irs pub 901 - us tax treaty benefits

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Publication 901 Contents(Rev. April 2008)Cat. No. 46849F What’s New . . . . . . . . . . . . . . . . . . . . . 1

DepartmentReminders . . . . . . . . . . . . . . . . . . . . . . 2of the

Treasury Introduction . . . . . . . . . . . . . . . . . . . . . 2U.S. TaxInternal

Application of Treaties . . . . . . . . . . . . . 2RevenueService Tax Exemptions Provided byTreaties

Treaties . . . . . . . . . . . . . . . . . . . . . 2Personal Services Income . . . . . . . . . 3Professors, 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 ServiceIncome . . . . . . . . . . . . . . . . . . . 34

Table 2 - Exempt PersonalServices Income . . . . . . . . . . . . 38

Table 3 - List of Tax Treaties . . . . . . . 50

How To Get Tax Help . . . . . . . . . . . . . . 51

What’s NewNew tax treaties and protocols. The UnitedStates has exchanged instruments of ratificationfor a new income tax treaty with Belgium andnew protocols for the income tax treaties withDenmark, Finland, and Germany. The provi-sions of these treaties and protocols are in-cluded in the appropriate areas of thispublication. The effective dates are as follows:

Belgium. The provisions relating to with-holding tax at source are effective for amountspaid or credited on or after February 1, 2008. Forother taxes, the treaty is effective for tax periodsbeginning on or after January 1, 2008. A personentitled to benefits under the previous treaty canelect to have that treaty apply in its entirety for atwelve-month period following the date the newtreaty would otherwise apply.

Denmark. The provisions relating to with-holding tax at source are effective for amountspaid or credited on or after February 1, 2008. Forother taxes, the protocol is effective for tax peri-ods beginning on or after January 1, 2008.

Finland. The provisions relating to withhold-ing tax at source are effective for amounts paidor credited on or after February 1, 2008. How-ever, the provisions for dividends exempt underArticle 10(3) as amended by this protocol areeffective January 1, 2007. For other taxes, theprotocol is effective for tax years beginning on orafter January 1, 2008.

Germany. The provisions relating to with-holding tax at source are effective for amountspaid or credited on or after January 1, 2007. Forother taxes, the treaty is effective for tax yearsbeginning on or after January 1, 2008. A personentitled to benefits under the treaty before modi-fication by this protocol can elect to have theGet forms and other informationunmodified treaty apply in its entirety for afaster and easier by: twelve-month period following the date the pro-tocol would otherwise apply.

Internet • www.irs.gov



We respond to many letters by telephone.Reminders Therefore, it would be helpful if you would in- Application of Treatiesclude your daytime phone number, including the

Disclosure of a treaty-based position that area code, in your correspondence. The United States has income tax treaties with areduces your tax. If you take the position that You can email us at *[email protected]. (The number of foreign countries. Under these trea-any U.S. tax is overruled or otherwise reduced asterisk must be included in the address.) ties, residents (not necessarily citizens) of for-by a U.S. treaty (a treaty-based position), you Please put “Publications Comment” on the sub- eign countries are taxed at a reduced rate, or aregenerally must disclose that position on your ject line. Although we cannot respond individu- exempt from U.S. income taxes on certain itemsaffected return. See Application of Treaties, ally to each email, we do appreciate your of income they receive from sources within thelater. feedback and will consider your comments as United States. These reduced rates and exemp-

we revise our tax products. tions vary among countries and specific items ofU.S. – U.S.S.R. income tax treaty. Theincome.Ordering forms and publications. VisitU.S.–U.S.S.R. income tax treaty remains in ef-

If the treaty does not cover a particular kindwww.irs.gov/formspubs to download forms andfect for the following members of the Common-of income, or if there is no treaty between yourpublications, call 1-800-829-3676, or write to thewealth of Independent States: Armenia,country and the United States, you must pay taxaddress shown in the How To Get Tax HelpAzerbaijan, Belarus, Georgia, Kyrgyzstan,on the income in the same way and at the samesection under Mail.Moldova, Tajikistan, Turkmenistan, and Uzbeki- rates shown in the instructions for Form

stan. That treaty will remain in effect until new Obtaining copies of treaties. You can get 1040NR. Also see Publication 519.treaties with these individual countries are nego- complete information about treaty provisions Many of the individual states of the Unitedtiated and ratified. Provisions of the from the taxing authority in the country from States tax the income of their residents. There-U.S.–U.S.S.R. income tax treaty are discussed which you receive income or from the treaty fore, you should consult the tax authorities of thein this publication under Commonwealth of Inde- itself. state in which you live to find out if that statependent States. You can obtain the text of most of the treaties taxes the income of individuals and, if so,

at www.irs.gov/businesses/international. You whether the tax applies to any of your income.U.S. – China income tax treaty. The can also obtain the text of most of the treaties at Tax treaties reduce the U.S. taxes of re-U.S.–China income tax treaty does not apply to the following address: sidents of foreign countries. With certain excep-Hong Kong.tions, they do not reduce the U.S. taxes of U.S.Department of the Treasurycitizens or residents. U.S. citizens and residentsU.S.–United Kingdom income tax treaty. Office of Public Correspondenceare subject to U.S. income tax on their world-Generally, the treaty is effective for tax periods 1500 Pennsylvania Ave. NW — Rm. 3419wide income.beginning on or after January 1, 2004. However, Washington, D.C. 20220

Treaty provisions generally are reciprocalan individual who was otherwise entitled to(apply to both treaty countries); therefore, a U.S.treaty benefits under Article 21 (students and If you have specific questions about a treaty,citizen or resident who receives income from ayou can get this information from most Internaltrainees) of the former treaty can continue totreaty country may refer to the tables in thisRevenue Service offices or from:apply that provision.publication to see if a tax treaty might affect the

Internal Revenue Service tax to be paid to that foreign country. ForeignU.S.–Japan income tax treaty. Generally,International Returns Section taxing authorities sometimes require certifica-the treaty is effective for tax periods beginningP.O. Box 920 tion from the U.S. Government that an applicanton or after January 1, 2005. However, an individ-Bensalem, PA 19020-8518 filed an income tax return as a U.S. citizen orual who was entitled to treaty benefits under

resident, as part of the proof of entitlement to theArticle 19 (teachers and researchers) or Articletreaty benefits. For more information, see Publi-20 (students and trainees) of the former treaty Tax questions. If you have a tax question,cation 686.as of March 30, 2004, can continue to apply check the information available on www.irs.gov

those provisions. or call 1-800-829-1040.Disclosure of a treaty-based position thatreduces your tax. If you take the position thatUseful Items any U.S. tax is overruled or otherwise reduced

You may want to see: by a U.S. treaty (a treaty-based position), youIntroduction generally must disclose that position on FormPublication 8833 and attach it to your return. If you are notThis publication will tell you whether a tax treaty

required to file a return because of your❏ 519 U.S. Tax Guide for Aliensbetween the United States and a particulartreaty-based position, you must file a return any-country offers a reduced rate of, or possibly a ❏ 597 Information on the United way to report your position. The filing of Formcomplete exemption from, U.S. income tax for States–Canada Income Tax Treaty 8833 does not apply to a reduced rate of with-residents of that particular country.holding tax on noneffectively connected income,❏ 686 Certification for Reduced Tax RatesTables in the back of this publication showsuch as dividends, interest, rents or royalties, orin Tax Treaty Countriesthe countries that have income tax treaties withto a reduced rate of tax on pay received forthe United States, the tax rates on different kindsservices performed as an employee, includingForm (and Instructions)of income, and the kinds of income that arepensions, annuities, and social security. Forexempt from tax. ❏ 8833 Treaty-Based Return Position more information, see Publication 519 and the

Disclosure Under Section 6114 orYou should use this publication only for Form 8833 instructions.7701(b)quick reference. It is not a complete If you fail to file Form 8833, you may have to

See How To Get Tax Help near the end ofguide to all provisions of every income pay a $1,000 penalty. Corporations are subjectCAUTION!

this publication for information about gettingtax treaty. to a $10,000 penalty for each failure.these publications and forms.

Comments and suggestions. We welcomeyour comments about this publication and your Tax Exemptionssuggestions for future editions.

You can write to us at the following address: Provided by TreatiesInternal Revenue Service In addition to the tables in the back of this publi-Individual Forms and Publications Branch cation, this publication contains discussions ofSE:W:CAR:MP:T:I the exemptions from tax and certain other ef-1111 Constitution Ave. NW, IR-6526 fects of the tax treaties on the following types ofWashington, DC 20224 income.

Page 2 Publication 901 (April 2008)



• Pay for certain personal services per- • The pay is paid by, or on behalf of, an If they have a fixed base available in the Unitedemployer or company that is not a residentformed in the United States. States, they are taxed on the income attributableof the United States, and to the fixed base.• Pay of a professor, teacher, or researcher

• The pay is not deductible in determiningwho teaches or performs research in the Income that residents of Bangladesh receivethe taxable income of the trade or busi-United States for a limited time. for services performed in the United States asness of the employer (or company) in the employees (dependent personal services) is ex-• Amounts received for maintenance and United States. empt from U.S. income tax if the residents meetstudies by a foreign student or apprentice

the following requirements.who is here for study or experience. These exemptions do not apply to public en- • They are in the United States for no moretertainers (such as theater, motion picture, ra-• Wages, salaries, and pensions paid by athan 183 days in any 12-month period be-dio, or television entertainers, musicians, andforeign government.ginning or ending in the tax year.athletes) from Australia who earn more than

$10,000 in gross receipts, including reimbursed • Their income is paid by, or on behalf of, anPersonal Services Income expenses, from their entertainment activities in employer who is not a U.S. resident.the United States during the tax year.

• Their income is not borne by a permanentPay for certain personal services performed inestablishment or a fixed base that the em-the United States is exempt from U.S. incomeployer has in the United States.tax if you are a resident of one of the countries Austria

discussed below, if you are in the United StatesIncome that residents of Austria receive for per- These exemptions do not apply to pubic en-for a limited number of days, and if you meetsonal services as independent contractors or tertainers (such as theater, motion picture, ra-certain other conditions. For this purpose, theself-employed individuals (independent per- dio, or television entertainers, musicians, andword “day” means a day during any part of whichsonal services) in the United States is exempt athletes) from Bangladesh who earn more thanyou are physically present in the United States.from U.S. income tax if they do not have a fixed $10,000 in gross receipts, including reimbursedbase regularly available to them in the United expenses, from their entertainment activities inTerms defined. Several terms appear inStates for performing the services. If they have a the United States during the tax year. Regard-many of the discussions that follow. The exactfixed base available in the United States, they less of these limits, income of Bangladesh enter-meanings of the terms are determined by theare taxed on the income attributable to the fixed tainers is exempt from U.S. income tax if theirparticular tax treaty under discussion; thus, thebase. visit to the United States is wholly or mainlymeanings vary among treaties. The definitions

Income that residents of Austria receive for supported by public funds of Bangladesh, itsthat follow are, therefore, general definitions thatservices performed in the United States as em- political subdivisions, or local authorities.may not give the exact meaning intended by aployees (dependent personal services) is ex-particular treaty. Income received from employment as aempt from U.S. income tax if the residents meet member of the regular complement of a ship orThe terms fixed base and permanent estab- the following requirements. an aircraft operated by a Bangladesh enterpriselishment generally mean a fixed place of busi-

in international traffic is exempt from U.S. tax. If• They are in the United States for no moreness, such as a place of management, a branch,the ship or aircraft is operated by a U.S. enter-than 183 days in any 12-month period be-an office, a factory, a warehouse, or a mining

ginning or ending in the tax year. prise, the income is subject to U.S. tax.site, through which an enterprise carries on itsbusiness. If the resident of Bangladesh is a share-• Their income is paid by, or on behalf of, an

holder in a U.S. corporation, these exemptionsThe term borne by generally means having employer who is not a U.S. resident.do not apply to director’s fees received as aultimate financial accounting responsibility for or

• Their income is not borne by a permanent member of the board of directors of the U.S.providing the monetary resources for an expen-establishment or a fixed base that the em- corporation. The amount received by the share-diture or payment, even if another entity in an-ployer has in the United States. holder that is more than the amount paid to aother location actually made the expenditure or

director that is not a shareholder is subject topayment.These exemptions do not apply to public en- U.S. tax at the rate of 15%.

tertainers (such as theater, motion picture, ra-dio, or television entertainers, musicians, andAustraliaathletes) from Austria who earn more than Barbados$20,000 in gross receipts, including reimbursedIncome that residents of Australia receive forexpenses, from their entertainment activities in Income that residents of Barbados receive forperforming personal services as independentthe United States during the tax year. performing personal services as independentcontractors or self-employed individuals (inde-

Income received by a resident of Austria for contractors or self-employed individuals (inde-pendent personal services) in the United Statesservices performed as an employee and mem- pendent personal services) in the United Statesduring the tax year is exempt from U.S. incomeber of the regular complement of a ship or air- during the tax year is exempt from U.S. incometax if the residents:craft operated in international traffic is exempt tax if the residents:• Are in the United States for no more than from U.S. income tax. • Are in the United States for no more than183 days during the tax year, and

89 days during the tax year,• Do not have a fixed base regularly avail-Bangladesh • Earn net income for independent servicesable to them in the United States for the

provided to U.S. residents that is not morepurpose of performing the services.Income that residents of Bangladesh receive for than $5,000 (there is no dollar limit if the

If they have a fixed base available in the United performing personal services as independent contractors are not U.S. residents), andStates, they are taxed on the income attributable contractors or self-employed individuals (inde-

• Do not have a regular base available into the fixed base. pendent personal services) in the United Statesthe United States for performing the serv-during the tax year is exempt from U.S. incomePay that residents of Australia receive for la-ices.tax if the residents:bor or personal services performed in the United

If they have a regular base available in theStates as employees (dependent personal serv- • Are in the United States for no more thanUnited States but otherwise meet the conditionsices), including services as a director of a com- 183 days in any 12-month period begin-for exemption, they are taxed only on the incomepany, is exempt from U.S. income tax if: ning or ending in the tax year, orattributable to the regular base.• The residents are in the United States for • Do not have a fixed base regularly avail-

Income that residents of Barbados receive forno more than 183 days during the tax able to them in the United States for thepersonal services performed in the Unitedyear, purpose of performing the services.

Publication 901 (April 2008) Page 3



States as employees (dependent personal serv- The exemption does not apply to public en- the services. If they have a fixed base availabletertainers (such as theater, motion picture, rain the United States, they are taxed on the in-ices) is exempt from U.S. tax if the residentsdio, or television artists, musicians, or athletes) come attributable to the fixed base.meet four requirements.from Belgium who earn more than $20,000 in Income that residents of Canada receive for• They are in the United States for no more gross receipts, including reimbursed expenses, personal services performed as employees (de-than 183 days during the calendar year. from their entertainment activities in the United pendent personal services) in the United StatesStates during the tax year.• The income earned in the calendar year in is exempt from U.S. tax if it is not more than

Income received by a resident of Belgium forthe United States is not more than $5,000. $10,000 for the year. If the income is more thanservices performed as an employee and mem- $10,000 for the year, it is exempt only if:• Their income is paid by or for an employer ber of the regular complement of a ship or air-

who is not a U.S. resident. • The residents are present in the Unitedcraft operated in international traffic is exemptStates for no more than 183 days duringfrom U.S. income tax.• The income is not borne by a permanentthe calendar year, andestablishment or regular base of the em-

Former treaty. Income that residents ofployer in the United States. • The income is not borne by a U.S. resi-Belgium receive for performing personal serv- dent employer or by a permanent estab-ices as independent contractors orIncome of a Barbadian resident from employ- lishment or fixed base of an employer inself-employed individuals (independent per-ment as a member of the regular complement of the United States.sonal services) in the United States during thea ship or aircraft operated in international traffictax year is exempt from U.S. income tax if the These exemptions do not apply to public en-is exempt from U.S. tax.residents: tertainers (such as theater, motion picture, ra-These exemptions do not apply to Barbadian

dio, or television artists, musicians, or athletes)• Are present in the United States less thanresident public entertainers (such as theater,from Canada who derive more than $15,000 in183 days during the tax year, andmotion picture, radio, or television artists, musi-gross receipts, including reimbursed expenses,cians, or athletes) who receive gross receipts of • Do not maintain a fixed base in the United from their entertainment activities in the Unitedmore than $250 per day or $4,000 in the tax States for a period or periods that total States during the calendar year. However, theyear, not including reimbursed expenses, from more than 182 days during the tax year. exemptions do apply, regardless of this $15,000their entertainment activities in the Unitedlimit, to athletes participating in team sports inIf they do not meet condition (2), they are taxedStates. However, the exemptions do apply re-leagues with regularly scheduled games in bothon the income attributed to the fixed base.gardless of these limits on gross receipts if theCanada and the United States.entertainer’s visit to the United States is sub- The exemption for independent personal

Pay received by a resident of Canada forstantially supported by Barbadian public funds services does not apply to individuals who areemployment regularly done in more than oneor if the entertainer’s services are provided to a public entertainers (theater, motion picture, orcountry on a ship, aircraft, motor vehicle, or trainnonprofit organization. television artists, musicians, or athletes), if theyoperated by a Canadian resident is exempt fromare in the United States for more than 90 daysU.S. tax.during the tax year or if their pay for services as

Belgium public entertainers is more than $3,000.Income that residents of Belgium receive for

China, People’s Republic oflabor or personal services performed in theNote. See the effective dates of the new United States as employees (dependent per- Income that residents of the People’s Republictreaty under What’s New at the beginning of this sonal services), including services as an officer of China receive for personal services as inde-publication. of a corporation, is exempt from U.S. income tax pendent contractors or self-employed individu-

if the residents meet three requirements. als (independent personal services) that theyNew treaty. Income that residents of Belgiumperform during the tax year in the United States• They are present in the United States lessreceive for personal services as independentis exempt from U.S. income tax if the residents:than 183 days during the tax year.contractors or self-employed individuals are

subject to the provisions of Article 7 (Business • Are present in the United States for no• They are employees of a resident ofProfits) of the treaty. Under that provision, busi- more than 183 days in the calendar year,Belgium or of a permanent establishmentness profits are exempt from U.S. income tax andin Belgium.unless they have a permanent establishment in • Do not have a fixed base regularly avail-• Their income is not borne by a permanentthe United States. If they have a permanent able in the United States for performingestablishment that the employer has in theestablishment available in the United States, United States. the services.they are taxed on the income attributable to the

If they have a fixed base available in the Unitedpermanent establishment. Income for services performed by an individ-States, they are taxable on the income attributa-Income that residents of Belgium receive for ual as an employee aboard a ship or an aircraftble to the fixed base.services performed in the United States as em- registered in Belgium and operated by a resi-

ployees (dependent personal services) is ex- dent of Belgium in international traffic is exempt Pay received by residents of the People’sempt from U.S. income tax if the residents meet from U.S. tax if the individual is a member of the Republic of China for services performed asthe following requirements. regular complement of the ship or aircraft. employees (dependent personal services) in the

These exemptions do not apply to fees re- United States is exempt from U.S. tax if:• They are in the United States for no moreceived by a resident of Belgium for servicesthan 183 days in any 12-month period be- • The residents are present in the Unitedperformed as a director of a U.S. corporation ifginning or ending in the tax year. States for no more than 183 days in thethe fees are treated as a distribution of profits

calendar year,• Their income is paid by, or on behalf of, an and cannot be taken as a deduction by theemployer who is not a U.S. resident. corporation. • The pay is paid by or for an employer who

is not a U.S. resident, and• Their income is not borne by a permanentestablishment that the employer has in the • The pay is not borne by a permanent es-Canada

tablishment or fixed base that the em-United States.ployer has in the United States.Income that residents of Canada receive for

The exemption does not apply to directors’ personal services as independent contractors orThese exemptions do not apply to directors’fees and similar payments received by a resi- self-employed individuals (independent per-

fees for service on the board of directors of adent of Belgium for services performed in the sonal services) that they perform during the taxU.S. corporation.United States as a member of the board of year in the United States is exempt from U.S. tax

directors of a company that is a resident of the These exemptions generally do not apply toif they do not have a fixed base regularly avail-income received as a public entertainer (such asUnited States. able to them in the United States for performing




a theater, motion picture, radio, or television Income that residents of Denmark receive forCzech Republicartist, musician, or athlete). However, income of services performed in the United States as em-

Income that residents of the Czech Republicathletes or public entertainers from China partic- ployees (dependent personal services) is ex-receive for performing personal services as in-ipating in a cultural exchange program agreed empt from U.S. income tax if the residents meetdependent contractors or self-employed individ-upon by the U.S. and Chinese governments is the following requirements.uals (independent personal services) in theexempt from U.S. tax. • They are in the United States for no moreUnited States is exempt from U.S. income tax if

than 183 days in any 12-month period be-the residents:ginning or ending in the tax year.Commonwealth of • Are present in the United States for noIndependent States • Their income is paid by, or on behalf of, anmore than 183 days in any 12-month pe-employer who is not a U.S. resident.riod, andIncome that residents of a C.I.S. member re-

• Their income is not borne by a permanentceive for performing personal services in the • Do not have a fixed base regularly avail-establishment or a fixed base that the em-United States is exempt from U.S. income tax if able to them in the United States for per-

those residents are in the United States for no ployer has in the United States.forming the services.more than 183 days during the tax year.

