 yea

rs43..

....

U.

S. ed

ucati

onal

or res

earch

ins

titutio

n..

....

....

....

....

....

....

....

No

limit

....

....

..

2019

St

udyin

g and

traini

ng:4

Remi

ttanc

es or

allow

ance

s ..

....

....

....

...

5 y

ears43

....

..

Any f

oreign

resid

ent.

....

....

....

....

..

No lim

it..

....

....

21

(1)

Comp

ensa

tion d

uring

stud

y or tr

aining

...

....

12

cons

ec.

mos.

....

....

....

Fr

ench

resid

ent.

....

....

....

....

....

.

$8,00

0..

....

....

.

21(2

)

5 yea

rs43..

....

Ot

her fo

reign

or U

.S. re

siden

t...

....

...

$5

,000 p

.a...

....

.

21(1

)

Co

mpen

satio

n whil

e gain

ing ex

perie

nce2

....

.

12 co

nsec

. mo

s...

....

....

..

Fren

ch re

siden

t...

....

....

....

....

...

$8

,000

....

....

...

21

(2)

Germ

any

15

Scho

larsh

ip or

fellow

ship

grant

....

....

....

....

No

limit

....

...

An

y U.S

. or fo

reign

resid

ent5

....

....

...

No

limit

....

....

..

20(3

)16

Ind

epen

dent

perso

nal s

ervice

s53..

....

....

....

....

....

....

...

....

....

....

....

....

....

...

....

....

....

...

7

17

Depe

nden

t pers

onal

servi

ces12

,17..

....

....

....

18

3 day

s..

....

An

y fore

ign re

siden

t...

....

....

....

....

No

limit

....

....

..

1542

Pu

blic e

nterta

inmen

t...

....

....

....

....

....

..

No lim

it..

....

.

Any U

.S. o

r forei

gn re

siden

t...

....

....

.

$20,0

00 p.

a.30..

...

17

18

Teac

hing4,

55..

....

....

....

....

....

....

....

..

2 yea

rs..

....

.

U.S.

educ

ation

al or

resea

rch

institu

tion

....

....

....

....

....

....

....

..

No lim

it..

....

....

20

(1)

19

Stud

ying a

nd tra

ining

:11

Remi

ttanc

es or

allow

ance

s ..

....

....

....

...

No

limit

....

...

An

y fore

ign re

siden

t...

....

....

....

....

No

limit

....

....

..

20(2

)

Co

mpen

satio

n duri

ng st

udy o

r train

ing..

....

..

4 yea

rs..

....

.

Any U

.S. o

r forei

gn re

siden

t...

....

....

.

$9,00

0 p.a.

....

...

20

(4)

Comp

ensa

tion w

hile g

aining

expe

rienc

e2..

...

1 y

ear.

....

...

An

y fore

ign re

siden

t...

....

....

....

....

$1

0,000

28..

....

..

20(5

)Gr

eece

16

Indep

ende

nt pe

rsona

l serv

ices

....

....

....

....

18

3 day

s..

....

Gr

eek r

eside

nt co

ntrac

tor..

....

....

....

No

limit

....

....

..

X

18

3 day

s..

....

Ot

her fo

reign

or U

.S. re

siden

t co

ntrac

tor..

....

....

....

....

....

....

...

$1

0,000

p.a.

....

..

X17

De

pend

ent p

erson

al se

rvice

s..

....

....

....

...

18

3 day

s..

....

Gr

eek r

eside

nt..

....

....

....

....

....

.

No lim

it..

....

....

X

18

3 day

s..

....

Ot

her fo

reign

or U

.S re

siden

t...

....

....

$1

0,000

p.a.

....

..

X18

Te

achin

g..

....

....

....

....

....

....

....

....

.

3 yea

rs..

....

.

U.S.

educ

ation

al ins

titutio

n..

....

....

...

No

limit

....

....

..

XII

19

Stud

ying a

nd tra

ining

:

Re

mitta

nces

or al

lowan

ces

....

....

....

....

.

No lim

it..

....

.

Any f

oreign

resid

ent.

....

....

....

....

..

No lim

it..

....

....

XI

IIHu

ngar

y16

Ind

epen

dent

perso

nal s

ervice

s7..

....

....

....

.

183 d

ays

....

..

Any c

ontra

ctor.

....

....

....

....

....

..

No lim

it..

....

....

13

17

Depe

nden

t pers

onal

servi

ces17

....

....

....

....

18

3 day

s..

....

An

y fore

ign re

siden

t...

....

....

....

....

No

limit

....

....

..

1418

Te

achin

g4..

....

....

....

....

....

....

....

....

2 y

ears

....

...

U.

S. ed

ucati

onal

institu

tion

....

....

....

.

No lim

it..

....

....

17

19

Stud

ying a

nd tra

ining

:23

Remi

ttanc

es or

allow

ance

s11..

....

....

....

..

No lim

it..

....

.

Any f

oreign

resid

ent.

....

....

....

....

..

No lim

it..

....

....

18

(1)

Page 45 of 61 Fileid: … ons/P901/201304/A/XML/Cycle02/source 10:02 - 11-Mar-2013The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

Publication 901 (April 2013) Page 45

Page 46: Treaties U.S. TaxTurkmenistan, and Uzbekistan. That treaty will remain in effect until new treaties with these in-dividual countries are negotiated and ratified. Provisions of the

Cate

gory

of P

erso

nal S

ervic

es

Coun

try(1

)Co

de1

(2)

Purp

ose 22

(3)

Maxim

um

Pres

ence

in

U.S.

(4)

Requ

ired E

mploy

er or

Pay

er(5

)

Maxim

um

Amou

nt of

Comp

ensa

tion

(6)

Trea

ty Ar

ticle

Cita

tion

(7)

Icelan

d15

Sc

holar

ship

or fel

lowsh

ip gra

nt..

....

....

....

..

5 yea

rs..

....

.

Any U

.S. o

r forei

gn re

siden

t5..

....

....

.

No lim

it..

....

....

19

(1)

16

Ind

epen

dent

perso

nal s

ervice

s53..

....

....

....

....

....

....

...

....

....

....

....

....

....

...

....

....

....

...

7

17

Depe

nden

t pers

onal

servi

ces8,

17..

....

....

....

. 18

3 day

s..

....

An

y fore

ign re

siden

t...

....

....

....

....

No

limit

....

....

..

1442

Pu

blic e

nterta

inmen

t...

....

....

....

....

....

..

No lim

it..

....

.

Any U

.S. o

r forei

gn re

siden

t...

....

....

.

$20,0

00 p.

a.25..

..

1619

St

udyin

g and

traini

ng:

Remi

ttanc

es or

allow

ance

s ..

....

....

....

...

5 y

ears

....

...

An

y fore

ign re

siden

t...

....

....

....

....

No

limit

....

....

..

19(1

)

Co

mpen

satio

n duri

ng st

udy o

r train

ing .

....

..

5 yea

rs..

....

.

Any U

.S. o

r forei

gn re

siden

t...

....

....

.

$9,00

0 p.a.

....

...

19

(1)

Comp

ensa

tion w

hile g

aining

expe

rienc

e..

....

12

cons

ec.

mo..

....

....

....

An

y U.S

. or fo

reign

resid

ent2

....

....

...

$9

,000

....

....

...

19

(2)

Comp

ensa

tion u

nder

U.S.

Gove

rnmen

t prog

ram..

....

....

....

....

..

1 yea

r...

....

.

U.S.

Gov

ernme

nt or

its co

ntrac

tor..

....

.

$9,00

0..

....

....

.

19(3

)In

dia

16

Indep

ende

nt pe

rsona

l serv

ices7,

8..

....

....

....

89

days

....

...

An

y con

tracto

r...

....

....

....

....

....

No

limit

....

....

..

1517

De

pend

ent p

erson

al se

rvice

s8, 17

....

....

....

...

183 d

ays

....

..

Any f

oreign

resid

ent.

....

....

....

....

..

No lim

it..

....

....

16

42

Publi

c ente

rtainm

ent.

....

....

....

....

....

....

No

limit

....

...

An

y U.S

. or fo

reign

resid

ent.

....

....

...

$1

,500 p

.a.26

, 50

...

18

18

Teac

hing4

....

....

....

....

....

....

....

....

..

2 yea

rs..

....

.

U.S.

educ

ation

al ins

titutio

n..

....

....

...

No

limit

....

....

..

2219

St

udyin

g and

traini

ng:

Remi

ttanc

es or

allow

ance

s ..

....

....

....

...

Re

ason

able

pe

riod

....

....

..

Any f

oreign

resid

ent27

....

....

....

....

.

No lim

it..

....

....

21

(1)

Indo

nesia

15

Scho

larsh

ip an

d fell

owsh

ip gra

nt15..

....

....

...

5 y

ears

....

...

An

y U.S

. or fo

reign

resid

ent5

....

....

...

No

limit

....

....

..

19(1

)16

Ind

epen

dent

perso

nal s

ervice

s7..

....

....

....

.

119 d

ays

....

..

Any c

ontra

ctor.

....

....

....

....

....

..

No lim

it..

....

....

15

17

Depe

nden

t pers

onal

servi

ces17

....

....

....

....

11

9 day

s..

....

An

y fore

ign re

siden

t...

....

....

....

....

No

limit

....

....

..

1642

Pu

blic e

nterta

inmen

t...

....

....

....

....

....

..

No lim

it..

....

.

Any U

.S. o

r forei

gn re

siden

t...

....

....

.

$2,00

0 p.a.

25, 5

0..

.

1718

Te

achin

g4, 44

....

....

....

....

....

....

....

....

2 y

ears

....

...

U.

S. ed

ucati

onal

institu

tion

....

....

....

.

No lim

it..

....

....

20

19

Stud

ying a

nd tra

ining

:

Re

mitta

nces

or al

lowan

ces

....

....

....

....

.

5 yea

rs..

....

.

Any f

oreign

resid

ent.

....

....

....

....

..

No lim

it..

....

....

19

(1)

Comp

ensa

tion d

uring

traini

ng..

....

....

....

.

5 yea

rs..

....

.

Any U

.S. o

r forei

gn re

siden

t...

....

....

.

$2,00

0 p.a.

....

...

19

(1)

Comp

ensa

tion w

hile g

aining

expe

rienc

e..

....

12

cons

ec.

mo..

....

....

....

An

y U.S

. or fo

reign

resid

ent.

....

....

...

$7

,500

....

....

...

19

(2)

Irelan

d16

Ind

epen

dent

perso

nal s

ervice

s7..

....

....

....

.

No lim

it..

....

.

Any c

ontra

ctor.

....

....

....

....

....

..

No lim

it..

....

....

14

17

Depe

nden

t pers

onal

servi

ces17

, 47

....

....

....

..

183 d

ays

....

..

Any f

oreign

resid

ent.

....

....

....

....

..

No lim

it..

....

....

15

42

Publi

c ente

rtainm

ent.

....

....

....

....

....

....

No

limit

....

...

An

y U.S

. or fo

reign

resid

ent.

....

....

...

$2

0,000

p.a.25

....

17

19

Stud

ying a

nd tra

ining

:

Re

mitta

nces

or al

lowan

ces11

....

....

....

....

1 y

ear45

....

...

An

y fore

ign re

siden

t...

....

....

....

....

No

limit

....

....

..

20

Page 46 of 61 Fileid: … ons/P901/201304/A/XML/Cycle02/source 10:02 - 11-Mar-2013The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

Page 46 Publication 901 (April 2013)

Page 47: Treaties U.S. TaxTurkmenistan, and Uzbekistan. That treaty will remain in effect until new treaties with these in-dividual countries are negotiated and ratified. Provisions of the

Cate

gory

of P

erso

nal S

ervic

es

Coun

try(1

)Co

de1

(2)

Purp

ose 22

(3)

Maxim

um

Pres

ence

in

U.S.

(4)

Requ

ired E

mploy

er or

Pay

er(5

)

Maxim

um

Amou

nt of

Comp

ensa

tion

(6)

Trea

ty Ar

ticle

Cita

tion

(7)

Israe

l15

Sc

holar

ship

and f

ellow

ship

grant

....

....

....

...

5 yea

rs..