If they have a fixed base available, they are These exemptions do not apply to directors’Pay received by an employee who is a mem-taxed only on income attributable to the fixed fees and similar payments received by a resi-ber of the regular complement of a ship or air-base.craft operated in international traffic by a C.I.S. dent of Denmark as a member of the board of

member or a resident of a C.I.S. member is directors of a company that is a resident of theIncome that residents of the Czech Republicexempt from U.S. tax. United States.receive for employment in the United States

These exemptions do not apply to public(dependent personal services) is exempt fromentertainers (such as theater, motion picture,U.S. income tax if the following three require-Cyprus radio, or television artists, musicians, and ath-ments are met.letes) from Denmark who earn more thanIncome that residents of Cyprus receive for per- • The resident is present in the United $20,000 in gross receipts, including reimbursedforming personal services as independent con- States for no more than 183 days in any expenses, from their entertainment activities intractors or sel f -employed indiv iduals 12-month period. the United States during the tax year.(independent personal services) in the United

Income received by a resident of Denmark• The income is paid by, or on behalf of, anStates during the tax year is exempt from U.S.for services performed as an employee andemployer who is not a U.S. resident.income tax if the residents:member of the regular complement of a ship or• The income is not borne by a permanent• Are present in the United States for less aircraft operated in international traffic is exempt

than 183 days in the tax year, and establishment or a fixed base that the em- from U.S. income tax.ployer has in the United States.• Do not have a fixed base regularly avail-

able to them in the United States for per-These exemptions do not apply to income Egyptforming the services.

residents of the Czech Republic receive as pub-If they have a fixed base available in the United lic entertainers (such as theater, motion picture, Income that residents of Egypt receive for per-States, they are taxable on the income attributa- radio, or television artists, or musicians) or forming personal services as independent con-ble to the fixed base. sportsmen if their gross receipts, including reim- tractors or as self-employed individuals

bursed expenses, are more than $20,000 during (independent personal services) in the UnitedPay received by residents of Cyprus fromthe tax year. Regardless of these limits, income States during the tax year is exempt from U.S.services performed as employees (dependentof Czech entertainers and sportsmen is exempt income tax if they are in the United States for nopersonal services), including services as an of-from U.S. income tax if their visit to the United more than 89 days during the tax year.ficer of a corporation, is exempt from U.S. in-States is substantially supported by public funds Income that residents of Egypt receive forcome tax if:of the Czech Republic, its political subdivisions, labor or personal services performed in the• The residents are in the United States for or local authorities, or the visit is made pursuant United States as employees (dependent per-less than 183 days during the tax year, to a specific arrangement between the United sonal services), including income for servicesStates and the Czech Republic.• The pay is paid by or for an employer who performed by an officer of a corporation or com-

is not a U.S. resident, and pany, is exempt from U.S. income tax if theThese exemptions do not apply to directors’residents meet four requirements.fees and similar payments received by a resi-• The pay is not borne by a permanent es-

dent of the Czech Republic as a member of thetablishment, fixed base, or trade or busi- • They are in the United States for no moreboard of directors of a company that is a residentness that the employer has in the United than 89 days during the tax year.of the United States.States. • They are employees of a resident of, or aIncome from employment as a member of

permanent establishment in, Egypt.the regular complement of a ship or aircraftPay received by a Cyprus resident for per-forming personal services as an employee and operated by a Czech enterprise in international • Their income is not borne by a permanentmember of the regular complement of a ship or traffic is exempt from U.S. income tax. If the ship establishment that the employer has in theaircraft operated in international traffic by a resi- or aircraft is operated by a U.S. enterprise, the United States.dent of Cyprus is exempt from U.S. tax. income is subject to U.S. tax. • Their income is subject to Egyptian tax.These exemptions do not apply to Cyprusresident public entertainers (theater, motion pic-

This exemption does not apply to pay re-ture, radio, or television artists, musicians, or Denmarkceived by a resident of Egypt who is an em-athletes) who receive gross receipts of moreployee and member of the regular complementIncome that residents of Denmark receive forthan $500 per day or $5,000 for the tax year, notof a ship or an aircraft operated in internationalpersonal services as independent contractors orincluding reimbursed expenses, from their en-traffic by a resident of the United States.self-employed individuals (independent per-tertainment activities in the United States.

sonal services) in the United States is exempt These exemptions do not apply to EgyptianDirectors’ fees received by residents of Cy-from U.S. income tax if they do not have a fixed resident public entertainers (theater, motion pic-prus for service on the board of directors of abase regularly available to them in the United ture, radio, or television artists, musicians, orU.S. corporation are exempt from U.S. incomeStates for performing the services. If they have a athletes), who earn income for services as pub-tax to the extent of a reasonable fixed amountfixed base available in the United States, they lic entertainers if the gross amount of the incomepayable to all directors for each day of attend-are taxed on the income attributable to the fixed is more than $400 for each day they are in theance at directors’ meetings held in the United

United States performing the services.States. base.




• They are in the United States for no moreEstonia Germanythan 183 days during any 12-month pe-

Income that residents of Estonia receive for per- riod.Note. See the effective dates of the protocolforming personal services as independent con-

• Their income is paid by, or on behalf of, an under What’s New at the beginning of this publi-t ractors or sel f -employed indiv idualsemployer who is not a resident of the cation.(independent personal services) in the UnitedUnited States.States is exempt from U.S. income tax if the Treaty as modified. Income that residents of

residents: • Their income is not borne by a permanent Germany receive for personal services as inde-establishment, fixed base, or trade or busi-• Are in the United States for no more than pendent contractors or self-employed individu-ness that the employer has in the United183 days in any 12-month period begin- als are subject to the provisions of Article 7States.ning or ending in the tax year, and (Business Profits) of the treaty. Under that provi-

sion, business profits are exempt from U.S. in-• Do not have a fixed base regularly avail- The exemption does not apply to pay received come tax unless they have a permanentable to them in the United States for per- by a resident of Finland who is an employee and establishment in the United States. If they haveforming the services. member of the regular complement of a ship or a permanent establishment available in the

If they have a fixed base available, they are aircraft operated in international traffic by a resi- United States, they are taxed on the incometaxed on the income attributable to the fixed attributable to the permanent establishment.dent of the United States.base. Income that residents of Germany receiveThese exemptions do not apply to income

for labor or personal services performed in theresidents of Finland receive as public entertain-Income that residents of Estonia receive forUnited States as employees (dependent per-ers or sportsmen if the gross income, includingservices performed in the United States as em-sonal services) is exempt from U.S. tax if thereimbursed expenses, is more than $20,000 forployees (dependent personal services) is ex-residents meet three requirements.their personal activities in the United States dur-empt from U.S. income tax if the following

ing the calendar year.requirements are met. • They are in the United States for no morethan 183 days during the calendar year.• The resident is in the United States for no

more than 183 days in any 12-month pe- • The income is paid by, or on behalf of, anFranceriod beginning or ending in the tax year. employer who is not a resident of the

United States.Income that residents of France receive for per-• The income is paid by, or on behalf of, anforming personal services as independent con-employer who is not a U.S. resident. • The income is not borne by a permanenttractors or sel f -employed indiv iduals establishment that the employer has in the• The income is not borne by a permanent (independent personal services) in the United United States.establishment or a fixed base that the em- States is exempt from U.S. income tax if they do

ployer has in the United States. not have a fixed base regularly available to them Pay received by a resident of Germany forin the United States for performing the services. services performed as an employee and mem-These exemptions do not apply to directors’ If they have a fixed base available in the United ber of the regular complement of a ship or air-fees and similar payments received by a resi- States, they are taxed on the income attributable craft operated in international traffic is exemptdent of Estonia as a member of the board of to the fixed base. from U.S. tax.directors or similar body of a company that is a Income that residents of France receive for The exemption does not apply to directors’U.S. resident. labor or personal services performed in the fees and other similar payments received by a

Pay received for employment as a member United States as employees (dependent per- resident of Germany for services performed inof the regular complement of a ship or an aircraft sonal services) is exempt from U.S. income tax if the United States as a member of the board ofoperated in international traffic by a United the residents meet three requirements. directors of a company resident in the UnitedStates enterprise is subject to U.S. tax. States.• They are in the United States for no moreThese exemptions do not apply to income The exemption does not apply to incomethan 183 days in any 12-month period.residents of Estonia receive as public entertain- residents of Germany receive as public enter-ers (such as theater, motion picture, radio, or • Their income is paid by, or on behalf of, an tainers (such as theater, motion picture, radio, ortelevision artists, or musicians) or sportsmen if employer who is not a resident of the television artists, or musicians) or athletes iftheir gross receipts, including reimbursed ex- their gross receipts, including reimbursed ex-United States.penses, are more than $20,000 for their per- penses, are more than $20,000 during the cal-• Their income is not borne by a permanentsonal activities in the United States during the endar year. Regardless of these limits, income

establishment or a fixed base that the em-tax year. Regardless of these limits, income of of German entertainers or athletes is exemptEstonian entertainers or athletes is exempt from ployer has in the United States. from U.S. tax if their visit to the United States isU.S. income tax if their visit to the United States substantially supported by public funds of Ger-is wholly or mainly supported by public funds of Income for services performed by a resident many, its political subdivisions, or local authori-Estonia, its political subdivisions, or local author- of France as an employee and member of the ties.ities. regular complement of a ship or an aircraft oper-

Unmodified treaty. Generally, the previousated in international traffic is exempt from tax indiscussion, other than the first paragraph, ap-the United States.

Finland plies to the unmodified treaty. Under that treaty,These exemptions do not apply to publicthe first paragraph would be as follows.entertainers (such as theater, motion picture,Income that residents of Finland receive for per- Income that residents of Germany receiveradio, or television artists, or musicians), orforming personal services as independent con- for personal services as independent contrac-sportsmen from France who earn more thantractors or sel f -employed indiv iduals tors or self-employed individuals (independent$10,000 in gross receipts, including reimbursed(independent personal services) in the United personal services) in the United States is ex-expenses, from their entertainment activities inStates is exempt from U.S. income tax if they do empt from U.S. income tax if the income is notthe United States during the tax year. Regard-not have a fixed base regularly available to them attributable to a fixed base regularly available inless of these limits, income of French entertain-in the United States for performing the services. the United States.ers or sportsmen is exempt from U.S. tax if theirIf they have a fixed base available in the United

visit is principally supported by public funds ofStates, they are taxed on the income attributableFrance.to the fixed base. Greece

These exemptions do not apply to directors’Income that residents of Finland receive forfees and similar payments received by a resi-labor or personal services performed in the Income that residents of Greece receive for la-dent of France as a member of the board ofUnited States as employees (dependent per- bor or personal services (including practicingdirectors of a company that is a resident of thesonal services) is exempt from U.S. income tax if liberal and artistic professions) is exempt fromUnited States.the residents meet three requirements. U.S. income tax if they are in the United States




for no more than 183 days during the tax year pay for services as public entertainers is more (such as theater, motion picture, radio, or televi-sion artists, or musicians) or athletes if their netand the pay is not more than $10,000. The pay, than $100 per day.income is more than $1,500 during the tax yearregardless of amount, is exempt from U.S. in- Income that residents of Iceland receive forfor their entertainment activities in the Unitedcome tax if it is for labor or personal services labor or personal services performed in theStates. Regardless of this limit, the income ofperformed as employees of, or under contract United States as employees (dependent per-Indian entertainers and athletes is exempt fromwith, a resident of Greece or a Greek corpora- sonal services) is exempt from U.S. income tax ifU.S. tax if their visit to the United States is whollytion or other entity of Greece, and if the residents the employees meet three requirements:or substantially supported from the public fundsare in the United States for no more than 183

• They are in the United States for no more of the Indian Government, its political subdivi-days during the tax year.than 182 days during the tax year. sions, or local authorities.

• They are employees of a resident of Ice-Hungary land or of a permanent establishment of a

Indonesiaresident of a state other than Iceland if theIncome that residents of Hungary receive forpermanent establishment is located in Ice- Income that residents of Indonesia receive forperforming personal services as independentland. performing personal services as individual con-contractors or self-employed individuals (inde-

tractors or self-employed individuals (indepen-pendent personal services) in the United States • Their income is not borne by a permanentdent personal services) in the United Statesduring the tax year is exempt from U.S. tax if the establishment that the employer has in theduring the tax year is exempt from U.S. incomeresidents: United States.tax if the residents:• Are in the United States for no more than

Income for services performed by an em- • Are present in the United States for no183 days during the tax year, andployee aboard a ship or an aircraft operated by a more than 119 days during any consecu-• Do not have a fixed base regularly avail- resident of Iceland in international traffic or in tive 12-month period, and

able in the United States. fishing on the high seas is exempt from U.S. tax• Do not have a fixed base regularly avail-if the individual is a member of the regular com-If they have a fixed base available in the United able to them in the United States for per-plement of the ship or aircraft.States, they are taxed on the income attributable forming the services.

to the fixed base.

If they have a fixed base available, they areIncome that residents of Hungary receive for Indiataxed only on the income attributable to the fixedlabor or personal services performed in thebase.Income that residents of India receive for per-United States as employees (dependent per-

forming personal services in the United States Income that residents of Indonesia receivesonal services) is exempt from U.S. income tax ifduring the tax year as independent contractors for personal services performed in the Unitedthe residents meet three requirements.or self-employed individuals (independent per- States as employees (dependent personal serv-• They are in the United States for no more sonal services) is exempt from U.S. income tax if ices) is exempt from U.S. income tax if the re-

than 183 days during the tax year. sidents meet three requirements.the residents:• Their income is paid by or on behalf of an • They are present in the United States no• Are present in the United States for no

employer who is not a resident of the more than 119 days during any consecu-more than 89 days during the tax year,United States. tive 12-month period.and

• Their income is not borne by a permanent • The income is paid by, or on behalf of, an• Do not have a fixed base regularly avail-establishment or a fixed base that the em- employer who is not a resident of theable to them in the United States for per-ployer has in the United States. United States.forming the services.

• The income is not borne or reimbursed byPay received by an employee who is a mem- If they have a fixed base available, they are a permanent establishment the employerber of the regular complement of a ship or air-taxed only on income attributable to the fixed has in the United States.craft operated by a Hungarian enterprise inbase.

international traffic is exempt from U.S. tax. If theIncome that residents of India receive for Pay received by an individual for servicesship or aircraft is operated by a U.S. enterprise,

personal services performed in the United performed as an employee aboard a ship orthe pay is subject to U.S. tax.States as employees (dependent personal serv- aircraft operated by an Indonesian resident inices) is exempt from U.S. income tax if the re- international traffic is exempt from U.S. tax if thesidents meet three requirements. individual is a member of the regular comple-Iceland

ment of the ship or aircraft.• They are present in the United States forIncome that residents of Iceland receive for per- These exemptions do not apply to incomeno more than 183 days during the taxforming personal services as independent con- residents of Indonesia receive as public enter-year.t ractors or sel f -employed indiv iduals tainers (such as theater, motion picture, radio, or(independent personal services) in the United • The income is paid by, or on behalf of, an television artists, or musicians) or athletes ifStates during the tax year is exempt from U.S. employer who is not a resident of the their gross receipts, including reimbursed ex-income tax if the residents: United States. penses, are more than $2,000 during any con-

secutive 12-month period. Regardless of these• Are present in the United States for no • The income is not borne by a permanentlimits, income of Indonesian entertainers andmore than 182 days during the tax year, establishment, fixed base, or trade or busi-athletes is exempt from U.S. tax if their visit toand ness the employer has in the Unitedthe United States is substantially supported orStates.• Do not maintain a fixed base in the United sponsored by the Indonesian Government and

States for a period or periods totaling the Indonesian competent authority certifies thatThe exemption does not apply to pay receivedmore than 182 days during the tax year. the entertainers or athletes qualify for this ex-by a resident of India for services performed asemption.If they do not meet condition (2), they are taxed an employee aboard a ship or aircraft operated

on the income that is attributable to the fixed in international traffic by a U.S. enterprise.base. These exemptions do not apply to directors’ Ireland

fees and similar payments received by an IndianThis exemption does not apply to residents ofresident as a member of the board of directors ofIceland who are public entertainers (theater, Income that residents of Ireland receive for per-a company that is a U.S. resident.motion picture, or television artists, musicians, sonal services as independent contractors or

These exemptions do not apply to incomeor athletes) if they are in the United States for self-employed individuals (independent per-residents of India receive as public entertainersmore than 90 days during the tax year or their sonal services) in the United States is exempt




from U.S. income tax if they do not have a fixed These exemptions do not apply to income • Earn net income for those services that isnot more than $5,000 during the tax year ifbase regularly available to them in the United that residents of Israel receive as public enter-the income is from a U.S. contractor.States for performing the services. If they have a tainers (such as theater, motion picture, radio, or

fixed base available in the United States, they television artists, musicians, or athletes), if the If they have a fixed base available in the Unitedare taxed on the income attributable to the fixed gross amount of the income is more than $400 States, they are taxed only on the income that isbase. for each day they are in the United States per- attributable to the fixed base. There is no dollar

forming the services.Income that residents of Ireland receive for limit for condition (3) if the contractor is from aservices performed in the United States as em- country other than the United States.ployees (dependent personal services) is ex-

Income that residents of Jamaica receive forItalyempt from U.S. income tax if the residents meetpersonal services performed in the Unitedthe following requirements.

Income that residents of Italy receive for per- States as employees (dependent personal serv-• They are in the United States for no more forming personal services in the United States ices) is exempt from U.S. income tax if the re-

than 183 days in any 12-month period be- during the tax year as independent contractors sidents meet four requirements.ginning or ending in the tax year. or self-employed individuals (independent per- • They are in the United States for no moresonal services) is exempt from U.S. income tax if• Their income is paid by, or on behalf of, an than 183 days during the tax year.the residents:employer who is not a U.S. resident.

• Their income is paid by or for an employer• Are present in the United States for no• Their income is not borne by a permanent who is not a resident of the United States.more than 183 days in the tax year, andestablishment or a fixed base that the em-• Their income is not borne by a permanentployer has in the United States. • Do not have a fixed base regularly avail-

establishment or a fixed base that the em-able to them in the United States for per-

ployer has in the United States.These exemptions do not apply to directors’ forming the services.fees and similar payments received by a resi- • Their net income received for the services

If they have a fixed base available, they aredent of Ireland as a member of the board of is not more than $5,000 during the taxtaxed only on the income attributable to the fixeddirectors of a company that is a resident of the year.base.United States. However, amounts received for

attending meetings in Ireland are not subject to Pay received from employment as a memberIncome that residents of Italy receive for per-U.S. income tax. of the regular complement of a ship or an aircraftsonal services performed in the United States as

Income received by a resident of Ireland for operated in international traffic by a Jamaicanemployees (dependent personal services) is ex-services performed as an employee and mem- enterprise is exempt from U.S. tax. If the ship orempt from U.S. income tax if:ber of the regular complement of a ship or air- aircraft is operated by a U.S. enterprise, the pay• The residents are present in the Unitedcraft operated in international traffic is exempt is subject to U.S. tax.

States for not more than 183 days duringfrom U.S. income tax. These exemptions do not apply to incomethe tax year,These exemptions do not apply to public that residents of Jamaica receive for performing

entertainers (such as theater, motion picture, services in the United States as entertainers,• The income is paid by or for an employerradio, or television entertainers, musicians, and such as theater, motion picture, radio, or televi-who is not a U.S. resident, andathletes) from Ireland who earn more than sion artists, musicians, or athletes, if the gross• The income is not borne by a permanent$20,000 in gross receipts, including reimbursed receipts (excluding reimbursements for ex-

establishment or fixed base that the em-expenses, from their entertainment activities in penses) from the services are more than $400 aployer has in the United States. day or $5,000 for the tax year.the United States during the tax year.

Directors’ fees received by residents of Ja-Pay received by a resident of Italy from em-maica for services performed in the Unitedployment regularly exercised aboard a ship orIsrael States as members of boards of directors of U.S.aircraft operated by an Italian enterprise in inter-corporations are exempt from U.S. tax if the fees

national traffic is exempt from U.S. tax.Income that residents of Israel receive for per- (excluding reimbursed expenses) are not moreforming personal services as independent con- These exemptions do not apply to directors’ than $400 per day for each day the directors aretractors or as self-employed individuals fees and similar payments received by an Italian present in the United States to perform the serv-(independent personal services) in the United resident as a member of the board of directors of ices.States during the tax year is exempt from U.S. a company that is a U.S. resident.income tax if they are in the United States for no These exemptions do not apply to incomemore than 182 days during the tax year. residents of Italy receive as public entertainers Japan

Income that residents of Israel receive for (such as theater, motion picture, radio, or televi-Income that residents of Japan receive for per-labor or personal services performed in the sion artists, musicians, or athletes) if they aresonal services as independent contractors orUnited States as employees (dependent per- present in the United States for more than 90self-employed individuals is subject to the provi-sonal services), including income for services days during the tax year or their gross receipts,sions of Article 7 (business profits) of the treaty.performed by an officer of a corporation or com- including reimbursed expenses, are more thanUnder that provision, business profits are ex-pany, is exempt from U.S. income tax if the $12,000 during the tax year for their entertain-empt from U.S. income tax unless they have aresidents meet four requirements. ment activities in the United States.permanent establishment in the United States. If• They are in the United States for no more they have a permanent establishment available

than 182 days during the tax year. in the United States, they are taxed on the in-Jamaicacome attributable to the permanent establish-• They are employees of a resident of, or ament.Income that residents of Jamaica receive for thepermanent establishment in, Israel.

performance of personal services as indepen- Income that residents of Japan receive for• Their income is not borne by a permanent dent contractors or self-employed individuals services performed in the United States as em-establishment that the employer has in the (independent personal services) in the United ployees (dependent personal services) is ex-United States. States during the tax year is exempt from U.S. empt from U.S. income tax if the residents meetincome tax if the residents:• Their income is subject to Israeli tax. the following requirements.

• Are in the United States for no more than • They are in the United States for no moreThe exemption does not apply to pay received89 days during the tax year, than 183 days in any 12-month period be-by an employee for labor or personal services

ginning or ending in the tax year.performed as a member of the regular comple- • Do not have a fixed base regularly avail-ment of a ship or an aircraft operated in interna- able to them in the United States for per- • Their income is paid by, or on behalf of, antional traffic by a U.S. resident. forming their services, and employer who is not a U.S. resident.




• Their income is not borne by a permanent • Are in the United States for no more than complement of a ship or an aircraft operated ininternational traffic by a U.S. enterprise.establishment that the employer has in the 182 days during the tax year,

United States. The exemptions do not apply to directors’• Earn income for those services that is notfees and similar payments received by a resi-more than $3,000 during the tax year, andThe exemption does not apply to directors’ dent of Latvia as a member of the board of

fees and similar payments received by a resi- • Do not maintain a fixed base in the United directors or similar body of a company that is adent of Japan for services performed as a mem- States for more than 182 days during the U.S. resident.ber of the board of directors of a company that is tax year. The exemptions do not apply to income re-a resident of the United States. sidents of Latvia receive as public entertainersIf they maintain a fixed base in the United States

The exemption does not apply to a resident (such as theater, motion picture, radio, or televi-for more than 182 days, they are taxed on theof Japan who performs services as an employee sion artists, or musicians) or sportsmen if theirincome attributable to the fixed base.aboard a ship or an aircraft operated in interna- gross receipts, including reimbursed expenses,

Income that residents of Korea receive fortional traffic by a U.S. resident. are more than $20,000 for their personal activi-labor or personal services performed in the ties in the United States during the tax year.These exemptions do not apply to publicUnited States as employees (dependent per- Regardless of these limits, income of Latvianentertainers (such as theater, motion picture,sonal services), including pay for services per- entertainers or athletes is exempt from U.S. in-radio, or television artists, musicians, or ath-formed as an officer of a corporation, is exempt come tax if their visit to the United States isletes) from Japan who earn more than $10,000from U.S. tax if the residents meet four require- wholly or mainly supported by public funds ofin gross receipts, including reimbursed ex-ments. Latvia, its political subdivisions, or local authori-penses, from their entertainment activities in the

ties.United States during the tax year. • They are in the United States for no morethan 182 days during the tax year.

• They are employees of a resident of Korea LithuaniaKazakhstanor of a permanent establishment main-

Income that residents of Lithuania receive forIncome that residents of Kazakhstan receive for tained in Korea.performing personal services as independentperforming personal services as independent • Their compensation is not borne by a per- contractors or self-employed individuals (inde-contractors or self-employed individuals (inde-

manent establishment that the employer pendent personal services) in the United Statespendent personal services) in the United Stateshas in the United States. is exempt from U.S. income tax if the residents:is exempt from U.S. income tax if:

• Their income for those services is not • Are in the United States for no more than• The residents are in the United States formore than $3,000. 183 days in any 12-month period begin-no more than 183 days in any consecutive

ning or ending in the tax year, and12-month period, and Pay received by employees who are mem-• Do not have a fixed base regularly avail-bers of the regular complement of a ship or• The income is not attributable to a fixed

able to them in the United States for per-aircraft operated by a resident of Korea in inter-base in the United States which is regu-forming the services.larly available to the residents. national traffic is exempt.

If they have a fixed base available, they areIf the residents have a fixed base available, theytaxed only on the income attributable to the fixedare taxed only on the income attributable to the Latvia base.fixed base.

Income that residents of Lithuania receive forIncome that residents of Latvia receive for per-Income that residents of Kazakhstan receiveservices performed in the United States as em-forming personal services as independent con-for employment in the United States (dependentployees (dependent personal services) is ex-tractors or sel f -employed indiv idualspersonal services) is exempt from U.S. incomeempt from U.S. income tax if the following(independent personal services) in the Unitedtax if the following three requirements are met.requirements are met.States is exempt from U.S. income tax if the

• The resident is in the United States for no residents: • The resident is in the United States for nomore than 183 days in any 12-month pe-more than 183 days in any 12-month pe-• Are in the United States for no more thanriod.riod beginning or ending in the tax year.183 days in any 12-month period begin-

• The income is paid by, or on behalf of, an ning or ending in the tax year, and • The income is paid by, or on behalf of, anemployer who is not a resident of theemployer who is not a U.S. resident.• Do not have a fixed base regularly avail-United States.

able to them in the United States for per- • The income is not borne by a permanent• The income is not borne by a permanent forming the services. establishment or a fixed base that the em-establishment or a fixed base that the em-ployer has in the United States.If they have a fixed base available, they areployer has in the United States.

taxed only on the income attributable to the fixedThe exemption does not apply to pay receivedbase.Income derived by a resident of Kazakhstan

for employment as a member of the regularfrom employment as a member of the regular Income that residents of Latvia receive for complement of a ship or an aircraft operated incomplement of a ship or aircraft operated in services performed in the United States as em- international traffic by a U.S. enterprise.international traffic is exempt from U.S. tax. ployees (dependent personal services) is ex- The exemptions do not apply to directors’These exemptions do not apply to directors’ empt from U.S. income tax if the following fees and similar payments received by a resi-fees and similar payments received by a resi- requirements are met. dent of Lithuania as a member of the board ofdent of Kazakhstan as a member of the board ofdirectors or similar body of a company that is a• The resident is in the United States for nodirectors or similar body of a company that is aU.S. resident.more than 183 days in any 12-month pe-U.S. resident.

riod beginning or ending in the tax year. The exemptions do not apply to income re-sidents of Lithuania receive as public entertain-• The income is paid by, or on behalf of, aners (such as theater, motion picture, radio, orKorea, Republic of employer who is not a U.S. resident.television artists, or musicians) or sportsmen if

Income that residents of the Republic of Korea • The income is not borne by a permanent their gross receipts, including reimbursed ex-receive for performing personal services as inestablishment or a fixed base that the em- penses, are more than $20,000 for their per-dependent contractors or self-employed individ- ployer has in the United States. sonal activities in the United States during theuals (independent personal services) in the tax year. Regardless of these limits, income ofUnited States during the tax year is exempt from The exemption does not apply to pay received Lithuanian entertainers or athletes is exemptU.S. tax if the residents: for employment as a member of the regular from U.S. income tax if their visit to the United




States is wholly or mainly supported by public • The resident is present in the United a corporation does not qualify for this exemp-tion.States for no more than 183 days in afunds of Lithuania, its political subdivisions, or

Income received by an individual for per-12-month period.local authorities.forming labor or personal services as an em-• The income is paid by, or on behalf of, an ployee aboard a ship or an aircraft operated in

employer who is not a resident of the international traffic by a Moroccan resident isLuxembourgUnited States. exempt from U.S. income tax if the individual is a

Income that residents of Luxembourg receive for member of the regular complement of the ship or• The income is not borne by a permanentpersonal services as independent contractors or aircraft.establishment or fixed base that the em-self-employed individuals (independent per- These exemptions do not apply to incomeployer has in the United States.sonal services) in the United States is exempt received for services performed in the Unitedfrom U.S. income tax if they do not have a fixed States by professional entertainers, includingThese exemptions do not apply to director’sbase regularly available to them in the United theater, film, radio, and television performers,fees and similar payments received by a resi-

musicians, and athletes, unless the services areStates for performing the services. If they have a dent of Mexico for services performed outsideperformed by, or for the account of, a Moroccanfixed base available in the United States, they Mexico as a director or overseer of a companynonprofit organization.are taxed on the income attributable to the fixed that is a U.S. resident.

base. These exemptions do not apply to incomeresidents of Mexico receive as public entertain-Income that residents of Luxembourg re- Netherlandsers (such as theater, motion picture, radio, orceive for services performed in the Unitedtelevision artists, or musicians) or athletes if theStates as employees (dependent personal serv- Income that residents of the Netherlands re-income, including reimbursed expenses, isices) is exempt from U.S. income tax if the receive for performing personal services as inde-more than $3,000 during the tax year for their pendent contractors or self-employedsidents meet the following requirements.entertainment activities in the United States. individuals (independent personal services) in• They are in the United States for no more This includes income from activities performed the United States is exempt from U.S. income

than 183 days in any 12-month period be- in the United States relating to the entertainer or tax if the income is not attributable to a fixedginning or ending in the tax year. athlete’s reputation, such as endorsements of base in the United States that is regularly avail-

commercial products. Regardless of this limit, able for performing the services.• Their income is paid by, or on behalf of, anthe income of Mexican entertainers and athletes Income that residents of the Netherlands re-employer who is not a U.S. resident.

ceive for employment in the United States (de-is exempt from U.S. tax if their visit to the United• Their income is not borne by a permanent pendent personal services) is exempt from U.S.States is substantially supported by public fundsestablishment or a fixed base that the em- income tax if the following three requirementsof Mexico, its political subdivisions, or local au-ployer has in the United States. are met.thorities.

• The resident is in the United States for noThe exemption does not apply to pay receivedmore than 183 days during the tax year.for employment exercised continuously or Morocco

predominantly aboard a ship or aircraft operated • The income is paid by, or on behalf of, anIncome that residents of Morocco receive forin international traffic by a U.S. enterprise. employer who is not a U.S. resident.performing personal services as independentThe exemptions do not apply to directors’ • The income is not borne by a permanentcontractors or as self-employed persons (inde-fees and similar payments received by a resi- establishment or fixed base the employerpendent personal services) in the United Statesdent of Luxembourg for services performed in has in the United States.during the tax year is exempt from U.S. incomethe United States as a member of the board oftax if the residents:

directors of a company that is a resident of the Income received by a Netherlands resident for• Are in the United States for no more thanUnited States. employment as a member of the regular com-

182 days during the tax year, plement of a ship or aircraft operated in interna-The exemptions do not apply to public enter-tional traffic is exempt from U.S. tax.tainers (such as theater, motion picture, radio, or • Do not maintain a fixed base in the United

These exemptions do not apply to directors’television artists, musicians, or athletes) from States for more than 89 days during thefees and other similar payments received by aLuxembourg who earn more than $10,000 in tax year, andresident of the Netherlands for services per-gross receipts, including reimbursed expenses, • Earn total income for those services that is formed outside the Netherlands as a member offrom their entertainment activities in the United not more than $5,000. the board of directors of a company that is a

States during the tax year. resident of the United States.If they have a fixed base in the United States forThese exemptions do not apply to incomemore than 89 days, they are taxed only on the

residents of the Netherlands receive as publicMexico income attributable to the fixed base.entertainers (such as theater, motion picture,

Income that residents of Morocco receive for radio, or television artists, or musicians) or ath-Income that residents of Mexico receive for per-labor or personal services performed in the letes if the gross income, including reimbursedforming personal services as independent con-United States as employees (dependent per- expenses, is more than $10,000.tractors or sel f -employed indiv idualssonal services) is exempt from U.S. income tax if(independent personal services) in the Unitedthe residents meet three requirements.States is exempt from U.S. income tax if the New Zealandresidents: • They are in the United States for less than

183 days during the tax year. Income that residents of New Zealand receive• Are in the United States for no more thanfor performing personal services as indepen-183 days in a 12-month period, and • They are employees of a resident of Mo-dent contractors or self-employed individualsrocco or of a permanent establishment of• Do not have a fixed base that they regu- (independent personal services) in the Uniteda resident of a country other than Moroccolarly use for performing the services. States in any tax year is exempt from U.S. in-if the permanent establishment is locatedcome tax if the residents:If they have a fixed base available, they are in Morocco.

taxed only on income attributable to the fixed • Are present in the United States for no• Their income is not borne by a permanentbase. more than 183 days during any consecu-establishment that the employer has in thetive 12-month period, andIncome that residents of Mexico receive for United States.

employment in the United States (dependent • Do not have a fixed base regularly avail-personal services) is exempt from U.S. tax if the Compensation received for services per- able to them in the United States for per-following three requirements are met. formed by a member of the board of directors of forming the services.