....

.

Any U

.S. o

r forei

gn re

siden

t5..

....

....

.

No lim

it..

....

....

24

(1)

16

Indep

ende

nt pe

rsona

l serv

ices

....

....

....

....

18

2 day

s..

....

An

y con

tracto

r...

....

....

....

....

....

No

limit

....

....

..

1617

De

pend

ent p

erson

al se

rvice

s16, 1

7..

....

....

....

18

2 day

s..

....

Isr

aeli r

eside

nt..

....

....

....

....

....

.

No lim

it..

....

....

17

42

Publi

c ente

rtainm

ent.

....

....

....

....

....

....

No

limit

....

...

An

y U.S

. or fo

reign

resid

ent.

....

....

...

$4

00 pe

r day

37..

..

1818

Te

achin

g4, 39

....

....

....

....

....

....

....

....

2 y

ears

....

...

U.

S. ed

ucati

onal

institu

tion

....

....

....

.

No lim

it..

....

....

23

19

Stud

ying a

nd tra

ining

:

Re

mitta

nces

or al

lowan

ces

....

....

....

....

.

5 yea

rs..

....

.

Any f

oreign

resid

ent.

....

....

....

....

..

No lim

it..

....

....

24

(1)

Comp

ensa

tion d

uring

stud

y or tr

aining

....

....

5 y

ears

....

...

An

y U.S

. or fo

reign

resid

ent.

....

....

...

$3

,000 p

.a...

....

.

24(1

)

Co

mpen

satio

n whil

e gain

ing ex

perie

nce2

....

.

12 co

nsec

. mo

....

....

....

..

Israe

li res

ident

....

....

....

....

....

...

$7

,500

....

....

...

24(2

)

Co

mpen

satio

n und

er U.

S.

Go

vernm

ent p

rogram

....

....

....

....

....

1 y

ear.

....

...

U.

S. G

overn

ment

or its

contr

actor

....

...

$1

0,000

....

....

.

24(3

)Ita

ly 16

Ind

epen

dent

perso

nal s

ervice

s 7..

....

....

....

.

No lim

it..

....

.

Any c

ontra

ctor.

....

....

....

....

....

..

No lim

it..

....

....

14

(1)

17

Depe

nden

t pers

onal

servi

ces 8,

17..

....

....

....

18

3 day

s..

....

An

y fore

ign re

siden

t...

....

....

....

....

No

limit

....

....

..

15(2

)42

Pu

blic e

nterta

inmen

t ..

....

....

....

....

....

...

90 da

ys..

....

.

Any U

.S. o

r forei

gn re

siden

t...

....

....

.

$20,0

00 p.

a.25..

..

1718

Te

achin

g or r

esea

rch 4

....

....

....

....

....

...

2 y

ears

....

...

An

y U.S

. or fo

reign

resid

ent.

....

....

...

No

limit

....

....

..

2019

St

udyin

g and

traini

ng:

Remi

ttanc

es or

allow

ance

s ..

....

....

....

...

No

limit

....

...

An

y fore

ign re

siden

t...

....

....

....

....

No

limit

....

....

..

21Ja

maica

16

Indep

ende

nt pe

rsona

l serv

ices7

....

....

....

...

89

days

....

...

An

y fore

ign co

ntrac

tor..

....

....

....

...

No

limit

....

....

..

14

89 da

ys..

....

.

Any U

.S. c

ontra

ctor.

....

....

....

....

..

$5,00

0 p.a.

....

...

14

17

Depe

nden

t pers

onal

servi

ces17

....

....

....

....

18

3 day

s..

....

An

y fore

ign re

siden

t...

....

....

....

....

$5

,000 p

.a...

....

.

1542

Pu

blic e

nterta

inmen

t ..

....

....

....

....

....

...

No lim

it..

....

.

Any U

.S. o

r forei

gn re

siden

t...

....

....

.

$400

per d

ay or

$5

,000 p

.a.6

....

....

18

18

Teac

hing4,

44..

....

....

....

....

....

....

....

..

2 yea

rs..

....

.

U.S.

educ

ation

al ins

titutio

n..

....

....

...

No

limit

....

....

..

2219

St

udyin

g and

traini

ng:23

Remi

ttanc

es or

allow

ance

s11..

....

....

....

..

No lim

it..

....

.

Any f

oreign

resid

ent.

....

....

....

....

..

No lim

it..

....

....

21

(1)

Comp

ensa

tion d

uring

stud

y..

....

....

....

...

12

cons

ec.

mo..

....

....

....

Ja

maica

n res

ident

....

....

....

....

....

$7

,500 p

.a...

....

.

21(2

)

Co

mpen

satio

n whil

e gain

ing ex

perie

nce2

....

.

12 co

nsec

. mo

....

....

....

..

Jama

ican r

eside

nt..

....

....

....

....

..

$7,50

0 p.a.

....

...

21

(2)

Japa

n16

Ind

epen

dent

perso

nal s

ervice

s8, 53

....

....

....

...

....

....

....

....

....

....

....

....

....

...

....

....

....

..

717

De

pend

ent p

erson

al se

rvice

s8, 17

....

....

....

...

183 d

ays

....

..

Any f

oreign

resid

ent.

....

....

....

....

..

No lim

it..

....

....

14

42

Publi

c ente

rtainm

ent.

....

....

....

....

....

....

No

limit

....

...

An

y U.S

. or fo

reign

resid

ent.

....

....

...

$1

0,000

p.a.25

....

16

18

Teac

hing o

r res

earch

4..

....

....

....

....

....

..

2 yea

rs..

....

.

Any U

.S. e

duca

tiona

l insti

tution

....

....

.

No lim

it..

....

....

20

19

Stud

ying a

nd tra

ining

:

Re

mitta

nces

or al

lowan

ces

....

....

....

....

.

1 yea

r45..

....

.

Any f

oreign

resid

ent.

....

....

....

....

..

No lim

it..

....

....

19

Page 47 of 61 Fileid: … ons/P901/201304/A/XML/Cycle02/source 10:02 - 11-Mar-2013The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

Publication 901 (April 2013) Page 47

Page 48: Treaties U.S. TaxTurkmenistan, and Uzbekistan. That treaty will remain in effect until new treaties with these in-dividual countries are negotiated and ratified. Provisions of the

Cate

gory

of P

erso

nal S

ervic

es

Coun

try(1

)Co

de1

(2)

Purp

ose 22

(3)

Maxim

um

Pres

ence

in

U.S.

(4)

Requ

ired E

mploy

er or

Pay

er(5

)

Maxim

um

Amou

nt of

Comp

ensa

tion

(6)

Trea

ty Ar

ticle

Cita

tion

(7)

Kaza

khsta

n15

Sc

holar

ship

or fel

lowsh

ip gra

nt4, 15

, 41

....

....

...

5 y

ears31

....

..

Any U

.S. o

r forei

gn re

siden

t5..

....

....

.

No lim

it..

....

....

19

16

Indep

ende

nt pe

rsona

l serv

ices7

....

....

....

...

18

3 day

s..

....

An

y con

tracto

r...

....

....

....

....

....

No

limit

....

....

..

1417

De

pend

ent p

erson

al se

rvice

s17, 4

7..

....

....

....

18

3 day

s..

....

An

y fore

ign re

siden

t...

....

....

....

....

No

limit

....

....

..

1519

St

udyin

g and

traini

ng:4

Remi

ttanc

es or

allow

ance

s..

....

....

....

...

5 y

ears31

....

..

Any f

oreign

resid

ent.

....

....

....

....

..

No lim

it..

....

....

19

Kore

a, So

uth

15

Scho

larsh

ip or

fellow

ship

grant15

....

....

....

...

5 y

ears

....

...

An

y U.S

. or fo

reign

resid

ent5

....

....

...

No

limit

....

....

..

21(1

)16

Ind

epen

dent

perso

nal s

ervice

s7..

....

....

....

.

182 d

ays

....

..

Any c

ontra

ctor.

....

....

....

....

....

..

$3,00

0 p.a.

....

...

18

17

Depe

nden

t pers

onal

servi

ces17

....

....

....

....

18

2 day

s..

....

Ko

rean r

eside

nt18..

....

....

....

....

...

$3

,000 p

.a...

....

.

1918

Te

achin

g4..

....

....

....

....

....

....

....

....

2 y

ears

....

...

U.

S. ed

ucati

onal

institu

tion

....

....

....

.

No lim

it..

....

....

20

19

Stud

ying a

nd tra

ining

:

Re

mitta

nces

or al

lowan

ces

....

....

....

....

.

5 yea

rs..

....

.

Any f

oreign

resid

ent.

....

....

....

....

..

No lim

it..

....

....

21

(1)

Comp

ensa

tion d

uring

traini

ng .

....

....

....

..

5 yea

rs..

....

.

Any f

oreign

or U

.S. re

siden

t...

....

....

.

$2,00

0 p.a.

....

...

21

(1)

Comp

ensa

tion w

hile g

aining

expe

rienc

e2..

...

1 y

ear.

....

...

Ko

rean r

eside

nt..

....

....

....

....

....

$5

,000

....

....

...

21(2

)

Co

mpen

satio

n und

er U.

S.

Go

vernm

ent p

rogram

....

....

....

....

....

1 y

ear.

....

...

U.

S. G

overn

ment

or its

contr

actor

....

...

$1

0,000

....

....

.

21(3

)La

tvia

15

Scho

larsh

ip or

fellow

ship

grants

4..

....

....

....

5 y

ears

....

...

An

y U.S

. or fo

reign

resid

ent5

....

....

...

No

limit

....

....

..

20(1

)16

Ind

epen

dent

perso

nal s

ervice

s7..

....

....

....

.

183 d

ays

....

..

Any c

ontra

ctor.

....

....

....

....

....

..

No lim

it..

....

....

14

17

Depe

nden

t pers

onal

servi

ces8,

17..

....

....

....

. 18

3 day

s..

....

An

y fore

ign re

siden

t...

....

....

....

....

No

limit

....

....

..

1542

Pu

blic e

nterta

inmen

t...

....

....

....

....

....

..

No lim

it..

....

.

Any U

.S. o

r forei

gn re

siden

t...

....

....

.

$20,0

00 p.

a. 30

....

17

19

Stud

ying a

nd tra

ining

:4

Remi

ttanc

es or

allow

ance

s ..

....

....

....

...

5 y

ears

....

...

An

y fore

ign re

siden

t...

....

....

....

....

No

limit

....

....

..

20(1

)

Co

mpen

satio

n duri

ng tra

ining

....

....

....

...

12

cons

ec.

mos.

....

....

....

La

tvian

resid

ent.

....

....

....

....

....

.

$8,00

0..

....

....

. 20

(2)

5 y

ears

....

...

Ot

her fo

reign

or U

.S. re

siden

t...

....

...

$5

,000 p

.a...

....

.

20(1

)

Co

mpen

satio

n whil

e gain

ing ex

perie

nce2

....

.

12 co

nsec

. mo

s...

....

....

..

Lativ

an re

siden

t...

....

....

....

....

...

$8

,000

....

....

...

20(2

)

Co

mpen

satio

n und

er U.

S.

Go

vernm

ent p

rogram

....

....

....

....

....

1 y

ear.

....

...

U.

S. G

overn

ment

or its

contr

actor

....

...

$1

0,000

....

....

.

20(3

)Lit

huan

ia15

Sc

holar

ship

or fel

lowsh

ip gra

nts4

....

....

....

..

5 yea

rs..

....

.

Any U

.S. o

r forei

gn re

siden

t5..

....

....

.

No lim

it..

....

....

20

(1)

16

Indep

ende

nt pe

rsona

l serv

ices7

....

....

....

...

18

3 day

s..

....

An

y con

tracto

r...

....

....

....

....

....

No

limit

....

....

..

1417

De

pend

ent p

erson

al se

rvice

s8, 17

....

....

....

...

183 d

ays

....

..

Any f

oreign

resid

ent.

....

....

....

....

..

No lim

it..

....

....

15

42

Publi

c ente

rtainm

ent.

....

....

....

....

....

....

No

limit

....

...

An

y U.S

. or fo

reign

resid

ent.

....

....

...

$2

0,000

p.a.