If they have a fixed base available in the United • Their income is not borne by a permanent income is more than $100 a day or $3,000 forestablishment that the employer has in theStates, they are taxed on the income attributable the tax year. Regardless of these limits, incomeUnited States.to the fixed base. of Philippine entertainers is exempt from U.S.

tax if their visit to the United States is substan-Income that residents of New Zealand receive The exemption does not apply to a resident of tially supported or sponsored by the Philippinefor labor or personal services performed in the Norway who performs services as an employee Government and the entertainers are certifiedUnited States as employees (dependent per- aboard a ship or an aircraft operated by a Unitedas qualified for this exemption by the Philippinesonal services) is exempt from U.S. income tax if States resident in international traffic or in fish-competent authority.the residents meet these requirements. ing on the high seas if the resident of Norway is a

member of the regular complement of the ship or• They are present in the United States foraircraft.no more than 183 days in any consecutive Poland

12-month period.Income that residents of Poland receive for per-• Their income is paid by or on behalf of an Pakistan forming personal services as independent con-

employer that is not a resident of thetractors or sel f -employed indiv idualsResidents of Pakistan who perform personalUnited States.(independent personal services) in the Unitedservices (including professional services) for or

• Their income is not borne by a permanent States is exempt from U.S. income tax if they areon behalf of a resident of Pakistan while in theestablishment or fixed base of the em- United States for no more than 183 days during in the United States for no more than 182 daysployer in the United States. the tax year are exempt from U.S. income tax on during the tax year.

the income from the services if they are subject Income that residents of Poland receive forPay received by a New Zealand resident as to Pakistani tax.labor or personal services performed as employ-an employee and member of the regular com-ees (dependent personal services), includingplement of a ship or aircraft operated in interna-services performed by an officer of a corporationPhilippinestional traffic is exempt from U.S. tax.or company, in the United States during the taxThe exemption from U.S. tax on income from

Income that residents of the Philippines receive year is exempt from U.S. income tax if the re-both independent and dependent personal serv-for performing personal services as indepen- sidents meet three requirements.ices does not apply to public entertainers (art-dent contractors or as self-employed individuals

ists, athletes, etc.) from New Zealand who earn • They are in the United States for no more(independent personal services) in the Unitedmore than $10,000 in gross receipts, including than 182 days during the tax year.States during the tax year is exempt from U.S.reimbursed expenses, from their entertainment income tax if the residents: • Their income is paid by or on behalf of anactivities in the United States during the tax

employer who is not a U.S. resident.• Are in the United States for no more thanyear.89 days during the tax year, • Their income is not borne by a permanent

establishment that the employer has in the• Earn gross income for those services thatNorway is not more than $10,000 for the tax year if United States.

the income is from U.S. contractors, andIncome that residents of Norway receive for per-Pay received by employees who are mem-forming personal services as independent con- • Do not have a fixed base regularly avail-

bers of the regular complement of a ship orable to them in the United States for per-t ractors or sel f -employed indiv idualsaircraft operated by a resident of Poland in inter-forming their services.(independent personal services) in the Unitednational traffic is exempt from U.S. tax.States during the tax year is exempt from U.S. If they have a fixed base available in the United

income tax if the residents: States, they are taxed only on the income attrib-utable to the fixed base. There is no dollar limit• Are present in the United States for no Portugalfor condition (2) if the contractor is a resident of amore than 182 days during the tax year,

Income that residents of Portugal receive forcountry other than the United States.andperforming personal services as independentIncome that residents of the Philippines re-• Do not maintain a fixed base in the United contractors or self-employed individuals (inde-ceive for personal services performed in theStates for more than 182 days during the pendent personal services) in the United StatesUnited States as employees (dependent per-tax year. is exempt from U.S. income tax if the residents:sonal services) is exempt from U.S. income tax if

If they do not meet requirement (2), they are the residents meet three requirements. • Are in the United States for no more thantaxed only on the income attributable to the fixed 182 days in any 12-month period, and• They are in the United States for no morebase.

than 89 days during the tax year. • Do not have a fixed base regularly avail-This exemption does not apply to residents of

able to them in the United States for per-• They are employees of a resident of theNorway who are public entertainers (theater,forming the activities.Philippines or of a permanent establish-motion picture, or television artists, musicians,

ment maintained in the Philippines. If they have a fixed base available, they areor athletes) if they are in the United States for• Their income is not borne by a permanent taxed only on the income attributable to the fixedmore than 90 days during the tax year or their

establishment that the employer has in thepay for services as public entertainers is more base.United States.than $10,000 during the tax year. Income that residents of Portugal receive for

Income that residents of Norway receive for employment in the United States (dependentPay received by an employee of a resident oflabor or personal services performed in the personal services) is exempt from U.S. incomethe Philippines for personal services performedUnited States as employees (dependent per- tax if the following three requirements are met.as a member of the regular complement of asonal services) is exempt from U.S. income tax ifship or an aircraft operated in international traffic • The resident is in the United States for nothe residents meet three requirements.by a resident of the Philippines is exempt from more than 183 days in any 12-month pe-• They are in the United States less than U.S. tax. riod.

183 days during the tax year.These exemptions do not apply to income • The income is paid by, or on behalf of, an• They are employees of a resident of Nor- residents of the Philippines receive for perform- employer who is not a U.S. resident.

way or of a permanent establishment of a ing services (both independent and dependent• The income is not borne by a permanentresident of a state other than Norway if the personal services) in the United States as enter-

establishment or fixed base that the em-permanent establishment is situated in tainers, such as theater, motion picture, radio, orployer has in the United States.Norway. television artists, musicians, or athletes, if the




Income received by a resident of Portugal for If they have a fixed base available, they areRussiaemployment as a member of the regular com- taxed only on income attributable to the fixed

Income that residents of Russia receive for per-plement of a ship or aircraft operated in interna- base.forming personal services as independent con-tional traffic is exempt from U.S. tax.

Income that residents of the Slovak Republictractors or sel f -employed indiv idualsThese exemptions do not apply to incomereceive for employment in the United States(independent personal services) in the Unitedresidents of Portugal receive as public entertain-(dependent personal services) is exempt fromStates is exempt from U.S. income tax if:ers (such as theater, motion picture, radio, orU.S. income tax if the following three require-

television artists, or musicians) or athletes if that • The residents are in the United States for ments are met.income, including reimbursed expenses, is no more than 183 days during the calen- • The resident is present in the Unitedmore than $10,000. The income of Portuguese dar year, or

States for no more than 183 days in anyentertainers and athletes is exempt from U.S.• The income is not attributable to a fixed 12-month period.tax if their visit to the United States is substan-

base in the United States which is regu-tially supported by public funds of Portugal or its • The income is paid by, or on behalf of, anlarly available to the residents.political or administrative subdivisions. employer who is not a U.S. resident.These exemptions do not apply to directors’ If the residents have a fixed base available, they • The income is not borne by a permanentfees and similar payments received by a resi- are taxed only on the income attributable to the

establishment or a fixed base that the em-dent of Portugal for services performed outsidefixed base. ployer has in the United States.of Portugal as a member of the board of direc-

tors of a company that is a resident of the United Income that residents of Russia receive forThese exemptions do not apply to incomeStates. employment in the United States (dependent

residents of the Slovak Republic receive as pub-personal services) is exempt from U.S. incomelic entertainers (such as theater, motion picture,tax if the following three requirements are met.

Romania radio, or television artists, or musicians) or• The resident is in the United States for no sportsmen if their gross receipts, including reim-more than 183 days during the calendarIncome that residents of Romania receive for bursed expenses, are more than $20,000 duringyear.performing personal services as independent the tax year. Regardless of these limits, income

contractors or self-employed individuals (inde- of Slovak entertainers and sportsmen is exempt• The income is paid by, or on behalf of, anpendent personal services) in the United States from U.S. income tax if their visit to the Unitedemployer who is not a resident of theduring the tax year is exempt from U.S. income States is substantially supported by public fundsUnited States.tax if the residents: of the Slovak Republic, its political subdivisions,

• The income is not borne by a permanent or local authorities, or the visit is made pursuant• Are present in the United States for no establishment or a fixed base that the em- to a specific arrangement between the Unitedmore than 182 days during the tax year, ployer has in the United States. States and the Slovak Republic.andThese exemptions do not apply to directors’However, income from employment directly• Do not maintain a permanent establish- fees and similar payments received by a resi-connected with a place of business that is not a

ment in the United States with which the dent of the Slovak Republic for services per-permanent establishment is exempt if the resi-income is effectively connected. formed in the United States as a member of thedent is present in the United States not longerboard of directors of a company that is a residentthan 12 consecutive months. For this purpose, aIncome that residents of Romania receive for of the United States.place of business means a construction site,labor or personal services performed as employ- Income from employment as a member ofassembly or installation project, or drilling opera-ees (dependent personal services), including the regular complement of a ship or aircrafttion.services performed by an officer of a corporation operated by a Slovak enterprise in international

or company, in the United States during the tax Income derived by a resident of Russia from traffic is exempt from U.S. income tax. If the shipyear is exempt from U.S. income tax if the re- employment as a member of the regular com- or aircraft is operated by a U.S. enterprise, thesidents meet these requirements. plement of a ship or aircraft operated in interna- income is subject to U.S. income tax.

tional traffic is exempt from U.S. tax.• They are in the United States for no moreIncome from technical services directly con-than 182 days during the tax year.

Slovenianected with the application of a right or property• They are employees of a resident of giving rise to a royalty is exempt if those servicesRomania or of a permanent establishment Income that residents of Slovenia receive forare provided as part of a contract granting themaintained in Romania by a resident of personal services as independent contractors oruse of the right or property.the United States. self-employed individuals (independent per-

These exemptions do not apply to directors’ sonal services) in the United States is exempt• Their income is not borne by a permanent fees and similar payments received by a resi- from U.S. income tax if they do not have a fixedestablishment that the employer has in the dent of Russia as a member of the board of base regularly available to them in the UnitedUnited States. directors or similar body of a company that is a States for performing the services. If they have a

resident of the United States. fixed base available in the United States, theyThese exemptions do not apply to entertain-are taxed on the income attributable to the fixeders, such as theater, motion picture, radio, orbase.television artists, musicians, or athletes, who are Slovak Republic Income that residents of Slovenia receive forpresent in the United States for more than 90services performed in the United States as em-Income that residents of the Slovak Republicdays during the tax year (90 days or more if theployees (dependent personal services) is ex-receive for performing personal services as in-entertainers are employees) or who earn grossempt from U.S. income tax if the residents meetdependent contractors or self-employed individ-income as entertainers in the United States ofthe following requirements.uals (independent personal services) in themore than $3,000 during the tax year ($3,000 or

United States is exempt from U.S. income tax ifmore if they are employees). However, the ex- • They are in the United States for no morethe residents:emptions do apply, without regard to the 90 day, than 183 days in any 12-month period be-

$3,000 requirement, if the entertainers are pres- ginning or ending in the tax year.• Are present in the United States for noent in the United States by specific arrange- more than 183 days in any 12-month pe- • Their income is paid by, or on behalf of, anments between the United States and Romania. riod, and employer who is not a U.S. resident.

Pay received by employees who are mem-• Do not have a fixed base regularly avail-bers of the regular complement of a ship or • Their income is not borne by a permanent

able to them in the United States for per-aircraft operated by a resident of Romania in establishment or a fixed base that the em-forming the activities.international traffic is exempt from U.S. tax. ployer has in the United States.




These exemptions do not apply to directors’ funds of South Africa, its political subdivisions, • They are in the United States for no moreor local authorities. than 183 days in any 12-month period.fees and similar payments received by a resi-

dent of Slovenia for services performed in the Income received by a resident of South Af- • Their income is paid by, or on behalf of, anUnited States as a member of the board of rica for services performed as an employee and employer who is not a U.S. resident.directors of a company that is a resident of the member of the complement of a ship or aircraft

• Their income is not borne by a permanentUnited States. operated in international traffic is exempt fromestablishment or a fixed base that the em-U.S. income tax.Income received by a Slovenian resident forployer has in the United States.employment as a member of the regular com-

plement of a ship or aircraft operated in interna-Income received from employment as a mem-Spaintional traffic is exempt from U.S. tax.

ber of the regular complement of a ship or anThese exemptions do not apply to income aircraft operated in international traffic by a SriIncome that residents of Spain receive as inde-

residents of Slovenia receive as public enter- Lanka enterprise is exempt from U.S. tax. If thependent contractors or self-employed individu-tainers (such as theater, motion picture, radio, or ship or aircraft is operated by a U.S. enterprise,als (independent personal services) in thetelevision artists, or musicians) or athletes if the income is subject to U.S. tax.United States is exempt from U.S. income tax iftheir gross receipts, including reimbursed ex- the residents do not have a fixed base available These exemptions do not apply to publicpenses, are more than $15,000 during the tax to them in the United States for performing the entertainers (such as theater, motion picture,year. Regardless of these limits, income of Slo- services. If they have a fixed base, they are radio, or television entertainers, musicians, andvenian entertainers or athletes is exempt from taxed only on the income attributable to the fixed athletes) from Sri Lanka who earn more thanU.S. tax if their visit to the United States is wholly base. $6,000 in gross receipts, including reimbursedor mainly paid by public funds of either the expenses, from their entertainment activities inIncome that residents of Spain receive forUnited States or Slovenia or their political subdi- the United States during the tax year. Regard-personal services performed in the Unitedvisions, or local authorities. less of these limits, income of Sri Lanka enter-States as employees (dependent personal serv-

tainers is exempt from U.S. income tax if theirices) is exempt from U.S. income tax if:visit to the United States is directly or indirectly• The residents are present in the UnitedSouth Africa supported wholly or substantially by public funds

States no more than 183 days in any of Sri Lanka or the United States, their politicalIncome that residents of South Africa receive for 12-month period, subdivisions, or local authorities.performing personal services as independent • The income is paid by, or on behalf of, an These exemptions do not apply to directors’contractors or self-employed individuals (inde-employer who is not a U.S. resident, and fees and other compensation received by a resi-pendent personal services) in the United States

dent of Sri Lanka for services performed in theis exempt from U.S. income tax if the residents: • The income is not borne by a permanentUnited States as a member of the board ofestablishment or fixed base the employer• Are in the United States for no more than directors of a company resident in the Unitedhas in the United States.183 days in any 12-month period begin- States.

ning or ending in the tax year, and The exemption does not apply to pay receivedby employees who are members of a regular• Do not have a fixed base regularly avail- Swedencomplement of a ship or aircraft operated inable to them in the United States for per-international traffic by a U.S. enterprise.forming the services. Income that residents of Sweden receive for

These exemptions do not apply to public performing personal services as independentIf they have a fixed base available, they areentertainers (such as theater, motion picture, contractors or self-employed individuals (inde-taxed only on income attributable to the fixedradio, or television artists, or musicians) or ath- pendent personal services) in the United Statesbase.letes from Spain who earn more than $10,000 in during the tax year is exempt from U.S. income

Income that residents of South Africa receive income, including reimbursed expenses, from tax if they do not have a fixed base regularlyfor services performed in the United States as their entertainment activities in the United States available to them in the United States for per-employees (dependent personal services) is ex- during the tax year. Regardless of these limits, forming the services. If they have a fixed baseempt from U.S. income tax if the following re- Spanish entertainers and athletes are exempt available in the United States, they are taxed onquirements are met. from U.S. tax if their visit to the United States is the income attributable to the fixed base.

substantially supported by public funds of Spain, Income that residents of Sweden receive for• The resident is in the United States for noa political subdivision, or local authority. labor or personal services performed in themore than 183 days in any 12-month pe-

United States as employees (dependent per-riod beginning or ending in the tax year.sonal services) is exempt from U.S. income tax if

• The income is paid by, or on behalf of, an Sri Lanka the residents meet three requirements.employer who is not a U.S. resident.

Income that residents of Sri Lanka receive for • They are in the United States for no more• The income is not borne by a permanent performing personal services as independent than 183 days during any consecutive

establishment or a fixed base that the em- contractors or self-employed individuals (inde- 12-month period.ployer has in the United States. pendent personal services) in the United States • Their income is paid by, or on behalf of, anduring the tax year is exempt from U.S. income

employer who is not a resident of theThese exemptions do not apply to directors’ tax if the residents:United States.fees and similar payments received by a resi-

• Are in the United States for no more thandent of South Africa for services performed in • Their income is not borne by a permanent183 days in any 12-month period, orthe United States as a member of the board of establishment or a fixed base that the em-directors of a company resident in the United • Do not have a fixed base regularly avail- ployer has in the United States.States. able to them in the United States for the

purpose of performing the services. Income received by a resident of Sweden forThese exemptions do not apply to incomeemployment as a member of the regular com-residents of South Africa receive as public enter-

If they have a fixed base available in the plement of a ship or aircraft operated in interna-tainers (such as theater, motion picture, radio, orUnited States, they are taxed on the income tional traffic is exempt from U.S. tax.television artists, or musicians) or athletes ifattributable to the fixed base.their gross receipts, including reimbursed ex- These exemptions do not apply to income

penses, are more than $7,500 during the tax Income that residents of Sri Lanka receive residents of Sweden receive as public entertain-year. Regardless of these limits, income of for services performed in the United States as ers (such as theater, motion picture, radio, orSouth African entertainers or athletes is exempt employees (dependent personal services) is ex- television artists, or musicians) or athletes if thefrom U.S. income tax if their visit to the United empt from U.S. income tax if the residents meet gross income, including reimbursed expenses,States is wholly or mainly supported by public the following requirements. is more than $6,000 for any 12-month period.




These exemptions do not apply to directors’ by a U.S. resident or borne by a permanent Tunisiafees received by a resident of Sweden for serv- establishment or fixed base in the United States.

Income that residents of Tunisia receive for per-ices performed outside of Sweden as a member Income that residents of Thailand receive for forming personal services as independent con-of the board of directors of a company that is a services performed in the United States as em- tractors or sel f -employed indiv idualsresident of the United States.ployees (dependent personal services) is ex- (independent personal services) in the Unitedempt from U.S. income tax if the following States are exempt from U.S. income tax if:requirements are met.Switzerland • They are in the United States for no more

• The resident is in the United States for no than 183 days during the tax year,Income that residents of Switzerland receive formore than 183 days in any 12-month pe-personal services as independent contractors or • They do not have a fixed base regularlyriod beginning or ending in the tax year.self-employed individuals (independent per- available in the United States for perform-

sonal services) that they perform during the tax • The income is paid by, or on behalf of, an ing the services, andyear in the United States is exempt from U.S. employer who is not a U.S. resident. • The gross income for the tax year fromincome tax if they do not have a fixed base

• The income is not borne by a permanent U.S. residents for services performed inregularly available to them in the United Statesestablishment or a fixed base that the em- the United States is no more than $7,500.for performing the services. If they have a fixedployer has in the United States.base available in the United States, they are

If they do not meet condition (2), they aretaxed on the income attributable to the fixedThese exemptions do not apply to directors’ taxed on the income that is attributable to thebase.

fees and similar payments received by a resi- fixed base.Income that residents of Switzerland receivedent of Thailand for services performed outsidefor services performed in the United States as Income that residents of Tunisia receive forof Thailand as a member of the board of direc-employees (dependent personal services) is ex- personal services performed in the United

empt from U.S. income tax if the residents meet tors of a company that is a resident of the United States as employees (dependent personal serv-the following requirements. ices) is exempt from U.S. income tax if:States.

These exemptions do not apply to income• They are in the United States for no more • The residents are in the U.S. for no morethan 183 days in any 12-month period be- residents of Thailand receive for performing than 183 days during the tax year,ginning or ending in the tax year. services in the United States as entertainers • Their income is paid by, or on behalf of, an

(such as theater, motion picture, radio, or televi-• Their income is paid by, or on behalf of, an employer who is not a resident of thesion artists, or musicians) and athletes, if theemployer who is not a U.S. resident. United States, andincome is more than $100 a day or $3,000 for• Their income is not borne by a permanent • Their income is not borne by a permanentthe tax year. Regardless of these limits, income

establishment or a fixed base that the em- establishment or fixed base the employerof Thai entertainers is exempt from U.S. tax ifployer has in the United States. has in the United States.their visit to the United States is substantially

supported by public funds of Thailand or itsThese exemptions do not apply to directors’ Pay received by employees who are mem-political subdivisions or local authorities.fees and similar payments received by a resi- bers of the regular complement of a ship or

dent of Switzerland as a member of the board of The exemption does not apply to pay re- aircraft operated by an enterprise in interna-directors of a company that is a resident of the ceived by employees who are members of the tional traffic is exempt from U.S. tax if the placeUnited States. regular complement of a ship or aircraft oper- of management of the enterprise is in Tunisia.