30..

..

1719

St

udyin

g and

traini

ng:4

Remi

ttanc

es or

allow

ance

s ..

....

....

....

...

5 y

ears

....

...

An

y fore

ign re

siden

t...

....

....

....

....

No

limit

....

....

..

20(1

)

Co

mpen

satio

n duri

ng tra

ining

....

....

....

...

12

cons

ec.

mos.

....

....

....

Lit

huan

ian re

siden

t...

....

....

....

....

$8

,000

....

....

...

20(2

)

5 yea

rs..

....

.

Othe

r forei

gn or

U.S

. resid

ent.

....

....

.

$5,00

0 p.a.

....

...

20

(1)

Comp

ensa

tion w

hile g

aining

expe

rienc

e2..

...

12

cons

ec.

mos.

....

....

....

Lit

huan

ian re

siden

t...

....

....

....

....

$8

,000

....

....

...

20(2

)

Co

mpen

satio

n und

er U.

S.

Go

vernm

ent p

rogram

....

....

....

....

....

1 y

ear.

....

...

U.

S. G

overn

ment

or its

contr

actor

....

...

$1

0,000

....

....

.

20(3

)

Page 48 of 61 Fileid: … ons/P901/201304/A/XML/Cycle02/source 10:02 - 11-Mar-2013The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

Page 48 Publication 901 (April 2013)

Page 49: Treaties U.S. TaxTurkmenistan, and Uzbekistan. That treaty will remain in effect until new treaties with these in-dividual countries are negotiated and ratified. Provisions of the

Cate

gory

of P

erso

nal S

ervic

es

Coun

try(1

)Co

de1

(2)

Purp

ose 22

(3)

Maxim

um

Pres

ence

in

U.S.

(4)

Requ

ired E

mploy

er or

Pay

er(5

)

Maxim

um

Amou

nt of

Comp

ensa

tion

(6)

Trea

ty Ar

ticle

Cita

tion

(7)

Luxe

mbou

rg16

Ind

epen

dent

perso

nal s

ervice

s7..

....

....

....

.

No lim

it..

....

.

Any c

ontra

ctor.

....

....

....

....

....

..

No lim

it..

....

....

15

17

Depe

nden

t pers

onal

servi

ces12

, 17

....

....

....

..

183 d

ays

....

..

Any f

oreign

resid

ent.

....

....

....

....

..

No lim

it..

....

....

16

42

Publi

c ente

rtainm

ent.

....

....

....

....

....

....

No

limit

....

...

An

y U.S

. or fo

reign

resid

ent.

....

....

...

$1

0,000

p.a.25

....

18

18

Teac

hing o

r res

earch

9..

....

....

....

....

....

..

2 yea

rs..

....

.

Any U

.S. o

r forei

gn re

siden

t...

....

....

.

No lim

it..

....

....

21

(2)

19

Stud

ying a

nd tra

ining

:

Re

mitta

nces

or al

lowan

ces11

....

....

....

....

2 y

ears45

....

..

Any U

.S. o

r forei

gn re

siden

t...

....

....

.

No lim

it..

....

....

21

(1)

Malta

16

Indep

ende

nt pe

rsona

l serv

ices53

..

....

....

....

....

....

....

....

....

....

....

....

....

...

....

....

....

..

717

De

pend

ent p

erson

al se

rvice

s12, 1

7..

....

....

....

18

3 day

s..

....

An

y fore

ign re

siden

t...

....

....

....

....

No

limit

....

....

..

1442

Pu

blic e

nterta

inmen

t...

....

....

....

....

....

..

No lim

it..

....

.

Any U

.S. o

r forei

gn re

siden

t...

....

....

.

$20,0

00 p.

a.25..

..

1619

St

udyin

g and

traini

ng:

Remi

ttanc

es or

allow

ance

s ..

....

....

....

...

1

year45

....

..

Any f

oreign

resid

ent.

....

....

....

....

..

No lim

it..

....

....

20

(1)

Comp

ensa

tion d

uring

stud

y or tr

aining

....

....

No

limit

....

...

An

y U.S

. or fo

reign

resid

ent.

....

....

...

$9

,000 p

.a...

....

. 20

(2)

Comp

ensa

tion w

hile g

aining

expe

rienc

e..

....

No

limit

....

...

An

y U.S

. or fo

reign

resid

ent.

....

....

...

$9

,000 p

.a...

....

. 20

Mexic

o16

Ind

epen

dent

perso

nal s

ervice

s7..

....

....

....

.

182 d

ays

....

..

Any c

ontra

ctor.

....

....

....

....

....

..

No lim

it..

....

....

14

17

Depe

nden

t pers

onal

servi

ces17

, 47

....

....

....

..

183 d

ays

....

..

Any f

oreign

resid

ent.

....

....

....

....

..

No lim

it..

....

....

15

42

Publi

c ente

rtainm

ent.

....

....

....

....

....

....

No

limit

....

...

An

y U.S

. or fo

reign

resid

ent.

....

....

...

$3

,000 p

.a.30

....

.

1819

St

udyin

g and

traini

ng:

Remi

ttanc

es or

allow

ance

s ..

....

....

....

...

No

limit

....

...

An

y fore

ign re

siden

t...

....

....

....

....

No

limit

....

....

..

21Mo

rocc

o15

Sc

holar

ship

or fel

lowsh

ip gra

nt15..

....

....

....

.

5 yea

rs..

....

.

Any U

.S. o

r forei

gn re

siden

t5..

....

....

.

No lim

it..

....

....

18

16

Indep

ende

nt pe

rsona

l serv

ices7

....

....

....

...

18

2 day

s..

....

An

y con

tracto

r13..

....

....

....

....

....

$5

,000

....

....

..

1417

De

pend

ent p

erson

al se

rvice

s17..

....

....

....

..

182 d

ays

....

..

Moroc

can r

eside

nt13, 1

8..

....

....

....

..

No lim

it..

....

....

15

19

Stud

ying a

nd tra

ining

:5

Remi

ttanc

es or

allow

ance

s..

....

....

....

...

5 y

ears

....

...

An

y fore

ign re

siden

t...

....

....

....

....

No

limit

....

....

..

18

Co

mpen

satio

n duri

ng tra

ining

....

....

....

...

5 y

ears

....

...

U.

S. or

any f

oreign

resid

ent.

....

....

...

$2

,000 p

.a...

....

. 18

Page 49 of 61 Fileid: … ons/P901/201304/A/XML/Cycle02/source 10:02 - 11-Mar-2013The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

Publication 901 (April 2013) Page 49

Page 50: Treaties U.S. TaxTurkmenistan, and Uzbekistan. That treaty will remain in effect until new treaties with these in-dividual countries are negotiated and ratified. Provisions of the

Cate

gory

of P

erso

nal S

ervic

es

Coun

try(1

)Co

de1

(2)

Purp

ose 22

(3)

Maxim

um

Pres

ence

in

U.S.

(4)

Requ

ired E

mploy

er or

Pay

er(5

)

Maxim

um

Amou

nt of

Comp

ensa

tion

(6)

Trea

ty Ar

ticle

Cita

tion

(7)

Neth

erlan

ds15

Sc

holar

ship

or fel

lowsh

ip gra

nt15, 3

3..

....

....

...

3 y

ears

....

...

An

y U.S

. or fo

reign

resid

ent5

....

....

...

No

limit

....

....

..

22(2

)16

Ind

epen

dent

perso

nal s

ervice

s7..

....

....

....

.

No lim

it..

....

.

Any c

ontra

ctor.

....

....

....

....

....

..

No lim

it..

....

....

15

17

Depe

nden

t pers

onal

servi

ces17

, 47

....

....

....

..

183 d

ays

....

..

Any f

oreign

resid

ent.

....

....

....

....

..

No lim

it..

....

....

16

42

Publi

c ente

rtainm

ent.

....

....

....

....

....

....

No

limit

....

...

An

y U.S

. or fo

reign

resid

ent.

....

....

...

$1

0,000

p.a.25

....

18

18

Teac

hing4,

34..

....

....

....

....

....

....

....

..

2 yea

rs..

....

.

U.S.

educ

ation

al ins

titutio

n..

....

....

...

No

limit

....

....

..

21(1

)19

St

udyin

g and

traini

ng:33

Remi

ttanc

es or

allow

ance

s ..

....

....

....

...

Re

ason

able

pe

riod

....

....

..

Any f

oreign

resid

ent.

....

....

....

....

..

No lim

it..

....

....

22

(1)

Comp

ensa

tion w

hile g

aining

expe

rienc

e..

....

Re

ason

able

pe

riod

....

....

..

Any U

.S. o

r forei

gn re

siden

t...

....

....

.

$2,00

0 p.a.

....

...

22

(1)

Comp

ensa

tion w

hile r

ecipi

ent o

f sch

olarsh

ip

or fe

llows

hip gr

ant.

....

....

....

....

....

..

Reas

onab

le

perio

d..

....

....

An

y U.S

. or fo

reign

resid

ent.

....

....

...

$2

,000 p

.a.36

....

.

22(2

)Ne

w Ze

aland

16

Indep

ende

nt pe

rsona

l serv

ices53

..

....

....

....

....

....

....

....

....

....

....

....

....

....

...

....

....

....

7

17

Depe

nden

t pers

onal

servi

ces17

....

....

....

....

18

3 day

s..

....

An

y fore

ign re

siden

t...

....

....

....

....

No

limit

....

....

..

1542

Pu

blic e

nterta

inmen

t...

....

....

....

....

....

..

No lim

it..

....

.

Any U

.S. o

r forei

gn re

siden

t...

....

....

.

$10,0

0025

....

....

17

19

Stud

ying a

nd tra

ining

:

Re

mitta

nces

or al

lowan

ces11

....

....

....

....

No

limit

....

...

An

y fore

ign re

siden

t...

....

....

....

....

No

limit

....

....

..

20No

rway

15

Scho

larsh

ip or

fellow

ship

grant15

....

....

....

...

5 y

ears

....

...

An

y U.S

. or fo

reign

resid

ent5

....

....

...

No

limit

....

....

..

16(1

)16

Ind

epen

dent

perso

nal s

ervice

s7..

....

....

....

.

182 d

ays

....

..

Any c

ontra

ctor.

....

....

....

....

....

..

No lim

it..

....

....

13

42

Publi

c ente

rtainm

ent.

....

....

....

....

....

....

90

days

....

...

An

y con

tracto

r...

....

....

....

....

....

$1

0,000

p.a.28

....

13

17

Depe

nden

t pers

onal

servi

ces17

, 56

....

....

....

..

182 d

ays

....

..

Norw

egian

resid

ent18

....

....

....

....

..

No lim

it..

....

....

14

18

Teac

hing4

....

....

....

....

....

....

....

....

..

2 yea

rs..

....

.

U.S.

educ

ation

al ins

titutio

n..

....

....

...

No

limit

....

....

..

1519

St

udyin

g and

traini

ng:

Remi

ttanc

es or

allow

ance

s ..

....

....

....

...

5 y

ears

....

...

An

y fore

ign re

siden

t...

....

....

....

....

No

limit

....

....

..

16(1

)

Co

mpen

satio

n duri

ng tra

ining

....

....

....

...

5 y

ears

....

...

U.

S. or

any f

oreign

resid

ent.

....

....

...

$2

,000 p

.a...

....

.

16(1

)

Co

mpen

satio

n whil

e gain

ing ex

perie

nce2

....

.

12 co

nsec

. mo

....

....

....

..

Norw

egian

resid

ent.

....

....

....

....

..

$5,00

0..

....

....

. 16

(2)

Comp

ensa

tion u

nder

U.S.

Gove

rnmen

t prog

ram..

....

....

....

....

..

1 yea

r...

....

.

U.S.

Gov

ernme

nt or

its co

ntrac

tor..

....

.

$10,0

00..

....

...

16

(3)

Pakis

tan

15

Scho

larsh

ip or

fellow

ship

grant15

....

....

....

...

No

limit

....

...

Pa

kistan

i non

profi

t orga

nizati

on..

....

...

No lim

it..

....

....

XI

II(1)

16

Indep

ende

nt pe

rsona

l serv

ices16

....

....

....

...

18

3 day

s..

....

Pa

kistan

i resid

ent c

ontra

ctor.

....

....

..

No lim

it..

....

....

XI

17

Depe

nden

t pers

onal

servi

ces16

....

....

....

....

18

3 day

s..

....

Pa

kistan

i resid

ent.

....

....

....

....

....

No

limit

....

....

..

XI18

Te

achin

g..

....

....

....

....

....

....

....

....

.

2 yea

rs..

....

.

U.S.

educ

ation

al ins

titutio

n..

....

....

...

No

limit

....

....

..

XII

19

Stud

ying a

nd tra

ining

:

Re

mitta

nces

or al

lowan

ces

....

....

....

....

.

No lim

it..

....

.

Any f

oreign

resid

ent.

....

....

....

....

..

No lim

it..

....

....

XI

II(1)

Comp

ensa

tion d

uring

traini

ng .

....

....

....

..

No lim

it..

....

.

U.S.

or an

y fore

ign re

siden

t...

....

....

.

$5,00

0 p.a.

....

...

XI

II(1)

Comp

ensa

tion w

hile g

aining

expe

rienc

e2..

...

1 y

ear.

....

...

Pa

kistan

i resid

ent.

....

....

....

....

....

$6

,000

....

....

...

XIII(2

)

Co

mpen

satio

n whil

e und

er U.

S.

Go

vernm

ent p

rogram

....

....

....

....

....

No

limit

....

...

U.

S. G

overn

ment,

its co

ntrac

tor, o

r any

for

eign r

eside

nt em

ploye

r...

....

....

.

$10,0

00..

....

...

XI

II(3)

Page 50 of 61 Fileid: … ons/P901/201304/A/XML/Cycle02/source 10:02 - 11-Mar-2013The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

Page 50 Publication 901 (April 2013)

Page 51: Treaties U.S. TaxTurkmenistan, and Uzbekistan. That treaty will remain in effect until new treaties with these in-dividual countries are negotiated and ratified. Provisions of the

Cate

gory

of P

erso

nal S

ervic

es

Coun

try(1

)Co

de1

(2)

Purp

ose 22

(3)

Maxim

um

Pres

ence

in

U.S.

(4)

Requ

ired E

mploy

er or

Pay

er(5

)

Maxim

um

Amou

nt of

Comp

ensa

tion

(6)

Trea

ty Ar

ticle

Cita

tion

(7)

Philip

pine

s15

Sc

holar

ship

or fel

lowsh

ip gra

nt15..

....

....

....

.

5 yea

rs..

....

.

Any U

.S. o

r forei

gn re

siden

t5..

....

....

.

No lim

it..

....

....

22

(1)

16

Indep

ende

nt pe

rsona

l serv

ices7

....

....

....

...

89

days

....

...

An

y fore

ign co

ntrac

tor..

....

....

....

...

No

limit

....

....

..

15

89 da

ys..

....

.

Any U

.S. re

siden

t...

....

....

....

....

..

$10,0

00 p.

a...

...

15

17

Depe

nden

t pers

onal

servi

ces17

....

....

....

....

89

days

....

...

An

y Phil

ippine

s res

ident18

....

....

....

..

No lim

it..

....

....

16

42

Publi

c ente

rtainm

ent

....

....

....

....

....

....

. No

limit

....

...

An

y U.S

. or fo

reign

resid

ent.

....

....

...

$1

00 pe

r day

or

$3,00

0 p.a.

28, 5

0..

...

17

18

Teac

hing4,

38..

....

....

....

....

....

....

....

..

2 yea

rs..

....

.

U.S.

educ

ation

al ins

titutio

n..

....

....

...

No

limit

....

....

..

2119

St

udyin

g and

traini

ng:

Re

mitta

nces

or al

lowan

ces

....

....

....

....

.

5 yea

rs..

....

.

Any f

oreign

resid

ent.

....

....

....

....

..

No lim

it..

....

....

22

(1)

Comp

ensa

tion d

uring

stud

y..

....

....

....

...

5 y

ears

....

...

An

y U.S

. or fo

reign

resid

ent.

....

....

...

$3

,000 p

.a...

....

. 22

(1)

Comp

ensa

tion w

hile g

aining

expe

rienc

e2..

...

12

cons

ec.

mo..

....

....

....

Ph

ilippin

es re

siden

t...

....

....

....

....

$7

,500 p

.a...

....

. 22

(2)

Comp

ensa

tion w

hile u

nder

U.S.

Gove

rnmen

t prog

ram..

....

....

....

....

..

1 yea

r...

....

.

U.S.

Gov

ernme

nt or

its co

ntrac

tor..

....

.

$10,0

00 p.

a...

...

22

(3)

Polan

d15

Sc

holar

ship

or fel

lowsh

ip gra

nt15..

....

....

....

.

5 yea

rs..

....

.

Any U

.S. o

r forei

gn re

siden

t5..

....

....

.

No lim

it..

....

....

18

(1)

16

Indep

ende

nt pe

rsona

l serv

ices

....

....

....

....

18

2 day

s..

....

An

y con

tracto

r...

....

....

....

....

....

No

limit

....

....

..

1517

De

pend

ent p

erson

al se

rvice

s17..

....

....

....

..

182 d

ays

....

..

Any f

oreign

resid

ent.

....

....

....

....

..

No lim

it..

....

....

16

18

Teac

hing4,

41..

....

....

....

....

....

....

....

..

2 yea

rs..

....

.

U.S.

educ

ation

al ins

titutio

n..

....

....

...

No

limit

....

....

..

1719

St

udyin

g and

traini

ng:

Remi

ttanc

es or

allow

ance

s ..

....

....

....

...

5 y

ears

....

...

An

y fore

ign re

siden

t...

....

....

....

....

No

limit

....

....

..

18(1

)

Co

mpen

satio

n duri

ng tra

ining

...

....

....

....

5 y

ears

....

...

U.

S. or

any f

oreign

resid

ent.

....

....

...

$2

,000 p

.a...

....

. 18

(1)

Comp

ensa

tion w

hile g

aining

expe

rienc

e2..

...

1 y

ear.

....

...

Po

lish r

eside

nt..

....

....

....

....

....

.

$5,00

0..

....

....

18

(2)

Comp

ensa

tion w

hile u

nder

U.S.

Gove

rnmen

t prog

ram..

....

....

....

....

..

1 yea

r...

....

.

U.S.

Gov

ernme

nt or

its co

ntrac

tor..

....

.

$10,0

00..

....

...

18

(3)

Portu

gal

15

Scho

larsh

ip or

fellow

ship

grant15

....

....

....

...

5

years

....

...

An

y U.S

. or fo

reign

resid

ent5

....

....

...

No

limit

....

....

..

23(1

)16

Ind

epen

dent

perso

nal s

ervice

s7..

....

....

....

.

182 d

ays

....

..

Any c

ontra

ctor.

....

....

....

....

....

..

No lim

it..

....

....

15

17

Depe

nden

t pers

onal

servi

ces8,

17..

....

....

....

. 18

3 day

s..

....

An

y fore

ign re

siden

t...

....

....

....

....

No

limit

....

....

..

1642

Pu

blic e

nterta

inmen

t...

....

....

....

....

....

..

No lim

it..

....

.

Any U

.S. o

r forei

gn re

siden

t...

....

....

.

$10,0

00 p.

a.30..

..

1918

Te

achin

g4, 42

....

....

....

....

....

....

....

....

2 y

ears

....

...

U.

S. ed

ucati

onal

institu

tion

....

....

....

.

No lim

it..

....

....

22

19

Stud

ying a

nd tra

ining

:4

Remi

ttanc

es or

allow

ance

s ..

....

....

....

...

5 y

ears

....

...

An

y fore

ign re

siden

t...

....

....

....

....

No

limit

....

....

..

23(1

)

Co

mpen

satio

n duri

ng st

udy o

r train

ing .

....

..

12 co

nsec

. mo

s...

....

....

..

Portu

gues

e res

ident

....

....

....

....

..

$8,00

0..

....

....

23

(2)

5 y

ears

....

...

Ot

her fo

reign

or U

.S. re

siden

t...

....

...

$5

,000 p

.a...

....

. 23

(1)

Comp

ensa

tion w

hile g

aining

expe

rienc

e2..

...

12

cons

ec.

mos.

....

....

....

Po

rtugu

ese r

eside

nt..

....

....

....

....

$8

,000

....

....

..

23(2

)

Page 51 of 61 Fileid: … ons/P901/201304/A/XML/Cycle02/source 10:02 - 11-Mar-2013The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

Publication 901 (April 2013) Page 51

Page 52: Treaties U.S. TaxTurkmenistan, and Uzbekistan. That treaty will remain in effect until new treaties with these in-dividual countries are negotiated and ratified. Provisions of the

Cate

gory

of P

erso

nal S

ervic

es

Coun

try(1

)Co

de1

(2)

Purp

ose 22

(3)

Maxim

um

Pres

ence

in

U.S.

(4)

Requ

ired E

mploy

er or

Pay

er(5

)

Maxim

um

Amou

nt of

Comp

ensa

tion

(6)

Trea

ty Ar

ticle

Cita

tion

(7)

Roma

nia15

Sc

holar

ship

or fel

lowsh

ip gra

nt15..

....

....

....

.

5 yea

rs..

....

.

Any U

.S. o

r forei

gn re

siden

t5..

....

....

.

No lim

it..

....

....

20

(1)

16

Indep

ende

nt pe

rsona

l serv

ices

....

....

....

....

18

2 day

s..

....

An

y con

tracto

r...

....

....

....

....

....

No

limit

....

....

..

1442

Publi

c ente

rtainm

ent.

....

....

....

....

....

..

90 da

ys..

....

.

Any c

ontra

ctor.

....

....

....

....

....

..

$3,00

0 p.a.

28..

...

14

17

Depe

nden

t pers

onal

servi

ces17

....

....

....

....

18

2 day

s..

....

Ro

mania

n res

ident18

....

....

....

....

..

No lim

it..

....

....

15

42

Pu

blic e

nterta

inmen

t...

....

....

....

....

....

89

days

....

...

An

y U.S

. or fo

reign

resid

ent.

....

....

...

$2

,999.9

9 p.a

.28..

....

....

...

15

18

Teac

hing4

....

....

....

....

....

....

....

....

..

2 yea

rs..

....

.

U.S.

educ

ation

al ins

titutio

n..

....

....

...

No

limit

....

....

..

1919

St

udyin

g and

traini

ng:

Remi

ttanc

es or

allow

ance

s ..

....

....

....

...

5 y

ears

....

...

An

y fore

ign re

siden

t...

....

....

....

....

No

limit

....

....

..

20(1

)

Co

mpen

satio

n duri

ng tra

ining

...

....

....

....

5 y

ears

....

...

U.

S. or

any f

oreign

resid

ent.

....

....

...

$2

,000 p

.a...

....

20

(1)

Comp

ensa

tion w

hile g

aining

expe

rienc

e2..

...

1 y

ear.

....

...

Ro

mania

n res

ident

....

....

....

....

....

$5

,000

....

....

..

20(2

)

Co

mpen

satio

n whil

e und

er U.

S.

Go

vernm

ent p

rogram

....

....

....

....

....

1 y

ear.

....

...

U.

S. G

overn

ment

or its

contr

actor

....

...

$1

0,000

....

....

.

20(3

)Ru

ssia

15

Scho

larsh

ip or

fellow

ship

grant4,

15, 4

1..

....

....

.

5 yea

rs31..

....

An

y U.S

. or fo

reign

resid

ent5

....

....

...

No

limit

....

....

..

1816

Ind

epen

dent

perso

nal s

ervice

s7..

....

....

....

.

183 d

ays

....

..

Any c

ontra

ctor.

....

....

....

....

....

..

No lim

it..

....

....

13

17

Depe

nden

t pers

onal

servi

ces8,

17, 3

2..

....

....

..

183 d

ays

....

..

Any f

oreign

resid

ent.

....

....

....

....

..

No lim

it..

....

....

14

19

Stud

ying a

nd tra

ining

:4

Remi

ttanc

es or

allow

ance

s..

....

....

....

...

5 y

ears31

....

..

Any f

oreign

resid

ent.