These exemptions do not apply to public ated in international traffic by a U.S. enterprise. However, if the enterprise is created under theentertainers (such as theater, motion picture, laws of the United States (or a U.S. state), theradio, or television entertainers, musicians, and pay is subject to U.S. tax.athletes) from Switzerland who earn more than Trinidad and Tobago These exemptions do not apply to income$10,000 in gross receipts, including reimbursed residents of Tunisia receive as public entertain-Income (including reimbursed travel expenses)expenses, from their entertainment activities in ers (such as theater, motion picture, radio, or

that residents of Trinidad and Tobago receivethe United States during the tax year.television artists, and musicians) or athletes if

during the tax year for personal services per-Income received by a resident of Switzerland their gross receipts, including reimbursed ex-for services performed as an employee and formed in the United States is exempt from U.S. penses, are more than $7,500 during the taxmember of the regular complement of a ship or income tax if the individuals are in the United year.aircraft operated in international traffic is exempt States for no more than 183 days during the tax These exemptions do not apply to fees re-from U.S. income tax. year and either: ceived by a resident of Tunisia for services per-

formed as a director of a U.S. corporation if the• The residents are employees of a residentfees are treated as a distribution of profits andof a country other than the United StatesThailandcannot be taken as a deduction by the corpora-or are employees of a permanent estab-

Income that residents of Thailand receive for tion.lishment of a U.S. resident outside theperforming personal services as independent United States and the income is not de-contractors or as self-employed individuals (in- ducted in figuring the profits of a perma-dependent personal services) in the United Turkey

nent establishment in the United States, orStates during the tax year is exempt from U.S.Income that residents of Turkey receive for per-income tax if the residents: • The income is not more than $3,000 (ex-forming personal services as independent con-cluding reimbursed travel expenses).• Are in the United States for no more than tractors or sel f -employed indiv iduals

89 days during the tax year, and (independent personal services) in the UnitedThese exemptions do not apply to the profes-States is exempt from U.S. income tax if the• Do not have a fixed base regularly avail- sional earnings of public entertainers such asresidents:able to them in the United States for per- actors, musicians, and professional athletes or

forming their services. to any person providing their services if the pay • Are in the United States for purposes ofis more than $100 per day (excluding reim- performing the services or activities for noIf they have a fixed base available in the United

more than 183 days in any 12-month pe-bursed travel expenses).States, they are taxed only on the income attrib-riod, andutable to the fixed base. Pay received by members of the regular

complement of a ship or aircraft operated in • Do not have a fixed base regularly avail-This exemption does not apply if a resident ofinternational traffic by a resident of Trinidad and able to them in the United States for per-Thailand earns more than $10,000 for indepen-

dent personal services and that income is paid Tobago is exempt from U.S. tax. forming the services.




If they have a fixed base available, they are of a company that is a resident of the United States for performing the services. If they have aStates. fixed base available, they are taxed on the in-taxed only on income attributable to the fixed

come attributable to the fixed base.These exemptions generally do not apply tobase.income received as a public entertainer (such as Income that residents of Venezuela receive

Income that residents of Turkey receive for a theater, motion picture, radio, or television for services performed in the United States asservices performed in the United States as em- artist, musician, or athlete). However, income of employees (dependent personal services) is ex-ployees (dependent personal services) is ex- Ukrainian entertainers and sportsmen is exempt empt from U.S. income tax if the residents meetempt from U.S. income tax if the following from U.S. income tax if their visit to the United the following requirements.requirements are met. States is substantially supported by public funds • They are in the United States for no more

of Ukraine, its political subdivisions, or local au-• The resident is in the United States for no than 183 days in any 12-month period be-thorities, or the visit is made pursuant to a spe-more than 183 days in any 12-month pe- ginning or ending in the tax year.cific arrangement between the United Statesriod.and Ukraine. • Their income is paid by, or on behalf of, an

• The income is paid by, or on behalf of, an employer who is not a U.S. resident.Income derived by a resident of Ukraine fromemployer who is not a U.S. resident. employment as a member of the regular com- • The income is not borne by a permanent

plement of a ship or aircraft operated in interna-• The income is not borne by a permanent establishment or a fixed base that the em-tional traffic is exempt from U.S. tax.establishment or a fixed base that the employer has in the United States.

ployer has in the United States.These exemptions do not apply to directors’United KingdomThis exemption does not apply to a resident of fees and similar payments received by a resi-

Turkey who performs services as a member of dent of Venezuela for services performed in theIncome that residents of the United Kingdomthe regular complement of a ship or an aircraft United States as a member of the board ofreceive for personal services as independentoperated by a U.S. resident in international traf- directors of a company resident in the Unitedcontractors or self-employed individuals arefic. States.subject to the provisions of Article 7 (Business

Pay received by a resident of Venezuela forThese exemptions do not apply to directors’ Profits) of the treaty. Under that provision, busi-services performed as an employee of a ship orfees and similar payments received by a resi- ness profits are exempt from U.S. income taxan aircraft operated in international traffic is ex-dent of Turkey for services provided in the unless they have a permanent establishment inempt from U.S. income tax.United States as a member of the board of the United States. If they have a permanent

These exemptions do not apply to incomedirectors of a company that is a resident of the establishment available in the United States,residents of Venezuela receive as public enter-United States. they are taxed on the income attributable to thetainers (such as theater, motion picture, radio, orpermanent establishment.These exemptions do not apply to incometelevision artists, or musicians) or sportsmen ifIncome that residents of the United Kingdomresidents of Turkey receive as public entertain-their gross income, including reimbursed ex-receive for services performed in the Uniteders (such as theater, motion picture, radio, orpenses, is more than $6,000 for their personalStates as employees (dependent personal serv-television artists, or musicians) or athletes ifactivities in the United States during the taxices) is exempt from U.S. income tax if the re-their gross receipts are more than $3,000 duringyear. Regardless of these limits, income of Ven-sidents meet the following requirements.the tax year for their entertainment activities inezuelan entertainers or athletes is exempt fromthe United States. If their visit to the United • They are in the United States for no more U.S. income tax if their visit to the United States

States is substantially supported by a Turkish than 183 days in any 12-month period be- is wholly or mainly supported by public funds ofnon-profit organization or from the public funds ginning or ending in the tax year. Venezuela, its political subdivisions, or local au-of Turkey, its political subdivisions, or local authorities.• Their income is paid by, or on behalf of, anthorities, the income is taxed as independent

employer who is not a U.S. resident.personal services or dependent personal serv- Professors, Teachers,ices. • Their income is not borne by a permanentand Researchersestablishment that the employer has in the

United States.Pay of professors and teachers who are re-Ukrainesidents of the following countries is generallyThese exemptions do not apply to directors’exempt from U.S. income tax for 2 or 3 years ifIncome that residents of Ukraine receive for fees and similar payments received by a resi-they temporarily visit the United States to teachperforming personal services as independent dent of the United Kingdom for services per-or do research. The exemption applies to paycontractors or self-employed individuals (inde- formed in the United States as a member of theearned by the visiting professor or teacher dur-pendent personal services) in the United States board of directors of a company resident in theing the applicable period. For most of the follow-is exempt from U.S. income tax if the income is United States.ing countries, the applicable period begins onnot attributable to a fixed base in the United These exemptions do not apply to publicthe date of arrival in the United States for theStates that is regularly available for performing entertainers (such as theater, motion picture,purpose of teaching or engaging in research.the services. radio, or television artists, musicians, or ath-Furthermore, for most of the following countries,letes) from the United Kingdom who earn moreIncome that residents of Ukraine receive forthe exemption applies even if the stay in thethan $20,000 in gross receipts, including reim-employment in the United States (dependentUnited States extends beyond the applicablebursed expenses, from their entertainment ac-personal services) is exempt from U.S. incomeperiod.tivities in the United States during the tax year.tax if the following three requirements are met.

The exemption generally applies to pay re- Income received by a resident of the United• The resident is in the United States for no ceived during a second teaching assignment ifKingdom for services performed as an em-more than 183 days during the tax year. both are completed within the specified time,ployee and member of the regular complement

even if the second assignment was not arrangedof a ship or aircraft operated in international• The income is paid by, or on behalf of, anuntil after arrival in the United States on the firsttraffic is exempt from U.S. income tax.employer who is not a resident of theassignment. For each of the countries listed, theUnited States.conditions are stated under which the pay of a

• The income is not borne by a permanent professor or teacher from that country is exemptVenezuelaestablishment or a fixed base that the em- from U.S. income tax.ployer has in the United States. Income that residents of Venezuela receive for If you do not meet the requirements for ex-

personal services as independent contractors or emption as a teacher or if you are a resident of aThese exemptions do not apply to directors’ self-employed individuals (independent per- treaty country that does not have a special provi-

fees and similar payments received by a resi- sonal services) in the United States is exempt sion for teachers, you may qualify under a per-dent of Ukraine for services performed outside from U.S. income tax if they do not have a fixed sonal services income provision discussedof Ukraine as a member of the board of directors base regularly available to them in the United earlier.




This exemption does not apply to incomeBangladesh Commonwealth offrom research carried on mainly for the privateIndependent States (C.I.S.)

An individual is exempt from U.S. income tax on benefit of any person rather than in the publicAn individual who is a resident of a C.I.S. mem-income from teaching or research for not more interest.ber on the date of arrival in the United Statesthan 2 years from the date of arrival for suchand who is temporarily in the United States atpurposes if he or she:the invitation of the U.S. Government or an edu- France• Is a resident of Bangladesh immediately cational or scientific research institution in the

before visiting the United States, and An individual who is a resident of France on theUnited States primarily to teach, engage in re-date of arrival in the United States and who issearch, or participate in scientific, technical, or• Is in the United States to teach or engage

professional conferences is exempt from U.S. temporarily in the United States at the invitationin research at a university, college, orincome tax on income for teaching, research, or of the U.S. Government, a university, or otherother recognized educational institution.participation in these conferences for a maxi- recognized educational or research institution inmum period of 2 years. the United States primarily to teach or engage inThis exemption does not apply to income from

This exemption does not apply to income research, or both, at a university or other educa-research carried on mainly for the private benefitfrom research carried on mainly for the benefit of tional or research institution is exempt from U.S.of any person rather than in the public interest.a private person, including a commercial enter- income tax on income from teaching or researchprise of the United States or a foreign trade for a maximum of 2 years from the date of arrivalorganization of a C.I.S. member. in the United States.Belgium

The exemption does, however, apply if the An individual may claim this benefit onlyresearch is conducted through an intergovern- once. Also, this benefit and the benefits de-Note. See the effective dates of the new mental agreement on cooperation. scribed later under Students and Apprentices

treaty under What’s New at the beginning of this This exemption also applies to journalists can be claimed for no more than 5 years.and correspondents who are temporarily in thepublication.

This exemption does not apply to incomeUnited States for periods not longer than 2 yearsfrom research carried on mainly for the privateand who receive their compensation from

New treaty. An individual who is a resident of benefit of any person rather than in the publicabroad. It is not necessary that the journalists orBelgium at the beginning of the visit to the interest.correspondents be invited by the U.S. Govern-United States and who is temporarily in the ment or other appropriate institution, nor does itUnited States to teach or carry on research at a matter that they are employed by a private per-school, college, university or other educational Germanyson, including commercial enterprises and for-or research institution is exempt from U.S. in- eign trade organizations.come tax for a period not exceeding 2 years

Note. See the effective dates of the protocolfrom the date of arrival in the United States onunder What’s New at the beginning of this publi-Czech Republicincome received for teaching or carrying on re-cation.

search.An individual is exempt from U.S. income tax on

This exemption does not apply to income income for teaching or research for up to 2 years Treaty as modified. A professor or teacherfrom research carried on mainly for the private if he or she: who is a resident of Germany and who is tempo-benefit of any person rather than in the publicrarily in the United States to engage in advanced• Is a resident of the Czech Republic imme-interest.study or research or teaching at an accrediteddiately before visiting the United States,educational institution or institution engaged inand

Former treaty. An individual who is a resident research for the public benefit is exempt from• Is in the United States primarily to teach orof Belgium on the date of arrival in the United U.S. tax on income received for such study,conduct research at a university, college,

research, or teaching for a maximum of 2 yearsStates and who is temporarily in the United school, or other accredited educational orfrom the date of arrival in the United States.States at the invitation of the U.S. Government, research institution.

a university, or other recognized educational The exemption does not apply to incomeinstitution in the United States primarily to teach from research carried on mainly for the privateA Czech resident is entitled to these benefitsor engage in research, or both, at a university or benefit of any person rather than in the publiconly once. However, the exemption does notother accredited educational institution is ex- interest. The exemption does not apply if, duringapply if:empt from U.S. income tax on income for the the preceding period, the benefit described in• The resident claimed during the immediate

paragraph (2), (3), or (4) of Article 20 of theteaching or research for a maximum of 2 years preceding period the benefits describedtreaty, pertaining to students, was claimed.from the date of arrival in the United States. later under Students and Apprentices, or

This exemption does not apply to income • The income is from research undertakenfrom research carried on mainly for the private Unmodified treaty. A professor or teacherprimarily for the private benefit of a spe-benefit of any person rather than in the public who is a resident of Germany and who is in thecific person or persons.interest. United States for not more than 2 years to en-

gage in advanced study or research or teachingEgypt at an accredited educational institution or institu-

China, People’s Republic of tion engaged in research for the public benefit isAn individual who is a resident of Egypt on the exempt from U.S. tax on income received fordate of arrival in the United States and who isAn individual who is a resident of the People’s such study, research, or teaching. If the individ-temporarily in the United States primarily toRepublic of China and who is temporarily in the ual’s visit to the United States exceeds 2 years,teach or engage in research, or both, at a univer-United States primarily to teach, lecture, or con- the exemption is lost for the entire visit unlesssity or other recognized educational institution isduct research at a university or other accredited the competent authorities of Germany and theexempt from U.S. income tax on income fromeducational institution or scientific research in- United States agree otherwise.the teaching or research for a maximum of 2stitution is exempt from U.S. income tax on in-

The exemption does not apply to incomeyears from the date of arrival in the Unitedcome for the teaching, lecturing, or research for from research carried on mainly for the privateStates. The individual must have been invited toa total of not more than 3 years. benefit of any person rather than in the publicthe United States for a period not expected to beThis exemption does not apply to income interest. The exemption does not apply if, duringlonger than 2 years by the U.S. Government or a

from research carried on mainly for the private the preceding period, the benefit described instate or local government, or by a university orbenefit of any person rather than in the public paragraph (2), (3), or (4) of Article 20 of theother recognized educational institution in the

treaty, pertaining to students, was claimed.interest. United States.




This exemption does not apply to incomeGreece Indonesiafrom research carried on mainly for the private

A professor or teacher who is a resident of An individual is exempt from U.S. tax on income benefit of any person rather than in the publicfor teaching or research for a maximum of 2Greece and who is temporarily in the United interest.years from the date of arrival in the UnitedStates to teach at a university, college, or otherStates if he or she:educational institution for a maximum of 3 years

Japanis exempt from U.S. income tax on the income • Is a resident of Indonesia immediatelyreceived for teaching during that period. before visiting the United States, and An individual who is a resident of Japan and who

is temporarily in the United States primarily to• Is in the United States at the invitation of ateach or engage in research at a university,university, school, or other recognized ed-Hungary college, or other recognized educational institu-ucational institution to teach or engage intion is exempt from U.S. income tax on incomeresearch, or both, at that educational insti-An individual who is a resident of Hungary on thefor the teaching or research for a maximum of 2tution.date of arrival in the United States and who isyears from the date of arrival in the Unitedtemporarily in the United States primarily toStates.A resident of Indonesia is entitled to this ex-teach or engage in research, or both, at a univer- The exemption does not apply to incomeemption only once. But this exemption does notsity or other recognized educational institution is from research carried on mainly for the privateapply to income from research carried on mainlyexempt from U.S. income tax on income for the benefit of any person rather than in the publicfor the private benefit of any person.

teaching or research for a maximum of 2 years interest.from the date of arrival in the United States. Theindividual must have been invited to the United Former treaty. An individual entitled to theIsraelStates for a period not expected to be longer teacher and researcher benefits under the for-

An individual who is a resident of Israel on thethan 2 years by the U.S. Government or a state mer treaty may continue to claim those benefitsdate of arrival in the United States and who is for as long as the individual would have beenor local government, or by a university or othertemporarily in the United States primarily to entitled to them under the treaty.recognized educational institution in the Unitedteach or engage in research, or both, at a univer-States.sity or other recognized educational institution is

The exemption does not apply to income exempt from U.S. income tax on income from Korea, Republic offrom research carried on mainly for the private the teaching or research for a maximum of 2

An individual who is a resident of the Republic ofbenefit of any person rather than in the public years from the date of arrival in the UnitedKorea on the date of arrival in the United Statesinterest. States. The individual must have been invited toand who is temporarily in the United States pri-the United States for a period not expected to bemarily to teach or engage in research, or both, atlonger than 2 years by the U.S. Government or aa university or other recognized educational in-Iceland state or local government, or by a university orstitution is exempt from U.S. income tax on in-other recognized educational institution in the

An individual who is a resident of Iceland on the come for the teaching or research for aUnited States.date of arrival in the United States and who is maximum of 2 years from the date of arrival in

This exemption does not apply to income the United States. The individual must havetemporarily in the United States at the invitation from research carried on mainly for the private been invited to the United States for a period notof the U.S. Government, a university, or other benefit of any person rather than in the public expected to be longer than 2 years by the U.S.recognized educational institution in the United interest. The exemption does not apply if, during Government or a state or local government, orStates primarily to teach or engage in research, the immediately preceding period, the benefits by a university or other recognized educationalor both, at a university or other educational insti- described in Article 24(1) of the treaty, pertain- institution in the United States.tution is exempt from U.S. income tax on income ing to students, were claimed. The exemption does not apply to incomefor the teaching or research for a maximum of 2 from research carried on mainly for the privateyears from the date of arrival in the United benefit of any person rather than in the publicItalyStates. interest.

This exemption does not apply to income A professor or teacher who is a resident of Italyfrom research carried on mainly for the private on the date of arrival in the United States and Luxembourgbenefit of any person rather than in the public who temporarily visits the United States to teach

or conduct research at a university, college,interest. A resident of Luxembourg who is temporarily inschool, or other educational institution, or at a the United States at the invitation of a U.S.medical facility primarily funded from govern- university, college, school, or other recognized

India ment sources, is exempt from U.S. income tax educational institution only to teach or engage infor up to 2 years on pay from this teaching or research, or both, at that educational institutionAn individual is exempt from U.S. tax on income research. is exempt from U.S. income tax on income for

received for teaching or research if he or she: This exemption does not apply to income the teaching or research for not more than 2from research carried on mainly for the private years from the date of arrival in the United• Is a resident of India immediately beforebenefit of any person rather than in the public States.visiting the United States, andinterest. If the individual’s visit to the United States is• Is in the United States to teach or engage longer than 2 years, the exemption is lost for the

in research at an accredited university or entire visit unless the competent authorities ofother recognized educational institution in Jamaica Luxembourg and the United States agree other-the United States for a period not longer wise.

An individual who is a resident of Jamaica on thethan 2 years. This exemption does not apply to pay fordate of arrival in the United States and who research carried on for the benefit of any persontemporarily visits the United States to teach orIf the individual’s visit to the United States other than the educational institution that ex-engage in research at a university, college, or tended the invitation.exceeds 2 years, the exemption is lost for theother recognized educational institution is ex-entire visit.empt from U.S. income tax on the income re-

This exemption does not apply to income ceived for the teaching or research for not more Netherlandsfrom research carried on mainly for the private than 2 years from the date of arrival in the Unitedbenefit of any person rather than in the public States. A resident of Jamaica is entitled to this An individual is exempt from U.S. income tax oninterest. exemption only once. income received for teaching or research for a




maximum of 2 years from the date of arrival if he described in Article 22(1) of the treaty, pertain- • Is in the United States primarily to teach orconduct research at a university, college,or she: ing to students, were claimed.school, or other accredited educational or• Is a resident of the Netherlands immedi- research institution.

ately before visiting the United States, and PolandA Slovak resident is entitled to these benefits• Is in the United States to teach or engage

An individual who is a resident of Poland on the only once. However, the exemption does notin research at a university, college, ordate of arrival in the United States and who is apply if:other recognized educational institution fortemporarily in the United States at the invitationnot more than 2 years. • The resident claimed during the immediateof the U.S. Government, a university, or other

preceding period the benefits describedrecognized educational institution in the UnitedIf the individual’s visit to the United States is later under Students and Apprentices, orStates primarily to teach or engage in research,longer than 2 years, the exemption is lost for theor both, at a university or other recognized edu- • The income is from research undertakenentire visit unless the competent authorities ofcational institution is exempt from U.S. income primarily for the private benefit of a spe-the Netherlands and the United States agree

cific person or persons.tax on income for the teaching or research for aotherwise.maximum of 2 years from the date of arrival inThe exemption does not apply to incomethe United States.from research carried on primarily for the private Slovenia

This exemption does not apply to incomebenefit of any person rather than in the publicfrom research carried on mainly for the private An individual who is a resident of Slovenia oninterest. Nor does the exemption apply if thebenefit of any person rather than in the public the date of arrival in the United States and whoresident claimed during the immediate preced-

temporarily visits the United States to teach orinterest.ing period the benefits described later underengage in research at a recognized educationalStudents and Apprentices.or research institution is exempt from U.S. in-

Portugal come tax on the income received for the teach-ing or research for not more than 2 years fromNorway An individual who is a resident of Portugal on the the date of arrival in the United States. This

date of arrival in the United States and who is benefit can be claimed for no more than 5 years.An individual who is a resident of Norway on thetemporarily in the United States at the invitationdate of arrival in the United States and who is The exemption does not apply to incomeof the U.S. Government, a university, other ac-temporarily in the United States at the invitation from research carried on mainly for the privatecredited educational institution, or recognizedof the U.S. Government, a university, or other benefit of any person rather than in the publicresearch institution in the United States, or interest.recognized educational institution in the Unitedunder an official cultural exchange program,States primarily to teach or engage in research,only to teach or engage in research, or both, at aor both, at a university or other recognized edu-university or educational institution is exempt Thailandcational institution is exempt from U.S. incomefrom U.S. income tax on income from teachingtax on income for the teaching or research for a

An individual who is a resident of Thailand onor research for a maximum of 2 years from themaximum period of 2 years from the date ofthe date of arrival in the United States and whodate of arrival in the United States. An individualarrival in the United States. is in the United States for not longer than 2 yearsis entitled to these benefits only once. However,This exemption does not apply to income primarily to teach or engage in research at athese benefits, and the benefits described laterfrom research carried on mainly for the private university, college, school, or other recognizedunder Students and Apprentices cannot be

benefit of any person rather than in the public educational institution is exempt from U.S. in-claimed either simultaneously or consecutively.interest. come tax on income for the teaching or re-This exemption does not apply to income

search. The exemption from tax applies only iffrom research carried on mainly for the privatethe visit does not exceed 2 years from the datebenefit of any person rather than in the publicPakistan the individual first visits the United States for the

interest.purpose of engaging in teaching or research.A professor or teacher who is a resident of

This exemption does not apply to incomePakistan and who temporarily visits the Unitedfrom research carried on mainly for the privateRomaniaStates to teach at a university, college, school,benefit of any person rather than in the publicor other educational institution for not longerinterest. This exemption does not apply if, duringAn individual who is a resident of Romania onthan 2 years is exempt from U.S. income tax onthe immediately preceding period, the benefitsthe date of arrival in the United States and whothe income received for teaching for that period. described in treaty Article 22(1), pertaining tois temporarily in the United States at the invita-students, were claimed.tion of the U.S. Government, a university, or

other recognized educational institution in thePhilippinesUnited States primarily to teach or engage in

Trinidad and Tobagoresearch, or both, at a university or other recog-An individual who is a resident of the Philippinesnized educational institution is exempt from U.S.on the date of arrival in the United States and An individual who is a resident of Trinidad andincome tax on income for the teaching or re-who is temporarily in the United States primarily Tobago on the date of arrival in the Unitedsearch for a maximum of 2 years from the dateto teach or engage in research, or both, at a States and who is temporarily in the Unitedof arrival in the United States.university or other recognized educational insti- States at the invitation of the U.S. Government,

tution is exempt from U.S. income tax on income This exemption does not apply to income a university, or other accredited educational in-from the teaching or research for not more than from research carried on mainly for the private stitution in the United States primarily to teach or2 years from the date of arrival in the United benefit of any person rather than in the public engage in research, or both, at a university orStates. The individual must have been invited to interest. other accredited educational institution is ex-the United States for a period not expected to be empt from U.S. income tax on the income re-longer than 2 years by the U.S. Government or a ceived for the teaching or research for a

Slovak Republicstate or local government, or by a university or maximum of 2 years from the date of arrival inother recognized educational institution in the the United States.

An individual is exempt from U.S. income tax onUnited States. This exemption does not apply to incomeincome for teaching or research for up to 2 yearsThis exemption does not apply to income from research carried on mainly for the privateif he or she:from research carried on mainly for the private benefit of any person rather than in the publicbenefit of any person rather than in the public • Is a resident of the Slovak Republic imme- interest. Nor does the exemption apply to in-interest. The exemption does not apply if, during diately before visiting the United States, come if an agreement exists between the Gov-the immediately preceding period, the benefits and ernments of Trinidad and Tobago and the




United States for providing the services of these Associate Program and Visiting Scientist Pro- Nevertheless, an individual who qualifies forindividuals. gram are not exempt from U.S. tax as a grant, this exemption may instead choose to be treated

allowance, or award. as a resident alien of the United States for allU.S. income tax purposes. Once made, this

Turkey choice applies for the entire period that the indi-Australia vidual remains qualified for exemption and may

An individual who was a resident of Turkey im- not be revoked without the permission of themediately before visiting the United States who A resident of Australia or an individual who was U.S. competent authority.is in the United States for not longer than 2 years a resident of Australia immediately before visit-for the purpose of teaching or engaging in scien- ing the United States who is temporarily here fortific research is exempt from U.S. income tax on full-time education is exempt from U.S. income Belgiumpayments received from outside the United tax on payments received from outside theStates for teaching or research. United States for the individual’s maintenance or

Note. See the effective dates of the neweducation.treaty under What’s New at the beginning of thispublication.United Kingdom

AustriaA professor or teacher who is a resident of the

New treaty. A student or business trainee whoUnited Kingdom on the date of arrival in the A student, apprentice, or business trainee whois a resident of Belgium immediately before visit-United States and who is in the United States for is a resident of Austria immediately before visit-ing the United States and is in the United Statesnot longer than 2 years primarily to teach or ing the United States and is in the United Statesfor the purpose of full-time education or trainingengage in research at a university, college, or for the purpose of full-time education at a recog-is exempt from U.S. income tax on the followingother recognized educational institution is ex- nized educational institution or full-time trainingamounts.empt from U.S. income tax on income for the is exempt from U.S. income tax on amounts

teaching or research. If the individual’s 2-year received from sources outside the United States • Payments received from abroad for main-period is exceeded, the exemption is lost for the for the individual’s maintenance, education, or tenance, education, or training.entire visit, including the 2-year period. training.

• Income from personal services of up toApprentices and business trainees are enti-The exemption does not apply to income $9,000 for each tax year.

tled to the benefit of this exemption for a maxi-from research carried on mainly for the privatemum period of 3 years.benefit of any person rather than in the public A business trainee is entitled to the benefit of

interest. this exemption for a maximum period of 2 years.For this purpose, a business trainee is an

Bangladesh individual who is temporarily in the UnitedVenezuela States:

An individual who is a resident of Bangladesh• To secure training to practice a professionimmediately before visiting the United StatesAn individual who is a resident of Venezuela on

or professional specialty, orand who is temporarily present in the Unitedthe date of arrival in the United States and whoStates for the primary purpose of:temporarily visits the United States to teach or • As an employee of, or under contract with,

engage in research at a recognized educational a resident of Belgium, for the primary pur-1. Studying at a university, college, school, oror research institution is exempt from U.S. in- pose of acquiring technical, professional,other recognized educational institution income tax on the income received for the teach- or business experience from a personthe United States,ing or research for not more than 2 years from other than that resident of Belgium orthe date of arrival in the United States. This 2. Securing training as a business or techni- other than a person related to that resi-benefit can be claimed for no more than 5 years. cal apprentice, or dent.

The exemption does not apply to income 3. Studying or doing research as a recipientfrom research carried on mainly for the private of a grant, allowance, or award from a gov- Former treaty. An individual who is a residentbenefit of any person rather than in the public ernmental, religious, charitable, or educa- of Belgium on the date of arrival in the Unitedinterest. tional organization States and who is temporarily in the United

States primarily to study at a university or otheris exempt from U.S. tax on the followingStudents and Apprentices recognized educational institution in the Unitedamounts.States, obtain professional training, or study or

Residents of the following countries who are in • The payments from abroad for the pur- do research as a recipient of a grant, allowance,the United States to study or acquire technical pose of maintenance, education, or train- or award from a governmental, religious, chari-experience are exempt from U.S. income tax, ing. table, scientific, literary, or educational organi-under certain conditions, on amounts received zation is exempt from U.S. income tax on the• The grant, allowance, or award.from abroad for their maintenance and studies. following amounts.

• The income from personal services per-This exemption does not apply to the salary • Gifts from abroad for maintenance, educa-formed in the United States of up to

paid by a foreign corporation to one of its execu- tion, study, research, or training.$8,000 for the tax year.tives, a citizen and resident of a foreign country • The grant, allowance, or award.who is temporarily in the United States to study a For an individual described in (2), the exemp-particular industry for an employer. That amount • Income from personal services performedtion from tax applies for not more than 2 yearsis a continuation of salary and is not received to in the United States of up to $2,000 forfrom the date the individual first arrived in thestudy or acquire experience. each tax year.United States.

For each country listed there is a statementAn individual is entitled to the benefit of thisof the conditions under which the exemption

exemption for a maximum of 5 years.Barbadosapplies to students and apprentices from thatAn individual who is a resident of Belgium oncountry.

A student or business apprentice who is a resi- the date of arrival in the United States and whoAmounts received from the National Insti- dent of Barbados on the date of arrival in the is in the United States as an employee of, or

tutes of Health (NIH) under provisions of the United States and is here for full-time education under contract with, a resident of Belgium isVisiting Fellows Program are generally treated or training is exempt from U.S. income tax on exempt from U.S. income tax for a period of 12as a grant, allowance, or award for purposes of payments received from outside the United consecutive months on up to $5,000 receivedwhether an exemption is provided by treaty. States for the individual’s maintenance, educa- for personal services if the individual is in theAmounts received from NIH under the Visiting tion, or training. United States primarily to:




• Acquire technical, professional, or busi- under contract with, a resident of a C.I.S. mem- Czech Republicness experience from a person other than ber is exempt from U.S. income tax on the

An individual who is a resident of the Czechthat resident of Belgium or other than a amounts received from that resident. Also ex-Republic at the beginning of his or her visit to theperson related to that resident, or empt is an amount received from U.S. sources,United States and who is temporarily present inof not more than $10,000, that is necessary to• Study at an educational institution. the United States is exempt from U.S. income

provide for ordinary living expenses. The ex-tax on certain amounts for a period of up to 5

emption contained in this paragraph is limited toAn individual who is a resident of Belgium on years. To be entitled to the exemption, the indi-1 year.the date of arrival in the United States and who vidual must be in the United States for the pri-

is temporarily present in the United States for An individual who is a resident of a C.I.S. mary purpose of:not longer than 1 year as a participant in a member and who is temporarily present in the • Studying at a university or other accred-program sponsored by the U.S. Government United States under an exchange program pro- ited educational institution in the Unitedprimarily to train, research, or study is exempt vided for by an agreement between govern- States,from U.S. income tax on income received for ments on cooperation in various fields ofpersonal services for the training, research, or • Obtaining training required to qualify himscience and technology is exempt from U.S.study in the amount of $10,000. or her to practice a profession or profes-income tax on all income received in connection

sional specialty, orwith the exchange program for a period notlonger than 1 year. • Studying or doing research as a recipientCanada

of a grant, allowance, or award from agovernmental, religious, charitable, scien-A full-time student, trainee, or business appren-

Cyprus tific, literary, or educational organization.tice who is or was a Canadian resident immedi-ately before visiting the United States is exempt If the individual meets any of these require-An individual who is a resident of Cyprus on thefrom U.S. income tax on amounts received from ments, the following amounts are exempt fromdate of arrival in the United States and who issources outside the United States for mainte- U.S. tax.temporarily here primarily to study at a universitynance, education, or training.

or other recognized educational institution in the • The payments from abroad, other thanAlso see Publication 597, Information on theUnited States, obtain professional training, or compensation for personal services, forUnited States–Canada Income Tax Treaty.study or do research as a recipient of a grant, the purpose of maintenance, education,

study, research, or training.allowance, or award from a governmental, relig-ious, charitable, scientific, literary, or educa-China, People’s Republic of • The grant, allowance, or award.tional organization is exempt from U.S. income

A student, business apprentice, or trainee who • The income from personal services per-tax on the following amounts.is a resident of the People’s Republic of China formed in the United States of up to

• Gifts from abroad for maintenance, educa-on the date of arrival in the United States and $5,000 for the tax year.tion, or training.who is present in the United States solely to

An individual who is a Czech resident at theobtain training, education, or special technical • The grant, allowance, or award.beginning of the visit to the United States andexperience is exempt from U.S. income tax on

• Income from personal services performed who is temporarily present in the United Statesthe following amounts.in the United States of up to $2,000 for as an employee of, or under contract with, a• Payments received from abroad for main- each tax year. Czech resident is exempt from U.S. income tax

tenance, education, study, research, or for a period of 12 consecutive months on up totraining. An individual is entitled to this exemption for $8,000 received for personal services if the indi-

up to 5 tax years and for an additional period as vidual is in the United States primarily to:• Grants or awards from a government, sci-entific, educational, or other tax-exempt is necessary to complete, as a full-time student, • Acquire technical, professional, or busi-organization. educational requirements for a postgraduate or ness experience from a person other than

professional degree from a recognized educa- the Czech resident, or• Income from personal services performedtional institution.in the United States of up to $5,000 for • Study at a university or other accredited

An individual who is a resident of Cyprus oneach tax year. educational institution in the United States.the date of arrival in the United States and who

An individual is entitled to this exemption only is temporarily here as an employee of, or under An individual who is a Czech resident at thefor the time reasonably necessary to complete contract with, a resident of Cyprus is exempt time he or she becomes temporarily present inthe education or training. from U.S. income tax for not more than 1 year on the United States and who is temporarily pres-

income from personal services for a maximum ent in the United States for a period not longerof $7,500 if the individual is in the United States than 1 year as a participant in a program spon-Commonwealth of sored by the U.S. Government for the primaryprimarily to either:Independent States (C.I.S.) purpose of training, research, or study is exempt• Acquire technical, professional, or busi- from U.S. income tax on up to $10,000 of in-An individual who is a resident of a C.I.S. mem- ness experience from a person other than come from personal services for that training,ber and who is temporarily in the United States a resident of Cyprus or other than a per- research, or study.primarily to study at an educational or scientific son related to that resident, or These exemptions do not apply to incomeresearch institution or to obtain training for quali-

from research undertaken primarily for the pri-• Study at a university or other recognizedfication in a profession or specialty is exemptvate benefit of a specific person or persons.educational institution.from U.S. income tax on amounts received as

stipends, scholarships, or other substitute al-An individual who is a resident of Cyprus onlowances necessary to provide ordinary living Denmarkthe date of arrival in the United States and whoexpenses. An individual is entitled to the benefit

is temporarily here for a period of not more thanof this exemption for a maximum of 5 years and A student, apprentice, or business trainee who1 year as a participant in a program sponsoredfor less than $10,000 in each tax year. is a resident of Denmark immediately beforeby the U.S. Government primarily to train, re-An individual who is a resident of a C.I.S. visiting the United States and is in the Unitedsearch, or study is exempt from U.S. income taxmember and who is temporarily in the United States for the purpose of full-time education aton income for personal services for the training,States primarily to acquire technical, profes- an accredited educational institution, or full-timeresearch, or study. This exemption is limited tosional, or commercial experience or perform training, is exempt from U.S. income tax on$10,000.technical services and who is an employee of, or amounts received from sources outside the




United States for the individual’s maintenance, governmental, religious, charitable, scientific, lit- An individual is entitled to this benefit and theerary, or educational organization is exempt benefit described earlier under Professors,education, or training.from U.S. income tax on the following amounts. Teachers, and Researchers for a maximum of 5Apprentices and business trainees are enti-

tax years.tled to the benefit of this exemption for a maxi- • Payments from abroad, other than com-This exemption does not apply to incomemum period of 3 years. pensation for personal services, for main-

from research carried on mainly for the privateThe exemption does not apply to income tenance, education, study, research, orbenefit of any person rather than in the publicfrom research undertaken primarily for the pri- training.interest.vate benefit of a specific person or persons. • The grant, allowance, or award. An individual who is a resident of France onthe date of arrival in the United States and who• Income from personal services performedis in the United States as an employee of, orEgypt in the United States of up to $5,000 forunder contract with, a resident of France is ex-each tax year.