....

....

....

....

..

No lim

it..

....

....

18

Slov

ak R

epub

lic15

Sc

holar

ship

or fel

lowsh

ip gra

nt4, 15

....

....

....

.

5 yea

rs..

....

.

Any U

.S. o

r forei

gn re

siden

t5..

....

....

.

No lim

it..

....

....

21

(1)

16

Indep

ende

nt pe

rsona

l serv

ices7

....

....

....

...

18

3 day

s..

....

An

y con

tracto

r...

....

....

....

....

....

No

limit

....

....

..

1417

De

pend

ent p

erson

al se

rvice

s12, 1

7..

....

....

....

18

3 day

s..

....

An

y fore

ign re

siden

t...

....

....

....

....

No

limit

....

....

..

1542

Pu

blic e

nterta

inmen

t...

....

....

....

....

....

..

No lim

it..

....

.

Any U

.S. o

r forei

gn re

siden

t...

....

....

.

$20,0

00 p.

a.30..

..

1818

Te

achin

g4, 35

....

....

....

....

....

....

....

....

2 y

ears

....

...

An

y U.S

. edu

catio

nal o

r

resea

rch in

stitut

ion..

....

....

....

....

. No

limit

....

....

..

21(5

)19

St

udyin

g and

traini

ng:4

Remi

ttanc

es or

allow

ance

s ..

....

....

....

...

5 y

ears

....

...

An

y fore

ign re

siden

t...

....

....

....

....

No

limit

....

....

..

21(1

)

Co

mpen

satio

n duri

ng tra

ining

...

....

....

....

5 y

ears

....

...

An

y U.S

. or a

ny fo

reign

resid

ent.

....

...

$5

,000 p

.a...

....

21

(1)

Comp

ensa

tion w

hile g

aining

expe

rienc

e2..

...

12

cons

ec.

mos.

....

....

....

Slo

vak r

eside

nt..

....

....

....

....

....

.

$8,00

0..

....

....

21

(2)

Comp

ensa

tion w

hile u

nder

U.S.

Gove

rnmen

t prog

ram..

....

....

....

....

..

1 yea

r...

....

.

U.S.

Gov

ernme

nt..

....

....

....

....

...

$1

0,000

....

....

.

21(3

)Sl

oven

ia15

Sc

holar

ship

or fel

lowsh

ip gra

nt4..

....

....

....

.

5 yea

rs10..

....

An

y U.S

. or fo

reign

resid

ent5

....

....

...

No

limit

....

....

..

20(1

)16

Ind

epen

dent

perso

nal s

ervice

s7..

....

....

....

.

No lim

it..

....

.

Any c

ontra

ctor.

....

....

....

....

....

..

No lim

it..

....

....

14

17

Depe

nden

t pers

onal

servi

ces12

, 17

....

....

....

..

183 d

ays

....

..

Any f

oreign

resid

ent.

....

....

....

....

..

No lim

it..

....

....

15

42

Publi

c ente

rtainm

ent.

....

....

....

....

....

....

No

limit

....

...

An

y U.S

. or fo

reign

resid

ent.

....

....

...

$1

5,000

p.a.30

....

17

18

Teac

hing o

r res

earch

4..

....

....

....

....

....

..

2 yea

rs40..

....

An

y U.S

. or fo

reign

resid

ent.

....

....

...

No

limit

....

....

..

20(3

)19

St

udyin

g and

traini

ng:4

Remi

ttanc

es or

allow

ance

s ..

....

....

....

...

5 y

ears10

....

..

Any f

oreign

resid

ent.

....

....

....

....

..

No lim

it..

....

....

20

(1)

Comp

ensa

tion d

uring

traini

ng .

....

....

....

..

12 m

os..

....

..

Slove

nian r

eside

nt..

....

....

....

....

..

$8,00

0..

....

....

20

(2)

5 y

ears10

....

..

Othe

r forei

gn or

U.S

. resid

ent.

....

....

.

$5,00

0 p.a.

....

..

20(1

)

Co

mpen

satio

n whil

e gain

ing ex

perie

nce2

....

.

12 m

os..

....

..

Slove

nian r

eside

nt..

....

....

....

....

..

$8,00

0..

....

....

20

(2)

Page 52 of 61 Fileid: … ons/P901/201304/A/XML/Cycle02/source 10:02 - 11-Mar-2013The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

Page 52 Publication 901 (April 2013)

Page 53: Treaties U.S. TaxTurkmenistan, and Uzbekistan. That treaty will remain in effect until new treaties with these in-dividual countries are negotiated and ratified. Provisions of the

Cate

gory

of P

erso

nal S

ervic

es

Coun

try(1

)Co

de1

(2)

Purp

ose 22

(3)

Maxim

um

Pres

ence

in

U.S.

(4)

Requ

ired E

mploy

er or

Pay

er(5

)

Maxim

um

Amou

nt of

Comp

ensa

tion

(6)

Trea

ty Ar

ticle

Cita

tion

(7)

Sout

h Afri

ca16

Ind

epen

dent

perso

nal s

ervice

s7..

....

....

....

.

183 d

ays

....

..

Any c

ontra

ctor.

....

....

....

....

....

..

No lim

it..

....

...

14

17

Depe

nden

t pers

onal

servi

ces12

, 17

....

....

....

..

183 d

ays

....

..

Any f

oreign

resid

ent.

....

....

....

....

..

No lim

it..

....

...

15

42

Publi

c ente

rtainm

ent.

....

....

....

....

....

....

No

limit

....

...

An

y U.S

. or fo

reign

resid

ent.

....

....

...

$7

,500 p

.a.30

....

.

1719

St

udyin

g and

traini

ng:

Remi

ttanc

es or

allow

ance

s11..

....

....

....

..

1 yea

r45..

....

.

Any f

oreign

resid

ent.

....

....

....

....

..

No lim

it..

....

...

20

Spain

15

Scho

larsh

ip or

fellow

ship

grant4,

15..

....

....

...

5 y

ears

....

...

An

y U.S

. or fo

reign

resid

ent5

....

....

...

No

limit

....

....

.

22(1

)16

Ind

epen

dent

perso

nal s

ervice

s7..

....

....

....

.

No lim

it..

....

.

Any c

ontra

ctor.

....

....

....

....

....

..

No lim

it..

....

...

15

17

Depe

nden

t pers

onal

servi

ces17

....

....

....

....

18

3 day

s..

....

An

y fore

ign re

siden

t...

....

....

....

....

No

limit

....

....

.

1642

Pu

blic e

nterta

inmen

t...

....

....

....

....

....

..

No lim

it..

....

.

Any U

.S. o

r forei

gn re

siden

t...

....

....

.

$10,0

00 p.

a.30..

..

1919

St

udyin

g and

traini

ng:4

Remi

ttanc

es or

allow

ance

s ..

....

....

....

...

5 y

ears

....

...

An

y fore

ign re

siden

t...

....

....

....

....

No

limit

....

....

.

22(1

)

Co

mpen

satio

n duri

ng tra

ining

....

....

....

...

5 y

ears

....

...

An

y U.S

. or fo

reign

resid

ent.

....

....

...

$5

,000 p

.a...

....

22

(1)

Comp

ensa

tion w

hile g

aining

expe

rienc

e2..

...

12

cons

ec.

mo..

....

....

....

Sp

anish

resid

ent.

....

....

....

....

....

$8

,000

....

....

..

22(2

)Sr

i Lan

ka16

Ind

epen

dent

perso

nal s

ervice

s7, 12

....

....

....

.

183 d

ays

....

..

Any c

ontra

ctor.

....

....

....

....

....

..

No lim

it..

....

...

15

17

Depe

nden

t pers

onal

servi

ces12

, 17

....

....

....

..

183 d

ays

....

..

Any f

oreign

resid

ent.

....

....

....

....

..

No lim

it..

....

...

16

42

Publi

c ente

rtainm

ent.

....

....

....

....

....

....

No

limit

....

...

An

y U.S

. or fo

reign

resid

ent.

....

....

...

$6

,000 p

.a.30

....

.

1819

St

udyin

g and

traini

ng:

Remi

ttanc

es or

allow

ance

s11..

....

....

....

..

No lim

it..

....

.

Any f

oreign

resid

ent.

....

....

....

....

..

No lim

it..

....

...

21

(1)

Comp

ensa

tion w

hile g

aining

expe

rienc

e2..

...

1 y

ear.

....

...

Sr

i Lan

kan r

eside

nt19..

....

....

....

....

$6

,000

....

....

..

21(2

)Sw

eden

16

Indep

ende

nt pe

rsona

l serv

ices7

....

....

....

...

No

limit

....

...

An

y con

tracto

r...

....

....

....

....

....

No

limit

....

....

.

1417

De

pend

ent p

erson

al se

rvice

s12, 1

7..

....

....

....

18

3 day

s..

....

An

y fore

ign re

siden

t...

....

....

....

....

No

limit

....

....

.

1542

Pu

blic e

nterta

inmen

t...

....

....

....

....

....

..

No lim

it..

....

.

Any U

.S. o

r forei

gn re

siden

t...

....

....

.

$6,00

025..

....

..

1819

St

udyin

g and

traini

ng:

Remi

ttanc

es or

allow

ance

s 11..

....

....

....

..

No lim

it..

....

.

Any f

oreign

resid

ent.

....

....

....

....

..

No lim

it..

....

...

21

Switz

erlan

d16

Ind

epen

dent

perso

nal s

ervice

s7..

....

....

....

.

No lim

it..

....

.

Any c

ontra

ctor.

....

....

....

....

....

..

No lim

it..

....

...

14

17

Depe

nden

t pers

onal

servi

ces8,

17..

....

....

....

. 18

3 day

s..

....

An

y fore

ign re

siden

t...

....

....

....

....

No

limit

....

....

.

1542

Pu

blic e

nterta

inmen

t...

....

....

....

....

....

..

No lim

it..

....

.

Any U

.S. o

r forei

gn re

siden

t...

....

....

.

$10,0

00 p.

a.25..

..

1719

St

udyin

g and

traini

ng:

R

emitta

nces

or al

lowan

ces 11

....

....

....

....

.

No lim

it..

....

.

Any f

oreign

resid

ent.

....

....

....

....

..

No lim

it..

....

...

20

Page 53 of 61 Fileid: … ons/P901/201304/A/XML/Cycle02/source 10:02 - 11-Mar-2013The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

Publication 901 (April 2013) Page 53

Page 54: Treaties U.S. TaxTurkmenistan, and Uzbekistan. That treaty will remain in effect until new treaties with these in-dividual countries are negotiated and ratified. Provisions of the

Cate

gory

of P

erso

nal S

ervic

es

Coun

try(1

)Co

de1

(2)

Purp

ose 22

(3)

Maxim

um

Pres

ence

in

U.S.

(4)

Requ

ired E

mploy

er or

Pay

er(5

)

Maxim

um

Amou

nt of

Comp

ensa

tion

(6)

Trea

ty Ar

ticle

Cita

tion

(7)

Thail

and

15

Scho

larsh

ip or

fellow

ship

grant

....

....

....

....

5 y

ears

....

...

An

y U.S

. or fo

reign

resid

ent5

....

....

...

No

limit

....

....

..

22(1

)16

Ind

epen

dent

perso

nal s

ervice

s7..

....

....

....

.

89 da

ys..

....

.

Any U

.S. re

siden

t or p

erman

ent

estab

lishm

ent.

....

....

....

....

....

....

.

$10,0

00 p.

a...

...

15

89

days

....

...

An

y fore

ign co

ntrac

tor..

....

....

....

...

No

limit49

....

....

15

17

Depe

nden

t pers

onal

servi

ces17

, 47

....

....

....

..

183 d

ays

....

..

Any f

oreign

resid

ent.

....

....

....

....

..

No lim

it..

....

....

16

42

Publi

c ente

rtainm

ent

....

....

....

....

....

....

. No

limit

....

...

An

y U.S

. or fo

reign

resid

ent.

....

....

...

$1

00 pe

r day

or

$3,00

0 p.a.

48..

....

.

1918

Te

achin

g or r

esea

rch4,

38..

....

....

....

....

....

2 y

ears

....

...