An individual who is a resident of Egypt on the empt from U.S. income tax for a period of 12date of arrival in the United States and who is consecutive months on up to $8,000 receivedAn individual is entitled to the benefit of thistemporarily in the United States primarily to for personal services if the individual is in theexemption for a maximum of 5 years.study at a university or other recognized educa- United States primarily to:An individual who is a resident of Estonia ontional institution in the United States, obtain pro- the date of arrival in the United States and who • Acquire technical, professional, or busi-fessional training, or study or do research as a is in the United States as an employee of, or ness experience from a person other thanrecipient of a grant, allowance, or award from a under contract with, a resident of Estonia is that resident of France, orgovernmental, religious, charitable, scientific, lit- exempt from U.S. income tax for a period of 12 • Study at an educational institution.erary, or educational organization is exempt consecutive months on up to $8,000 receivedfrom U.S. income tax on the following amounts. for personal services if the individual is in the

United States primarily to: Germany• Gifts from abroad for maintenance, educa-tion, study, research, or training. • Acquire technical, professional, or busi-

ness experience from a person other than• The grant, allowance, or award. Note. See the effective dates of the protocolthat resident of Estonia, or under What’s New at the beginning of this publi-• Income from personal services performed

cation. The only change under the protocol that• Study at an educational institution.in the United States of up to $3,000 eachapplies to students and business apprentices

tax year. increases the compensation for dependent per-An individual who is a resident of Estonia onsonal services that is exempt from U.S. tax fromthe date of arrival in the United States and whoAn individual is entitled to the benefit of this $5,000 to $9,000.is temporarily present in the United States forexemption for a maximum of 5 tax years and for

not longer than 1 year as a participant in a A student or business apprentice (includingany additional period of time needed to com-program sponsored by the U.S. Government Volontaere and Praktikanten) who is or was im-plete, as a full-time student, educational require-primarily to train, research, or study is exempt mediately before visiting the United States aments as a candidate for a postgraduate or from U.S. income tax on income received for resident of Germany and who is present in theprofessional degree from a recognized educa- personal services for the training, research, or United States for full-time education or trainingtional institution. study in the amount of $10,000. is exempt from U.S. income tax on amounts

An individual who is a resident of Egypt on from sources outside the United States for main-These provisions do not apply to incomethe date of arrival in the United States and who tenance, education, or training.from research carried on mainly for the privateis temporarily in the United States as an em-An individual who is or was immediatelybenefit of any person rather than in the public

ployee of, or under contract with, a resident of before visiting the United States a resident ofinterest.Egypt is exempt from U.S. income tax for a Germany is exempt from U.S. tax on amountsperiod of 12 consecutive months on up to $7,500 received as a grant, allowance, or award from areceived for personal services if the individual is Finland nonprofit religious, charitable, scientific, literary,in the United States primarily to: or educational organization.

A full-time student, trainee, or business appren-• Acquire technical, professional, or busi- Individuals described in the previous twotice who is a resident of Finland immediatelyness experience from a person other than paragraphs are also exempt from U.S. tax onbefore visiting the United States is exempt fromthat resident of Egypt or other than a per- compensation for dependent personal servicesU.S. income tax on amounts received from

of up to $9,000 per year if:son related to that resident, orsources outside the United States for mainte-

• They are present in the United States for• Study at a university or other educational nance, education, or training.not more than 4 years, andinstitution.

• The services are performed for the pur-FranceAn individual who is a resident of Egypt on the pose of supplementing funds availabledate of arrival in the United States and who is otherwise for maintenance, education, orAn individual who is a resident of France on thetemporarily in the United States for no more than training.date of arrival in the United States and who is1 year as a participant in a program sponsored

temporarily in the United States primarily toby the U.S. Government primarily to train, re- If the individual’s visit exceeds 4 years, thestudy at a university or other recognized educa-search, or study is exempt from U.S. income tax exemption is lost for the entire visit unless thetional institution in the United States, obtain pro-on income received for personal services for the competent authorities of Germany and thefessional training, or study, or do research as atraining, research, or study for a maximum of United States agree otherwise.recipient of a grant, allowance, or award from a$10,000. An individual who is a resident of Germanynot-for-profit governmental, religious, charitable,

and who is employed by a German enterprise orscientific, artistic, cultural, or educational organi-by a nonprofit religious, charitable, scientific,zation is exempt from U.S. income tax on theEstonia literary, or educational organization is exemptfollowing amounts.from U.S. tax on compensation paid by the em-An individual who is a resident of Estonia on the • Gifts from abroad for maintenance, educa-ployer from outside the United States if:date of arrival in the United States and who is tion, study, research, or training.

temporarily in the United States primarily to • The individual is temporarily in the United• The grant, allowance, or award.study at a university or other accredited educa- States for not more than 1 year to acquiretional institution in the United States, obtain pro- • Income from personal services performed technical, professional, or business experi-fessional training, or study or do research as a in the United States of up to $5,000 each ence from any person other than his or herrecipient of a grant, allowance, or award from a tax year. employer, and




• The compensation is not more than program sponsored by the U.S. Government Ireland$10,000. primarily to train, research, or study is exempt

A student, apprentice, or business trainee whofrom U.S. income tax on income received forIf the compensation is more than $10,000, none is a resident of Ireland immediately before visit-personal services for the training, research, orof the income is exempt. ing the United States and is in the United Statesstudy for a maximum of $10,000.for the purpose of full-time education at a recog-

Greece nized educational institution or full-time trainingis exempt from U.S. income tax on amountsIndiaA student or business apprentice who is a resi-received from sources outside the United States

dent of Greece and is temporarily in the Unitedfor the individual’s maintenance, education, orAn individual who is a resident of India immedi-States only to study or acquire business experi-training.ately before visiting the United States and who isence is exempt from U.S. income tax on

temporarily in the United States primarily foramounts received from sources outside the Apprentices and business trainees are enti-studying or training is exempt from U.S. incomeUnited States for maintenance or studies. tled to the benefit of this exemption for a maxi-tax on payments from abroad for maintenance, mum period of 1 year.study, or training. The exemption does not apply

Hungary to payments borne by a permanent establish-Israelment in the United States or paid by a U.S.

An individual who is a resident of Hungary im-citizen or resident, the U.S. Government, or anymediately before arrival in the United States and An individual who is a resident of Israel on theof its agencies, instrumentalities, political subdi-is here for full-time education or training is ex- date of arrival in the United States and who isvisions, or local authorities.empt from U.S. income tax on payments re- temporarily in the United States primarily to

ceived from outside the United States for the Under the treaty, if the payments are not study at a university or other recognized educa-individual’s maintenance, education, or training. exempt under the rule described above, an indi- tional institution in the United States, obtain pro-

vidual described in the previous paragraph may fessional training, or study or do research as aThe full-time student or trainee may insteadrecipient of a grant, allowance, or award from abe eligible to deduct exemptions for his or herchoose to be treated as a resident alien of thegovernmental, religious, charitable, scientific, lit-spouse and dependents and the standard de-United States for U.S. income tax purposes.erary, or educational organization is exemptduction. The individual must file Form 1040NROnce made, the choice applies for the entirefrom U.S. income tax on the following amounts.period that the individual remains qualified for or Form 1040NR-EZ to claim these amounts.

exemption as a full-time student or trainee and For information on how to claim these amounts, • Gifts from abroad for maintenance, educa-may not be changed unless permission is ob- see chapter 5 in Publication 519. tion, study, research, or training.tained from the U.S. competent authority.

The individual is entitled to these benefits • The grant, allowance, or award.only for a period of time considered reasonable

• Income from personal services performedor customarily required to complete studying orIceland in the United States of up to $3,000 eachtraining.tax year.An individual who is a resident of Iceland on the

date of arrival in the United States and who isAn individual is entitled to the benefit of thisIndonesiatemporarily in the United States primarily to

exemption for a maximum of 5 tax years.study at a university or other recognized educa-An individual who is a resident of Indonesiational institution in the United States, obtain pro- An individual who is a resident of Israel onimmediately before visiting the United Statesfessional training, or study or do research as a the date of arrival in the United States and whoand who is temporarily in the United States isrecipient of a grant, allowance, or award from a is temporarily in the United States as an em-exempt from U.S. income tax on certaingovernmental, religious, charitable, scientific, lit- ployee of, or under contract with, a resident ofamounts for a period of up to 5 years. To beerary, or educational organization is exempt Israel is exempt from U.S. income tax for a

from U.S. income tax on the following amounts. entitled to the exemption, the individual must be period of 12 consecutive months on up to $7,500temporarily in the United States for full-time received for personal services if the individual is• Gifts from abroad for maintenance, educa-study at a U.S. university, school, or other recog- in the United States primarily to:tion, study, research, or training.nized educational institution, or for full-time • Acquire technical, professional, or busi-• The grant, allowance, or award. study, research, or training as a recipient of a ness experience from a person other thangrant, allowance, or award from either the U.S.• Income from personal services performed that resident of Israel or other than a per-or Indonesian Government, a scientific, educa-in the United States of up to $2,000 each son related to that resident, ortional, religious, or charitable organization, ortax year.

• Study at a university or other educationalunder a technical assistance program enteredinstitution.An individual is entitled to the benefit of this into by either the U.S. or Indonesian Govern-

exemption for a maximum of 5 years. ment. If the individual meets any of these re-An individual who is a resident of Israel on the

quirements, the following amounts are exemptAn individual who is a resident of Iceland on date of arrival in the United States and who isfrom tax.the date of arrival in the United States and who temporarily in the United States for no more than

is temporarily in the United States as an em- 1 year as a participant in a program sponsored• All payments from abroad for mainte-ployee of, or under contract with, a resident of by the U.S. Government primarily to train, re-nance, education, study, research, orIceland is exempt from U.S. income tax for a search, or study is exempt from U.S. income taxtraining.period of 12 consecutive months on up to $5,000 on income received for personal services for the

• The grant, allowance, or award.received for personal services if the individual is training, research, or study for a maximum ofin the United States primarily to: $10,000.• Income from personal services performed

• Acquire technical, professional, or busi- in the United States of up to $2,000 eachness experience from a person other than tax year. Italythat resident of Iceland or other than aperson related to that person, or An individual who is a resident of Indonesia A student or business apprentice (trainee) who

immediately before visiting the United States is a resident of Italy on the date of arrival in the• Study at an educational institution.and is temporarily in the United States only as a United States and who is temporarily in thebusiness or technical apprentice is exempt fromAn individual who is a resident of Iceland on United States only for education or training isU.S. income tax for a period of 12 consecutivethe date of arrival in the United States and who exempt from U.S. income tax on amounts re-months on up to $7,500 received for personalis temporarily present in the United States for ceived from outside the United States for main-services.not longer than 1 year as a participant in a tenance, education, and training.




The individual is entitled to this exemption • The grant, allowance, or award.Jamaicaonly for a period of time necessary to complete • Income from personal services performedA student who is a resident of Jamaica on the the study, training, or research, but the exemp-

in the United States of up to $5,000 fordate of arrival in the United States and is here for tion for training or research may not extend for aeach tax year.full-time education or training is exempt from period exceeding 5 years.

U.S. income tax on payments received fromThese exemptions do not apply to income An individual is entitled to the benefit of thisoutside the United States for the student’s main-

from research if it is undertaken primarily for the exemption for a maximum of 5 years.tenance, education, or training.private benefit of a specific person or persons. An individual who is a resident of Latvia onAn individual who is a resident of Jamaica on

the date of arrival in the United States and whothe date of arrival in the United States and whois in the United States as an employee of, oris temporarily in the United States as an em- Korea, Republic of under contract with, a resident of Latvia is ex-ployee of, or under contract with, a resident ofempt from U.S. income tax for a period of 12Jamaica is exempt from U.S. income tax for a An individual who is a resident of the Republic ofconsecutive months on up to $8,000 receivedperiod of 12 consecutive months on up to $7,500 Korea on the date of arrival in the United Statesfor personal services if the individual is in theof net income from personal services if the indi- and who is temporarily in the United States pri-United States primarily to:vidual is in the United States primarily to: marily to study at a university or other recog-

nized educational institution in the United • Acquire technical, professional, or busi-• Acquire technical, professional, or busi-States, obtain professional training, or study or ness experience from a person other thanness experience from a person other thando research as a recipient of a grant, allowance,that resident of Jamaica or other than a that resident of Latvia, oror award from a governmental, religious, chari-person related to that resident, or • Study at an educational institution.table, scientific, literary, or educational organi-

• Study at a university or other recognized zation is exempt from U.S. income tax on theeducational institution. An individual who is a resident of Latvia on thefollowing amounts.

date of arrival in the United States and who is• Amounts from abroad for maintenance,An individual who qualifies for one of the ex- temporarily present in the United States for noteducation, study, research, or training.emptions discussed above may instead choose longer than 1 year as a participant in a program

to be treated as a resident alien of the United sponsored by the U.S. Government primarily to• The grant, allowance, or award.States for all U.S. income tax purposes. Once train, research, or study is exempt from U.S.• Income from personal services performedmade, the choice applies for the entire period income tax on income received for personal

in the United States of up to $2,000 eachthat the individual remains qualified for exemp- services for the training, research, or study in thetax year.tion and may not be revoked unless permission amount of $10,000.

is obtained from the U.S. competent authority. These provisions do not apply to incomeAn individual is entitled to the benefit of thisfrom research carried on mainly for the privateexemption for a maximum of 5 years.benefit of any person rather than in the publicJapan An individual who is a resident of Korea on interest.

the date of arrival in the United States and whoA student or business apprentice who is a resi- is temporarily in the United States as an em-dent of Japan immediately before visiting the ployee of, or under contract with, a resident of LithuaniaUnited States and is in the United States for the Korea is exempt from U.S. income tax for 1 yearpurpose of education or training is exempt from on up to $5,000 received for personal services if An individual who is a resident of Lithuania onU.S. income tax on amounts received from the individual is in the United States primarily to: the date of arrival in the United States and whoabroad for the individual’s maintenance, educa- is temporarily in the United States primarily to• Acquire technical, professional, or busi-tion, or training. study at a university or other accredited educa-ness experience from a person other thanBusiness apprentices are entitled to the ben- tional institution in the United States, obtain pro-that resident of Korea or other than a per-efit of this exemption for a maximum period of 1 fessional training, or study or do research as ason related to that resident, oryear. recipient of a grant, allowance, or award from a

• Study at an educational institution. governmental, religious, charitable, scientific, lit-Former treaty. An individual entitled to the erary, or educational organization is exempt

An individual who is a resident of Korea on thestudent and trainee benefits under the former from U.S. income tax on the following amounts.date of arrival in the United States and who istreaty may continue to claim those benefits for

• Payments from abroad, other than com-temporarily present in the United States for notas long as the individual would have been enti-pensation for personal services, for main-longer than 1 year as a participant in a programtled to those benefits under that treaty.tenance, education, study, research, orsponsored by the U.S. Government primarily totraining.train, research, or study is exempt from U.S.

Kazakhstan income tax on income received for personal • The grant, allowance, or award.services for the training, research, or study for a

An individual who is a resident of Kazakhstan at • Income from personal services performedmaximum of $10,000.the beginning of his or her visit to the United in the United States of up to $5,000 forStates is exempt from U.S. tax on payments each tax year.from abroad for maintenance, education, study, Latviaresearch, or training and on any grant, allow- An individual is entitled to the benefit of this

An individual who is a resident of Latvia on theance, or other similar payments. To be entitled exemption for a maximum of 5 years.date of arrival in the United States and who isto the exemption, the individual must be tempo- An individual who is a resident of Lithuaniatemporarily in the United States primarily torarily present in the United States primarily to: on the date of arrival in the United States andstudy at a university or other accredited educa- who is in the United States as an employee of, or• Study at a university or other accreditedtional institution in the United States, obtain pro- under contract with, a resident of Lithuania iseducational institution,fessional training, or study or do research as a exempt from U.S. income tax for a period of 12• Obtain training required to qualify him or recipient of a grant, allowance, or award from a consecutive months on up to $8,000 received

her to practice a profession or professional governmental, religious, charitable, scientific, lit- for personal services if the individual is in thespecialty, or, erary, or educational organization is exempt United States primarily to:

from U.S. income tax on the following amounts.• Study or do research as a recipient of a • Acquire technical, professional, or busi-grant, allowance, or other similar pay- • Payments from abroad, other than com- ness experience from a person other thanments from a governmental, religious, pensation for personal services, for main- that resident of Lithuania, orcharitable, scientific, literary, or educa- tenance, education, study, research, or

• Study at an educational institution.tional organization. training.




An individual who is a resident of Lithuania on primarily for full-time study at a recognized uni- An individual who is a resident of Norway onversity, college, or school or securing training asthe date of arrival in the United States and who the date of arrival in the United States and whoa business apprentice is exempt from U.S. in-is temporarily present in the United States for is in the United States as an employee of, orcome tax on the following amounts.not longer than 1 year as a participant in a under contract with, a resident of Norway is

program sponsored by the U.S. Government exempt from U.S. income tax for a period of 12• Payments from abroad for maintenance,primarily to train, research, or study is exempt consecutive months on up to $5,000 receivededucation, or training.from U.S. income tax on income received for for personal services if the individual is in the

• Income from personal services performedpersonal services for the training, research, or United States primarily to:in the United States of up to $2,000 eachstudy in the amount of $10,000. • Acquire technical, professional, or busi-tax year.These provisions do not apply to income ness experience from a person other than

from research carried on mainly for the private that resident of Norway or other than aThe individual is entitled to this exemptionbenefit of any person rather than in the public person related to that resident of Norway,only for a period of time considered reasonableinterest. oror customarily required to complete studying ortraining. • Study at an educational institution.