An

y U.S

. or fo

reign

resid

ent.

....

....

...

No

limit

....

....

..

2319

St

udyin

g and

traini

ng:

Remi

ttanc

es or

allow

ance

s ..

....

....

....

...

5 y

ears

....

...

An

y fore

ign re

siden

t...

....

....

....

....

No

limit

....

....

..

22(1

)

Co

mpen

satio

n duri

ng tra

ining

....

....

....

...

5 y

ears.

....

...

An

y U.S

. or fo

reign

resid

ent.

....

....

...

$3

,000 p

.a...

....

22

(1)

Comp

ensa

tion w

hile g

aining

expe

rienc

e..

....

12

cons

ec.

mos.

....

....

....

Th

ai res

ident2

....

....

....

....

....

....

$7

,500 p

.a...

....

22

(2)

Comp

ensa

tion u

nder

U.S.

Gove

rnmen

t prog

ram..

....

....

....

....

..

1 yea

r...

....

.

U.S.

Gov

ernme

nt..

....

....

....

....

...

$1

0,000

....

....

.

22(3

)Tr

inida

d and

Toba

go15

Sc

holar

ship

or fel

lowsh

ip gra

nt15..

....

....

....

.

5 yea

rs..

....

.

Any U

.S. o

r forei

gn re

siden

t5..

....

....

.

No lim

it..

....

....

19

(1)

16

Indep

ende

nt pe

rsona

l serv

ices14

....

....

....

...

18

3 day

s..

....

An

y fore

ign re

siden

t con

tracto

r...

....

..

No lim

it..

....

....

17

18

3 day

s..

....

An

y U.S

. con

tracto

r...

....

....

....

....

$3

,0006

....

....

.

1717

De

pend

ent p

erson

al se

rvice

s14..

....

....

....

..

183 d

ays

....

..

Any f

oreign

resid

ent.

....

....

....

....

..

No lim

it..

....

....

17

183 d

ays

....

..

Any U

.S. re

siden

t...

....

....

....

....

..

$3,00

06..

....

...

17

18

Teac

hing4

....

....

....

....

....

....

....

....

..

2 yea

rs..

....

.

U.S.

educ

ation

al ins

titutio

n or U

.S.

Gove

rnmen

t...

....

....

....

....

....

....

No

limit

....

....

..

1819

St

udyin

g and

traini

ng:

Remi

ttanc

es or

allow

ance

s ..

....

....

....

...

5 y

ears

....

...

An

y fore

ign re

siden

t...

....

....

....

....

No

limit

....

....

..

19(1

)

Co

mpen

satio

n duri

ng st

udy o

r res

earch

....

..

5 yea

rs...

....

.

U.S

. or a

ny fo

reign

resid

ent.

....

....

...

$2

,000 p

.a.6

....

..

19(1

)

Co

mpen

satio

n duri

ng pr

ofess

ional

traini

ng..

..

5 yea

rs..

....

.

U.S

. or a

ny fo

reign

resid

ent.

....

....

...

$5

,000 p

.a.6

....

..

19(1

)

Co

mpen

satio

n whil

e gain

ing ex

perie

nce

....

..

1 yea

r...

....

.

Trini

dad–

Toba

go re

siden

t2..

....

....

...

$5

,0006

....

....

.

19(2

)

Co

mpen

satio

n und

er U.

S.

Go

vernm

ent p

rogram

....

....

....

....

....

1 y

ear.

....

...

U.

S. G

overn

ment

or its

contr

actor

....

...

$1

0,000

6..

....

..

19(3

)Tu

nisia

15

Scho

larsh

ip an

d fell

owsh

ip gra

nt11, 1

5..

....

....

.

5 yea

rs..

....

.

Any U

.S. o

r forei

gn re

siden

t5..

....

....

.

No lim

it..

....

....

20

16

Indep

ende

nt pe

rsona

l serv

ices7

....

....

....

...

18

3 day

s..

....

U.

S. re

siden

t con

tracto

r...

....

....

....

$7

,500 p

.a...

....

14

17

Depe

nden

t pers

onal

servi

ces17

....

....

....

....

18

3 day

s..

....

An

y fore

ign re

siden

t...

....

....

....

....

No

limit

....

....

..

1542

Pu

blic e

nterta

inmen

t...

....

....

....

....

....

..

No lim

it..

....

.

Any U

.S. o

r forei

gn re

siden

t...

....

....

.

$7,50

0 p.a.

25..

...

17

19

Stud

ying a

nd tra

ining

:11

Remi

ttanc

es or

allow

ance

s ..

....

....

....

...

5 y

ears

....

...

An

y fore

ign re

siden

t...

....

....

....

....

No

limit

....

....

..

20

Co

mpen

satio

n duri

ng tra

ining

....

....

....

...

5 y

ears

....

...

An

y U.S

. or fo

reign

resid

ent.

....

....

...

$4

,000 p

.a...

....

20

Turk

ey16

Ind

epen

dent

perso

nal s

ervice

s7..

....

....

....

.

183 d

ays

....

..

Any c

ontra

ctor.

....

....

....

....

....

..

No lim

it..

....

....

14

17

Depe

nden

t pers

onal

servi

ces12

, 17

....

....

....

..

183 d

ays

....

..

Any f

oreign

resid

ent.

....

....

....

....

..

No lim

it..

....

....

15

42

Publi

c ente

rtainm

ent.

....

....

....

....

....

....

No

limit

....

...

An

y U.S

. or fo

reign

resid

ent.

....

....

...

$3

,000 p

.a. 48

....

17

18

Teac

hing o

r res

earch

....

....

....

....

....

....

2 y

ears

....

...

An

y fore

ign re

siden

t...

....

....

....

....

No

limit

....

....

..

20(2

)19

St

udyin

g and

traini

ng:

Remi

ttanc

es or

allow

ance

s11..

....

....

....

..

No lim

it..

....

.

Any f

oreign

resid

ent.

....

....

....

....

..

No lim

it..

....

....

20

(1)

Page 54 of 61 Fileid: … ons/P901/201304/A/XML/Cycle02/source 10:02 - 11-Mar-2013The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

Page 54 Publication 901 (April 2013)

Page 55: Treaties U.S. TaxTurkmenistan, and Uzbekistan. That treaty will remain in effect until new treaties with these in-dividual countries are negotiated and ratified. Provisions of the

Cate

gory

of P

erso

nal S

ervic

es

Coun

try(1

)Co

de1

(2)

Purp

ose 22

(3)

Maxim

um

Pres

ence

in

U.S.

(4)

Requ

ired E

mploy

er or

Pay

er(5

)

Maxim

um

Amou

nt of

Comp

ensa

tion

(6)

Trea

ty Ar

ticle

Cita

tion

(7)

Ukra

ine15

Sc

holar

ship

or fel

lowsh

ip gra

nt41..

....

....

....

.

5 yea

rs31..

....

An

y U.S

. or fo

reign

resid

ent5

....

....

...

No

limit

....

....

..

2016

Ind

epen

dent

perso

nal s

ervice

s3, 7

....

....

....

..

No lim

it..

....

.

Any c

ontra

ctor.

....

....

....

....

....

..

No lim

it..

....

....

14

17

Depe

nden

t pers

onal

servi

ces3,

17..

....

....

....

. 18

3 day

s..

....

An

y fore

ign re

siden

t...

....

....

....

....

No

limit

....

....

..

1519

St

udyin

g and

traini

ng:

Remi

ttanc

es or

allow

ance

s4..

....

....

....

...

5 y

ears31

....

..

Any f

oreign

resid

ent.

....

....

....

....

..

No lim

it..

....

....

20

Unite

d King

dom

16

Indep

ende

nt pe

rsona

l serv

ices53

....

....

....

....

....

....

...

....

....

....

....

....

....

....

...

....

....

....

7

17

Depe

nden

t pers

onal

servi

ces12

, 17

....

....

....

..

183 d

ays

....

..

Any f

oreign

resid

ent.

....

....

....

....

..

No lim

it..

....

....

14

42

Publi

c ente

rtainm

ent.

....

....

....

....

....

....

No

limit

....

...

An

y U.S

. or fo

reign

resid

ent.

....

....

...

$2

0,000

p.a.25

....

16

18

Teac

hing o

r res

earch

4..

....

....

....

....

....

..

2 yea

rs..

....

.

Any U

.S. e

duca

tiona

l insti

tution

....

....

.

No lim

it..

....

....

20

A19

St

udyin

g and

traini

ng:

Remi

ttanc

es or

allow

ance

s11..

....

....

....

..

1 yea

r45..

....

.

Any f

oreign

resid

ent.

....

....

....

....

..

No lim

it..

....

....

20

Vene

zuela

15

Scho

larsh

ip or

fellow

ship

grants

4..

....

....

....

5 y

ears10

....

..

Any U

.S. o

r forei

gn re

siden

t5..

....

....

.

No lim

it..

....

....

21

(1)

16

Indep

ende

nt pe

rsona

l serv

ices7,

12..

....

....

...

No

limit

....

...

An

y con

tracto

r...

....

....

....

....

....

No

limit

....

....

..

1417

De

pend

ent p

erson

al se

rvice

s12, 1

7..

....

....

....

18

3 day

s..

....

An

y fore

ign re

siden

t...

....

....

....

....

No

limit

....

....

..

1542

Pu

blic e

nterta

inmen

t...

....

....

....

....

....

..

No lim

it..

....

.

Any U

.S. o

r forei

gn re

siden

t...

....

....

.

$6,00

0 p.a.

30..

...

18

18

Teac

hing4

....

....

....

....

....

....

....

....

..

2 yea

rs40..

....

An

y U.S

. or fo

reign

resid

ent.

....

....

...

No

limit

....

....

..

21(3

)19

St

udyin

g and

traini

ng:4

Remi

ttanc

es or

allow

ance

s ..

....

....

....

...

5 y

ears10

....

..

Any f

oreign

resid

ent.

....

....

....

....

..

No lim

it..

....

....

21

(1)

Comp

ensa

tion d

uring

traini

ng .

....

....

....

..

12 m

os..

....

..

Vene

zuela

n res

ident

....

....

....

....

..

$8,00

0 ..

....

....

21

(2)

5 y

ears10

....

..

Othe

r forei

gn or

U.S

. resid

ent.

....

....

.

$5,00

0 p.a.

....

...

21

(1)

Comp

ensa

tion w

hile g

aining

expe

rienc

e..

....

12

mos

....

....

Ve

nezu

elan r

eside

nt2..

....

....

....

...

$8

,000

....

....

...

21(2

)

Page 55 of 61 Fileid: … ons/P901/201304/A/XML/Cycle02/source 10:02 - 11-Mar-2013The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

Publication 901 (April 2013) Page 55

Page 56: Treaties U.S. TaxTurkmenistan, and Uzbekistan. That treaty will remain in effect until new treaties with these in-dividual countries are negotiated and ratified. Provisions of the

1 Refers to income code numbers under which the income is reported on Forms 1042-S. Personal services must be performed by a nonresident alien individual who is a resident of the specified treaty country.

2 Applies only if training or experience is received from a person other than alien's employer.3 The exemption does not apply to income received for performing services in the United States as an entertainer or a sportsman. However, this

income is exempt for U.S. income tax if the visit is (a) substantially supported by public funds of Ukraine, its political subdivisions, or local authorities, or (b) made under a specific arrangement agreed to by the governments of the treaty countries.

4 Does not apply to compensation for research work primarily for private benefit.5 Grant must be from a nonprofit organization. In many cases, the exemption also applies to amounts from either the U.S. or foreign government. For

Indonesia and the Netherlands, the exemption also applies if the amount is awarded under a technical assistance program entered into by the United States or the foreign government, or its political subdivisions or local authorities.

6 Reimbursed expenses are not taken into account in figuring any maximum compensation to which the exemption applies. For Japan and Trinidad and Tobago, only reimbursed travel expenses are disregarded in figuring the maximum compensation.

7 Exemption does not apply to the extent income is attributable to the recipient's fixed U.S. base. For residents of Korea and Norway, the fixed base must be maintained for more than 182 days (for Norway, 30 days in the case of the exploration or exploitation of the seabed and sub-soil and their natural resources); for residents of Morocco, the fixed base must be maintained for more than 89 days.

8 Does not apply to fees paid to a director of a U.S. corporation.9 Does not apply to compensation for research work for other than the U.S. educational institution (or, for Italy, a medical facility that is primarily

publicly funded) involved. 10 Applies to any additional period that a full-time student needs to complete the educational requirements as a candidate for a postgraduate or

professional degree from a recognized educational institution. 11 Applies only to full-time student or trainee. 12 Fees paid to a resident of the treaty country for services performed in the United States as a director of a U.S. corporation are subject to U.S. tax. 13 Exemption does not apply if, during the immediately preceding period, such individual claimed the benefits of Article 23(1).14 Does not apply to compensation paid to public entertainers that is more than $100 a day. 15 Does not apply to payments from the National Institutes of Health under its Visiting Associate Program and Visiting Scientist Program.16 Exemption applies only if the compensation is subject to tax in the country of residence. 17 The exemption does not apply if the employee's compensation is borne by a permanent establishment (or in some cases a fixed base) that the

employer has in the United States. 18 The exemption also applies if the employer is a permanent establishment in the treaty country but is not a resident of the treaty country. 19 Applies also to a participant in a program sponsored by the U.S. Government or an international organization. 20 The exemption is also extended to journalists and correspondents who are temporarily in the U.S. for periods not longer than 2 years and who

receive compensation from abroad. 21 Also exempt are amounts of up to $10,000 received from U.S. sources to provide ordinary living expenses. For students, the amount will be less than

$10,000, determined on a case by case basis. 22 Withholding may be required if the factors on which the treaty exemption is based may not be determinable until after the close of the tax year.

Athletes and entertainers may be able to enter into a central withholding agreement with the IRS for reduced withholding provided certain requirements are met.

23 A student or trainee may choose to be treated as a U.S. resident for tax purposes. If the choice is made, it may not be changed without the consent of the U.S. competent authority.

24 Does not apply to amounts received in excess of reasonable fees payable to all directors of the company for attending meetings in the United States.25 Exemption does not apply if gross receipts (including reimbursements) exceed this amount.26 Exemption does not apply if net income exceeds this amount.27 Exemption does not apply to payments borne by a permanent establishment in the United States or paid by a U.S. citizen or resident or the federal,

state, or local government.28 Exemption does not apply if compensation (or gross income for the Phillippines and Romania) exceeds this amount.29 The exemption applies only to income from activities performed under special cultural exchange programs agreed to by the U.S. and Chinese

governments.30 Exemption does not apply if gross receipts (or compensation for Portugal and Venezuela), including reimbursements, exceed this amount. Income is

fully exempt if visit to the United States is substantially supported by public funds of the treaty country or its political subdivisions or local authorities.31 The 5-year limit pertains only to training or research.32 Compensation from employment directly connected with a place of business that is not a permanent establishment is exempt if the alien is present in

the United States for a period not exceeding 12 consecutive months. Compensation for technical services directly connected with the application of a right or property giving rise to a royalty is exempt if the services are provided as part of a contract granting the use of the right or property.

33 Exemption does not apply if, during the immediately preceding period, the individual claimed the benefits of Article 21.34 Exemption does not apply if, during the immediately preceding period, the individual claimed the benefits of Article 22.35 Exemption does not apply if the individual either (a) claimed the benefit of Article 21(5) during a previous visit, or (b) during the immediately

preceding period, claimed the benefit of Article 21(1), (2), or (3).36 Exemption applies only to compensation for personal services performed in connection with, or incidental to, the individual's study, research, or

training.37 If the compensation exceeds $400 per day, the entertainer may be taxed on the full amount. If the individual receives a fixed amount for more than

one performance, the amount is prorated over the number of days the individual performs the services (including rehearsals).38 Exemption does not apply if, during the immediately preceding period, the individual claimed the benefits of Article 22(1).39 Exemption does not apply if, during the immediately preceding period, the individual claimed the benefits of Article 24(1). 40 The combined benefit for teaching cannot exceed 5 years. 41 Exemption does not apply if, during the immediately preceding period, the individual claimed the benefits of Article 18(1).42 Exemption does not apply if the individual either (a) previously claimed the benefit of this Article, or (b) during the immediately preceding period,

claimed the benefit of Article 23. The benefits under Articles 22 and 23 cannot be claimed at the same time. 43 The combined period of benefits under Articles 20 and 21(1) cannot exceed 5 years. 44 Exemption does not apply if the individual previously claimed the benefit of this Article.45 The time limit pertains only to an apprentice or business trainee. 46 Exemption does not apply if gross receipts exceed this amount.

Page 56 of 61 Fileid: … ons/P901/201304/A/XML/Cycle02/source 10:02 - 11-Mar-2013The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

Page 56 Publication 901 (April 2013)

Page 57: Treaties U.S. TaxTurkmenistan, and Uzbekistan. That treaty will remain in effect until new treaties with these in-dividual countries are negotiated and ratified. Provisions of the

47 Fees paid to a resident of the treaty country for services as a director of a U.S. corporation are subject to U.S. tax, unless the services are performed in the country of residence.

48 Exemption does not apply if gross receipts exceed this amount. Income is fully exempt if visit to the United States is substantially supported by public funds of the treaty country or its political subdivisions or local authorities.

49 A $10,000 limit applies if the expense is borne by a permanent establishment or a fixed base in the United States. Exemption does not apply if the recipient maintains a permanent establishment in the U.S. with which the income is effectively connected.

50 This provision does not apply if these activities are substantially supported by a nonprofit organization or by public funds of the treaty country or its political subdivisions or local authorities. For Indonesia and the Phillipines, the competent authority of the sending state must certify that the visit qualifies.

51 Exemption does not apply if gross receipts, including reimbursements, exceed this amount during the year. Income is fully exempt if visit is wholly or mainly supported by public funds of one or both of the treaty countries or their political subdivisions or local authorities.

52 Exemption applies to a business apprentice (trainee) only for a period not exceeding 1 year (2 years for Belgium and Bulgaria) from the date of arrival in the United States.

53 Treated as business profits under Article 7 (VII) of the treaty. 54 Employment with a team which participates in a league with regularly scheduled games in both countries is covered under the provisions for

dependent personal services.55 Exemption does not apply if during the immediately preceding period, the individual claimed the benefit of Article 20(2), (3), or (4).56 Labor or personal services performed in connection with the exploration or exploitation of the seabed and sub-soil and their natural resources is fully

exempt for a period of 60 days in the tax year.

Page 57 of 61 Fileid: … ons/P901/201304/A/XML/Cycle02/source 10:02 - 11-Mar-2013The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

Publication 901 (April 2013) Page 57

Page 58: Treaties U.S. TaxTurkmenistan, and Uzbekistan. That treaty will remain in effect until new treaties with these in-dividual countries are negotiated and ratified. Provisions of the

Table 3. List of Tax Treaties (Updated through March 31, 2013)

CountryOfficial Text

Symbol1General

Effective Date4 Citation

Applicable Treasury Explanations

or Treasury Decision (T.D.)Australia TIAS 10773 Dec. 1, 1983 1986-2 C.B. 220 1986-2 C.B. 246 Protocol TIAS Jan. 1, 2004Austria TIAS Jan. 1, 1999Bangladesh TIAS Jan. 1, 2007Barbados TIAS 11090 Jan. 1, 1984 1991-2 C.B. 436 1991-2 C.B. 466 Protocol TIAS Jan. 1, 1994 Protocol TIAS Jan. 1, 2005Belgium TIAS Jan. 1, 2008Bulgaria TIAS Jan. 1, 2009Canada2 TIAS 11087 Jan. 1, 1985 1986-2 C.B. 258 1987-2 C.B. 298 Protocol TIAS Jan. 1, 1996 Protocol TIAS Dec. 16, 1997 Protocol TIAS Jan. 1, 2009China, People's Republic of TIAS 12065 Jan. 1, 1987 1988-1 C.B. 414 1988-1 C.B. 447Commonwealth of Independent

States3 TIAS 8225 Jan. 1, 1976 1976-2 C.B. 463 1976-2 C.B. 475Cyprus TIAS 10965 Jan. 1, 1986 1989-2 C.B. 280 1989-2 C.B. 314Czech Republic TIAS Jan. 1, 1993Denmark TIAS Jan. 1, 2001 Protocol TIAS Jan. 1, 2008Egypt TIAS 10149 Jan. 1, 1982 1982-1 C.B. 219 1982-1 C.B. 243Estonia TIAS Jan. 1, 2000Finland TIAS 12101 Jan. 1, 1991 Protocol TIAS Jan. 1, 2008France TIAS Jan. 1, 1996 Protocol TIAS Jan. 1, 2007 Protocol TIAS Jan. 1, 2009Germany TIAS Jan. 1, 1990 Protocol TIAS Jan. 1, 2008Greece TIAS 2902 Jan. 1, 1953 1958-2 C.B. 1054 T.D. 6109, 1954-2 C.B. 638Hungary TIAS 9560 Jan. 1, 1980 1980-1 C.B. 333 1980-1 C.B. 354Iceland TIAS Jan. 1, 2009India TIAS Jan. 1, 1991Indonesia TIAS 11593 Jan. 1, 1990Ireland TIAS Jan. 1, 1998Israel TIAS Jan. 1, 1995Italy TIAS Jan. 1, 2010Jamaica TIAS 10207 Jan. 1, 1982 1982-1 C.B. 257 1982-1 C.B. 291Japan TIAS Jan. 1, 2005 Kazakhstan TIAS Jan. 1, 1996Korea, Republic of TIAS 9506 Jan. 1, 1980 1979-2 C.B. 435 1979-2 C.B. 458Latvia TIAS Jan. 1, 2000Lithuania TIAS Jan. 1, 2000Luxembourg TIAS Jan. 1, 2001Malta TIAS Jan. 1, 2011Mexico TIAS Jan. 1,1994 Protocol TIAS Oct. 26, 1995 Protocol TIAS Jan. 1, 2004Morocco TIAS 10195 Jan. 1, 1981 1982-2 C.B. 405 1982-2 C.B. 427Netherlands TIAS Jan. 1, 1994 Protocol TIAS Jan. 1, 2005New Zealand TIAS 10772 Nov. 2, 1983 1990-2 C.B. 274 1990-2 C.B. 303 Protocol TIAS Jan. 1, 2011Norway TIAS 7474 Jan. 1, 1971 1973-1 C.B. 669 1973-1 C.B. 693 Protocol TIAS 10205 Jan. 1, 1982 1982-2 C.B. 440 1982-2 C.B. 454

Page 58 of 61 Fileid: … ons/P901/201304/A/XML/Cycle02/source 10:02 - 11-Mar-2013The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

Page 58 Publication 901 (April 2013)

Page 59: Treaties U.S. TaxTurkmenistan, and Uzbekistan. That treaty will remain in effect until new treaties with these in-dividual countries are negotiated and ratified. Provisions of the

Table 3. (continued)

CountryOfficial Text

Symbol1General

Effective Date4 Citation

Applicable Treasury Explanations

or Treasury Decision (T.D.)Pakistan TIAS 4232 Jan. 1, 1959 1960-2 C.B. 646 T.D. 6431, 1960-1 C.B. 755Philippines TIAS 10417 Jan. 1, 1983 1984-2 C.B. 384 1984-2 C.B. 412Poland TIAS 8486 Jan. 1, 1974 1977-1 C.B. 416 1977-1 C.B. 427Portugal TIAS Jan. 1, 1996Romania TIAS 8228 Jan. 1, 1974 1976-2 C.B. 492 1976-2 C.B. 504Russia TIAS Jan. 1, 1994Slovak Republic TIAS Jan. 1, 1993Slovenia TIAS Jan. 1, 2002South Africa TIAS Jan. 1, 1998Spain TIAS Jan. 1, 1991Sri Lanka TIAS Jan. 1, 2004Sweden TIAS Jan. 1, 1996 Protocol TIAS Jan. 1, 2007Switzerland TIAS Jan. 1, 1998Thailand TIAS Jan. 1, 1998Trinidad and Tobago TIAS 7047 Jan. 1, 1970 1971-2 C.B. 479Tunisia TIAS Jan. 1, 1990Turkey TIAS Jan. 1, 1998Ukraine TIAS Jan. 1, 2001United Kingdom TIAS Jan. 1, 2004Venezuela TIAS Jan. 1, 2000

1 (TIAS) — Treaties and Other International Act Series. 2 Information on the treaty can be found in Publication 597, Information on the United States­Canada Income Tax Treaty.3 The U.S.-U.S.S.R. income tax treaty applies to the countries of Armenia, Azerbaijan, Belarus, Georgia, Kyrgyzstan, Moldova, Tajikistan, Turkmenistan, and Uzbekistan.4 Date listed is the effective date for most income taxes. Check the treaty and/or protocol for other effective dates, including, for example, taxes withheld at source.

Page 59 of 61 Fileid: … ons/P901/201304/A/XML/Cycle02/source 10:02 - 11-Mar-2013The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

Publication 901 (April 2013) Page 59

Page 60: Treaties U.S. TaxTurkmenistan, and Uzbekistan. That treaty will remain in effect until new treaties with these in-dividual countries are negotiated and ratified. Provisions of the

Page 60 of 61 Fileid: … ons/P901/201304/A/XML/Cycle02/source 10:02 - 11-Mar-2013The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

How To Get Tax HelpYou can get help with unresolved tax issues, order free publications and forms, ask tax questions, and get information from the IRS in sev-eral ways. By selecting the method that is best for you, you will have quick and easy access to tax help.

Free help with your tax return. Free help in preparing your return is available nationwide from IRS-certified volunteers. The Vol-unteer Income Tax Assistance (VITA) program is designed to help low-moderate income, elderly, dis-abled, and limited English profi-cient taxpayers. The Tax Counsel-ing for the Elderly (TCE) program is designed to assist taxpayers age 60 and older with their tax returns. Most VITA and TCE sites offer free electronic filing and all volunteers will let you know about credits and deductions you may be entitled to claim. Some VITA and TCE sites provide taxpayers the opportunity to prepare their return with the as-sistance of an IRS-certified volun-teer. To find the nearest VITA or TCE site, visit IRS.gov or call 1-800-906-9887 or 1-800-829-1040.

As part of the TCE program, AARP offers the Tax-Aide counsel-ing program. To find the nearest AARP Tax-Aide site, visit AARP's website at www.aarp.org/money/taxaide or call 1-888-227-7669.

For more information on these programs, go to IRS.gov and enter “VITA” in the search box.

Internet. You can access the IRS website at IRS.gov 24 hours a day, 7

days a week to:E­file your return. Find out about commercial tax prepa-ration and e­file services avail-able free to eligible taxpayers.Check the status of your 2012 refund. Go to IRS.gov and click on Where’s My Refund. Information about your return will generally be available within 24 hours after the IRS receives your e-filed return, or 4 weeks after you mail your paper return. If you filed Form 8379 with your return, wait 14 weeks (11 weeks if you filed electronically). Have your 2012 tax return handy so you can provide your social secur-ity number, your filing status, and the exact whole dollar amount of your refund.Where's My Refund? has a new look this year! The tool will include a tracker that dis-plays progress through three

stages: (1) return received, (2) refund approved, and (3) re-fund sent. Where's My Re­fund? will provide an actual personalized refund date as soon as the IRS processes your tax return and approves your refund. So in a change from previous filing seasons, you won't get an estimated re-fund date right away. Where's My Refund? includes informa-tion for the most recent return filed in the current year and does not include information about amended returns.You can obtain a free tran-script online at IRS.gov by clicking on Order a Return or Account Transcript under “Tools.” For a transcript by phone, call 1-800-908-9946 and follow the prompts in the recorded message. You will be prompted to provide your SSN or Individual Taxpayer Identification Number (ITIN), date of birth, street address and ZIP code.Download forms, including talking tax forms, instructions, and publications.Order IRS products.Research your tax questions.Search publications by topic or keyword.Use the Internal Revenue Code, regulations, or other of-ficial guidance.View Internal Revenue Bulle-tins (IRBs) published in the last few years.Figure your withholding allow-ances using the IRS Withhold-ing Calculator at www.irs.gov/individuals.Determine if Form 6251 (Alter-native Minimum Tax— Individ-uals), must be filed by using our Alternative Minimum Tax (AMT) Assistant available at IRS.gov by typing Alternative Minimum Tax Assistant in the search box.Sign up to receive local and national tax news by email.Get information on starting and operating a small busi-ness.

Phone. Many services are available by phone.

Ordering forms, instructions, and publications. Call 1-800-TAX-FORM (1-800-829-3676) to order current-year forms, instruc-tions, and publications, and prior-year forms and

instructions (limited to 5 years). You should receive your order within 10 days.Asking tax questions. Call the IRS with your tax questions at 1-800-829-1040.Solving problems. You can get face-to-face help solving tax problems most business days in IRS Taxpayer Assis-tance Centers (TAC). An em-ployee can explain IRS letters, request adjustments to your account, or help you set up a payment plan. Call your local Taxpayer Assistance Center for an appointment. To find the number, go to www.irs.gov/localcontacts or look in the phone book under United States Government, In­ternal Revenue Service.TTY/TDD equipment. If you have access to TTY/TDD equipment, call 1-800-829-4059 to ask tax questions or to order forms and publications. The TTY/TDD telephone number is for individuals who are deaf, hard of hearing, or have a speech disability. These indi-viduals can also access the IRS through relay services such as the Federal Relay Service at www.gsa.gov/fedrelay.TeleTax topics. Call 1-800-829-4477 to listen to pre-recorded messages cov-ering various tax topics.Checking the status of your 2012 refund. To check the status of your 2012 refund, call 1-800-829-1954 or 1-800-829-4477 (automated Where's My Refund? informa-tion 24 hours a day, 7 days a week). Information about your return will generally be availa-ble within 24 hours after the IRS receives your e-filed re-turn, or 4 weeks after you mail your paper return. If you filed Form 8379 with your return, wait 14 weeks (11 weeks if you filed electronically). Have your 2012 tax return handy so you can provide your social security number, your filing status, and the exact whole dollar amount of your refund. Where's My Refund? will pro-vide an actual personalized refund date as soon as the IRS processes your tax return and approves your refund. Where's My Refund? includes information for the most re-cent return filed in the current

year and does not include in-formation about amended re-turns.

Evaluating the quality of our tel­ephone services. To ensure IRS representatives give accurate, courteous, and professional an-swers, we use several methods to evaluate the quality of our tele-phone services. One method is for a second IRS representative to lis-ten in on or record random tele-phone calls. Another is to ask some callers to complete a short survey at the end of the call.

Walk-in. Some products and services are availa-ble on a walk-in basis.

Products. You can walk in to some post offices, libraries, and IRS offices to pick up cer-tain forms, instructions, and publications. Some IRS offi-ces, libraries, and city and county government offices have a collection of products available to photocopy from reproducible proofs. Also, some IRS offices and libraries have the Internal Revenue Code, regulations, Internal Revenue Bulletins, and Cu-mulative Bulletins available for research purposes.Services. You can walk in to your local TAC most business days for personal, face-to-face tax help. An em-ployee can explain IRS letters, request adjustments to your tax account, or help you set up a payment plan. If you need to resolve a tax problem, have questions about how the tax law applies to your individ-ual tax return, or you are more comfortable talking with someone in person, visit your local TAC where you can talk with an IRS representative face-to-face. No appointment is necessary—just walk in. Before visiting, check www.irs.gov/localcontacts for hours of operation and serv-ices provided. If you have an ongoing, complex tax account problem or a special need, such as a disability, an ap-pointment can be requested by calling your local TAC. You can leave a message and a representative will call you back within 2 business days. All other issues will be han-dled without an appointment. To call your local TAC, go to

Page 60 Publication 901 (April 2013)

Page 61: Treaties U.S. TaxTurkmenistan, and Uzbekistan. That treaty will remain in effect until new treaties with these in-dividual countries are negotiated and ratified. Provisions of the

Page 61 of 61 Fileid: … ons/P901/201304/A/XML/Cycle02/source 10:02 - 11-Mar-2013The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

www.irs.gov/localcontacts or look in the phone book under United States Government, In­ternal Revenue Service.

Mail. You can send your order for forms, instruc-tions, and publications to

the address below. You should re-ceive a response within 10 days af-ter your request is received.

Internal Revenue Service1201 N. Mitsubishi MotorwayBloomington, IL 61705-6613

Taxpayer Advocate Service.The Taxpayer Advocate Service (TAS) is your voice at the IRS. Its job is to ensure that every taxpayer is treated fairly, and that you know and understand your rights. TAS offers free help to guide you through the often-confusing proc-ess of resolving tax problems that you haven’t been able to solve on your own. Remember, the worst thing you can do is nothing at all.

TAS can help if you can’t re-solve your problem with the IRS and:

Your problem is causing finan-cial difficulties for you, your family, or your business.You face (or your business is facing) an immediate threat of adverse action.You have tried repeatedly to contact the IRS but no one has responded, or the IRS has not responded to you by the date promised.

If you qualify for help, they will do everything they can to get your problem resolved. You will be as-signed to one advocate who will be with you at every turn. TAS has of-fices in every state, the District of Columbia, and Puerto Rico. Al-though TAS is independent within the IRS, their advocates know how to work with the IRS to get your problems resolved. And its serv-ices are always free.

As a taxpayer, you have rights that the IRS must abide by in its dealings with you. The TAS tax toolkit at www.TaxpayerAdvocate.irs.gov can help you understand these rights.

If you think TAS might be able to help you, call your local advo-cate, whose number is in your phone book and on our website at www.irs.gov/advocate. You can also call the toll-free number at 1-877-777-4778. Deaf and hard of hearing individuals who have ac-cess to TTY/TDD equipment can call 1-800-829-4059. These indi-viduals can also access the IRS through relay services such as the Federal Relay Service at www.gsa.gov/fedrelay.

TAS also handles large-scale or systemic problems that affect many taxpayers. If you know of one of these broad issues, please re-port it through the Systemic Advo-cacy Management System at www.irs.gov/advocate.

Low Income Taxpayer Clin­ics (LITCs). Low Income Tax-payer Clinics (LITCs) are inde-pendent from the IRS. Some clinics serve individuals whose in-come is below a certain level and who need to resolve a tax problem. These clinics provide professional representation before the IRS or in court on audits, appeals, tax col-lection disputes, and other issues for free or for a small fee. Some clinics can provide information about taxpayer rights and respon-sibilities in many different lan-guages for individuals who speak English as a second language. For more information and to find a clinic near you, see the LITC page on www.irs.gov/advocate or IRS Publication 4134, Low Income Tax­payer Clinic List. This publication is also available by calling 1-800-TAX-FORM (1-800-829-3676) or at your local IRS office.

Free tax services. Publication 910, IRS Guide to Free Tax Serv-ices, is your guide to IRS services and resources. Learn about free tax information from the IRS, in-cluding publications, services, and education and assistance pro-grams. The publication also has an index of over 100 TeleTax topics (recorded tax information) you can listen to on the telephone. The ma-jority of the information and serv-ices listed in this publication are available to you free of charge. If there is a fee associated with a re-source or service, it is listed in the publication.

Accessible versions of IRS published products are available on request in a variety of alterna-tive formats for people with disabili-ties.

DVD for tax products. You can order Publication 1796, IRS Tax Products

DVD, and obtain:Current-year forms, instruc-tions, and publications.Prior-year forms, instructions, and publications.Tax Map: an electronic re-search tool and finding aid.Tax law frequently asked questions.Tax Topics from the IRS tele-phone response system.Internal Revenue Code—Title 26 of the U.S. Code.Links to other Internet-based tax research materials.Fill-in, print, and save features for most tax forms.Internal Revenue Bulletins.Toll-free and email technical support.Two releases during the year.– The first release will ship the beginning of January 2013.– The final release will ship the beginning of March 2013.

Purchase the DVD from National Technical Information Service (NTIS) at www.irs.gov/cdorders for $30 (no handling fee) or call 1-877-233-6767 toll free to buy the DVD for $30 (plus a $6 handling fee).

Publication 901 (April 2013) Page 61