Luxembourg An individual who immediately before visitingAlso exempt is a resident of Norway who isthe United States is a resident of the Nether-

A student, apprentice, or business trainee who present in the United States for not longer than 1lands and is temporarily present in the Unitedis a resident of Luxembourg immediately before year as a participant in a program sponsored byStates for a period not exceeding 3 years for thevisiting the United States and is in the United the Government of the United States primarily topurpose of study, research, or training solely asStates for the purpose of full-time education at a train, research, or study. The individual is ex-a recipient of a grant, allowance, or award from arecognized educational institution or full-time empt from tax on income from personal servicesscientific, educational, religious, or charitable or-training is exempt from U.S. income tax on performed in the United States and received forganization or under a technical assistance pro-amounts received for the individual’s mainte- the training, research, or study, for a maximumgram entered into by either the Netherlands ornance, education, or training. of $10,000.the United States, or its political subdivisions or

Apprentices and business trainees are enti- local authorities is exempt from U.S. income taxtled to the benefit of this exemption for a maxi- on the following amounts.mum period of 2 years. Pakistan• The amount of the grant, allowance, or

If the individual’s visit to the United States is award. Residents of Pakistan temporarily in the Unitedlonger than 2 years, the exemption is lost for theStates are exempt from U.S. income tax on• Income of up to $2,000 for personal serv-entire visit unless the competent authorities ofcertain income they may receive. To be entitledices performed in the United States forLuxembourg and the United States agree other-to this exemption, they must be in the Unitedany tax year if the services are connectedwise.States only as students at a recognized univer-with, or incidental to, the study, research,sity, college, or school, or as recipients of grants,or training.allowances, or awards from religious, charitable,Mexicoscientific, or educational organizations of Paki-An individual is not entitled to these exemp-stan primarily to study or research. The incomeA student or business apprentice who is a resi- tions if, during the immediately preceding pe-exempt in these cases is any payment fromdent of Mexico immediately before visiting the riod, the individual claimed the exemptionabroad for maintenance, education, or training,United States and is in the United States solely discussed earlier under Professors, Teachers,and any pay for personal services of not morefor the purpose of education or training is ex- and Researchers.than $5,000 for any tax year.empt from U.S. tax on amounts received from

sources outside the United States for the individ- Other residents of Pakistan who are tempo-ual’s maintenance, education, or training. New Zealand rarily in the United States for no more than 1

year are exempt from U.S. income tax on pay ofA resident of New Zealand or an individual who not more than $6,000 received for that period,was a resident of New Zealand immediatelyMorocco including pay from the enterprise or organizationbefore visiting the United States who is in the of which they are employees or with which they

An individual who is a resident of Morocco on United States for full-time education is exempt are under contract. To qualify for this exemption,the date of arrival in the United States and who from U.S. income tax on amounts received from they must be employees of, or under contractis temporarily in the United States primarily to abroad for maintenance or education. with, a Pakistani enterprise or religious, charita-study at a university or other recognized educa- ble, scientific, or educational organization andtional institution in the United States, obtain pro- be in the United States only to acquire technical,fessional training, or study or do research as a Norway professional, or business experience from a per-recipient of a grant, allowance, or award from a son other than that enterprise or organization.An individual who is a resident of Norway on thegovernmental, religious, charitable, scientific, lit-

Also exempt from U.S. income tax on certaindate of arrival in the United States and who iserary, or educational organization is exemptincome are residents of Pakistan temporarily intemporarily in the United States primarily tofrom U.S. income tax on the following amounts.the United States under an arrangement withstudy at a university or other recognized educa-

• Gifts from abroad for maintenance, educa- the U.S. Government, or any of its agencies ortional institution in the United States, obtain pro-tion, study, research, or training. instrumentalities, only for study, training, or ori-fessional training, or study or do research as a

entation. They are exempt from tax on income ofrecipient of a grant, allowance, or award from a• The grant, allowance, or award.not more than $10,000 for services directly re-governmental, religious, charitable, scientific, lit-

• Income from personal services performed lated to their training, study, or orientation, in-erary, or educational organization is exemptin the United States of up to $2,000 each cluding income from their employer abroad.from U.S. income tax on the following amounts.tax year.

• Gifts from abroad for maintenance, educa-tion, study, research, or training. PhilippinesAn individual is entitled to the benefit of this

exemption for a maximum of 5 years. • The grant, allowance, or award. An individual who is a resident of the Philippineson the date of arrival in the United States and• Income from personal services performedwho is temporarily in the United States primarilyin the United States up to $2,000 each taxNetherlandsto study at a university or other recognized edu-year.

An individual who immediately before visiting cational institution in the United States, obtainthe United States is a resident of the Nether- professional training, or study or do research asAn individual is entitled to the benefit of thislands and who is present in the United States a recipient of a grant, allowance, or award from aexemption for a maximum of 5 tax years.




governmental, religious, charitable, scientific, lit- • Acquire technical, professional, or busi- • Income from personal services performedness experience from a person other than in the United States of up to $2,000 eacherary, or educational organization is exemptthat resident of Poland or other than a tax year.from U.S. income tax on the following amounts.person related to that resident, or• Gifts from abroad for maintenance, educa- An individual is entitled to the benefit of this• Study at an educational institution.tion, study, research, or training. exemption for a maximum of 5 years.

• The grant, allowance, or award. An individual who is a resident of RomaniaAn individual who is a resident of Poland onon the date of arrival in the United States andthe date of arrival in the United States and who• Income from personal services performedwho is temporarily in the United States as anis temporarily in the United States for not longerin the United States of up to $3,000 eachemployee of, or under contract with, a residentthan 1 year as a participant in a program spon-tax year.of Romania is exempt from U.S. income tax for 1sored by the U.S. Government primarily to train,year on up to $5,000 received for personal serv-research, or study is exempt from U.S. incomeAn individual is entitled to the benefit of thisices if the individual is in the United States pri-tax on up to $10,000 of income received forexemption for a maximum of 5 years.marily to:personal services for the training, research, orAn individual who is a resident of the Philip-

study. • Acquire technical, professional, or busi-pines on the date of arrival in the United Statesness experience from a person other thanand who is temporarily in the United States asthat resident of Romania or other than aan employee of, or under contract with, a resi- Portugal person related to that resident, ordent of the Philippines is exempt from U.S. in-

come tax for a period of 12 consecutive months An individual who is a resident of Portugal on the • Study at an educational institution.on up to $7,500 received for personal services if date of arrival in the United States and who isthe individual is in the United States primarily to: temporarily in the United States primarily to An individual who is a resident of Romania on

study at a university or other accredited educa- the date of arrival in the United States and who• Acquire technical, professional, or busi-tional institution in the United States, obtain pro- is temporarily in the United States for not longerness experience from a person other than fessional training, or study, or do research as a than 1 year as a participant in a program spon-that resident of the Philippines or other recipient of a grant, allowance, or award from a sored by the U.S. Government primarily to train,than a person related to that resident, or governmental, religious, charitable, scientific, lit- research, or study is exempt from U.S. incomeerary, or educational organization is exempt• Study at an educational institution. tax on up to $10,000 of income received forfrom U.S. income tax on the following amounts. personal services for the training, research, or

An individual who is a resident of the Philip- study.• Payments from abroad for maintenance,pines on the date of arrival in the United States, education, study, research, or training.and who is temporarily in the United States (for

• The grant, allowance, or award.no more than 1 year as a participant in a pro- Russiagram sponsored by the U.S. Government) pri- • Income from personal services performed

An individual who is a resident of Russia at themarily to train, research, or study is exempt from in the United States of up to $5,000 eachbeginning of his or her visit to the United StatesU.S. income tax on income received for per- tax year.is exempt from U.S. tax on payments fromsonal services for the training, research, orabroad for maintenance, education, study, re-study, up to a maximum of $10,000. An individual is entitled to the benefit of thissearch, or training and on any grant, allowance,exemption for a maximum of 5 tax years fromor other similar payments. To be entitled to thethe date of arrival in the United States. Theexemption, the individual must be temporarilyPoland benefits provided here and the benefits de-present in the United States primarily to:scribed earlier under Professors, Teachers, and

An individual who is a resident of Poland on the Researchers cannot be claimed simultaneously • Study at a university or other accrediteddate of arrival in the United States and who is or consecutively. educational institution,temporarily in the United States primarily toAn individual who is a resident of Portugal on

study at a university or other recognized educa- • Obtain training required to qualify him orthe date of arrival in the United States and whotional institution in the United States, obtain pro- her to practice a profession or professionalis in the United States as an employee of, orfessional training, or study or do research as a specialty, orunder contract with, a resident of Portugal isrecipient of a grant, allowance, or award from a exempt from U.S. income tax for a period of 12 • Study or do research as a recipient of agovernmental, religious, charitable, scientific, lit- consecutive months on up to $8,000 received grant, allowance, or other similar pay-erary, or educational organization is exempt for personal services if the individual is in the ments from a governmental, religious,from U.S. income tax on the following amounts. United States primarily to: charitable, scientific, literary, or educa-

• Gifts from abroad for maintenance, educational organization.• Acquire technical, professional, or busi-tion, study, research, or training. ness experience from a person other than

The individual is entitled to this exemptionthat resident of Portugal, or• The grant, allowance, or award.only for a period of time necessary to complete

• Study at an educational institution.• Any other payments received from Poland, the study, training, or research, but the exemp-except income from performing personal tion for training or research may not extend for aservices. period exceeding 5 years.Romania

These exemptions do not apply to income• Income from personal services performedAn individual who is a resident of Romania on from research if it is undertaken primarily for thein the United States of up to $2,000 each the date of arrival in the United States and who private benefit of a specific person or persons.tax year. is temporarily in the United States primarily tostudy at a university or other recognized educa-

An individual is entitled to the benefit of this tional institution in the United States, obtain pro- Slovak Republicexemption for a maximum of 5 years. fessional training, or study or do research as aAn individual who is a resident of Poland on An individual who is a resident of the Slovakrecipient of a grant, allowance, or award from a

the date of arrival in the United States and who Republic at the beginning of his or her visit to thegovernmental, religious, charitable, scientific, lit-is temporarily in the United States as an em- United States and who is temporarily present inerary, or educational organization is exemptployee of, or under contract with, a resident of the United States is exempt from U.S. incomefrom U.S. income tax on the following amounts.Poland is exempt from U.S. income tax for 1 tax on certain amounts for a period of up to 5• Gifts from abroad for maintenance, educa-year on up to $5,000 received for personal serv- years. To be entitled to the exemption, the indi-

tion, study, research, or training.ices if the individual is in the United States pri- vidual must be in the United States for the pri-marily to: mary purpose of:• The grant, allowance, or award.




• Studying at a university or other accred- • Income from personal services performed temporarily in the United States as an employeeited educational institution in the United in the United States of up to $5,000 for of, or under contract with, a resident of Spain isStates, each tax year. exempt from U.S. income tax for a period of 12

consecutive months on up to $8,000 received• Obtaining training required to qualify him An individual is entitled to the benefit of thisfor personal services if the individual is in theor her to practice a profession or profes- exemption for a maximum of 5 tax years and forUnited States primarily to:sional specialty, or any additional period of time needed to com-

plete, as a full-time student, educational require- • Acquire technical, professional, or busi-• Studying or doing research as a recipientments as a candidate for a postgraduate or ness experience from a person other thanof a grant, allowance, or award from aprofessional degree from a recognized educa- that Spanish resident, orgovernmental, religious, charitable, scien-tional institution.tific, literary, or educational organization. • Study at a university or other accredited

An individual who is a resident of Slovenia on educational institution in the United States.If the individual meets any of these require-the date of arrival in the United States and whoments, the following amounts are exempt fromis temporarily in the United States as an em- Both the $5,000 and $8,000 exemptions in-U.S. tax.ployee of, or under contract with, a resident of clude any amount excluded or exempted from• The payments from abroad, other than Slovenia is exempt from U.S. income tax for a tax under U.S. tax law.

compensation for personal services, for period not exceeding 12 months on up to $8,000 These exemptions do not apply to incomethe purpose of maintenance, education, received for personal services if the individual is from research carried on mainly for the privatestudy, research, or training. in the United States primarily to: benefit of any person rather than in the public• The grant, allowance, or award. interest.• Acquire technical, professional, or busi-

ness experience from a person other than• The income from personal services per-that resident of Slovenia, orformed in the United States of up to

Sri Lanka$5,000 for the tax year. • Study at a university or other recognizededucational institution. A student, apprentice, or business trainee, who

An individual who is a Slovak resident at the is a resident of Sri Lanka resident immediatelybeginning of the visit to the United States and These provisions do not apply to income from before visiting the United States and is in thewho is temporarily present in the United States research carried on mainly for the private benefit United States for the purpose of full-time educa-as an employee of, or under contract with, a of any person rather than in the public interest. tion or training, is exempt from U.S. income taxSlovak resident is exempt from U.S. income tax

on amounts received from sources outside thefor a period of 12 consecutive months on up toUnited States for the individual’s maintenance,$8,000 received from personal services if the South Africa education, or training.individual is in the United States primarily to:

An individual who is a resident of Sri LankaA student, apprentice, or business trainee who• Acquire technical, professional, or busi- on the date of arrival in the United States andis a resident of South Africa immediately beforeness experience from a person other than who is temporarily in the United States as anvisiting the United States and is in the Unitedthe Slovak resident, or employee of, or under contract with, a residentStates for the purpose of full-time education orof Sri Lanka, or as a participant in a program• Study at a university or other accredited training is exempt from U.S. income tax onsponsored by the United States or by any inter-educational institution in the United States. amounts received from sources outside thenational organization, is exempt from U.S. in-United States for the individual’s maintenance,

An individual who is a Slovak resident at the come tax for a period not exceeding 1 year on upeducation, or training.time he or she becomes temporarily present in to $6,000 received for personal services if theApprentices and business trainees are enti-the United States and who is temporarily pres- individual is in the United States primarily to:tled to the benefit of this exemption for a maxi-ent in the United States for a period not longer mum period of 1 year. • Acquire technical, professional, or busi-than 1 year as a participant in a program spon-

ness experience from a person other thansored by the U.S. government for the primarythat resident of Sri Lanka or other than apurpose of training, research, or study is exempt Spain person related to that resident, orfrom U.S. income tax on up to $10,000 of in-

come from personal services for that training, An individual who is a resident of Spain at the • Study at a university or other recognizedresearch, or study. beginning of the visit to the United States and educational institution.

These exemptions do not apply to income who is temporarily in the United States primarilyfrom research undertaken primarily for the pri- to study at a U.S. university or other accredited

Swedenvate benefit of a specific person or persons. educational institution, to obtain training to be-come qualified to practice a profession or pro- A student, apprentice, or business trainee whofessional specialty, or to study or do research as is a resident of Sweden immediately before visit-Slovenia a recipient of a grant, allowance, or award from a ing the United States and is in the United Statesgovernmental, religious, charitable, scientific, lit-

for the purpose of full-time education or trainingAn individual who is a resident of Slovenia at the erary, or educational organization is exemptis exempt from U.S. tax on amounts receivedbeginning of the visit to the United States and from U.S. income tax on the following amounts.from sources outside the United States for thewho is temporarily in the United States primarily

• Payments from abroad (other than com-to study at a U.S. university or other recognized individual’s maintenance, education, and train-pensation for personal services) for main-educational institution, to obtain training to be- ing.tenance, education, study, research, orcome qualified to practice a profession or pro-training.fessional specialty, or to study or do research as

a recipient of a grant, allowance, or award from a Switzerland• The grant, allowance, or award.governmental, religious, charitable, scientific, lit-

A student, apprentice, or business trainee who• Income from personal services performederary, or educational organization is exemptis a resident of Switzerland immediately beforein the United States of up to $5,000 forfrom U.S. income tax on the following amounts.visiting the United States and is in the Unitedeach tax year.• Payments from abroad (other than com- States for the purpose of full-time education or

An individual is entitled to the benefit of thispensation for personal services) for main- training is exempt from U.S. income tax onexemption for a maximum of 5 years.tenance, education, study, research, or amounts received from sources outside the

training. United States for the individual’s maintenance,An individual who is a resident of Spain at theeducation, or training.• The grant, allowance, or award. beginning of the visit to the United States and is




• Gifts from abroad for maintenance, educa-Thailand Ukrainetion, study, research, or training.

An individual who is a resident of Thailand at the An individual who is a resident of Ukraine at the• The grant, allowance, or award.beginning of his or her visit to the United States beginning of his or her visit to the United States

and who is temporarily present in the United is exempt from U.S. tax on payments from• Income from personal services performedStates is exempt from U.S. income tax on cer- abroad for maintenance, education, study, re-in the United States of up to $2,000 eachtain amounts for a period of up to 5 years. To be search, or training and on any grant, allowance,tax year, or, if the individual is obtainingentitled to the exemption, the individual must be or other similar payments. To be entitled to thetraining required to qualify to practice ain the United States for the primary purpose of: exemption, the individual must be temporarily

profession or a professional specialty, a present in the United States primarily to:• Studying at a university or other recog- maximum of $5,000 for any tax year.nized educational institution in the United • Study at a university or other accreditedStates, educational institution,An individual is entitled to the benefit of this

exemption for a maximum period of 5 tax years.• Obtaining training required to qualify him • Obtain training required to qualify him oror her to practice a profession or profes- her to practice a profession or professionalAn individual who is a resident of Trinidadsional specialty, or specialty, orand Tobago on the date of arrival in the United

States and who is in the United States as an• Studying or doing research as a recipient • Study or do research as a recipient of aemployee of, or under contract with, a residentof a grant, allowance, or award from a grant, allowance, or other similar pay-or corporation of Trinidad and Tobago is exemptgovernmental, religious, charitable, scien- ments from a governmental, religious,from U.S. income tax for 1 tax year on up totific, literary, or educational organization. charitable, scientific, literary, or educa-$5,000 received for personal services if the indi- tional organization.

If the individual meets any of these require- vidual is in the United States primarily to:ments, the following amounts are exempt from

The individual is entitled to this exemption• Study at an educational institution, orU.S. tax.only for a period of time necessary to complete

• Acquire technical, professional, or busi-• Gifts from abroad for the purpose of main- the study, training, or research, but the exemp-tenance, education, study, research, or tion for training or research may not extend for aness experience from a person other thantraining. period exceeding 5 years.that resident or corporation of Trinidad and

These exemptions do not apply to incomeTobago.• The grant, allowance, or award.from research if it is undertaken primarily for the

• Income from personal services performed private benefit of a specific person or persons.Also exempt is a resident of Trinidad andin the United States of up to $3,000 for the Tobago who is present in the United States fortax year. not longer than 1 year as a participant in a

United Kingdomprogram sponsored by the U.S. GovernmentAn individual who is a resident of Thailand at primarily to train, research, or study. The individ- A student or business apprentice who is a resi-the beginning of the visit to the United States ual is exempt from tax on income from personal dent of the United Kingdom immediately beforeand who is temporarily present in the United

services performed in the United States and visiting the United States and is in the UnitedStates as an employee of, or under contractreceived for the training, research, or study for States for the purpose of full-time education at awith, a resident of Thailand is exempt from U.S.up to a maximum of $10,000. recognized educational institution or full-timeincome tax for a period of 12 consecutive

training is exempt from U.S. income tax onmonths on up to $7,500 received from personalamounts received from abroad for the individ-services if the individual is in the United States Tunisia ual’s maintenance, education, or training.primarily to:

Business apprentices are entitled to the ben-An individual who is a resident of Tunisia imme-• Acquire technical, professional, or busi- efit of this exemption for a maximum period of 1diately before visiting the United States and whoness experience from a person other than year.

the Thai resident, or is in the United States for full-time study orFormer treaty. An individual entitled to treatytraining is exempt from U.S. income tax on the• Study at a university or other recognizedbenefits under Article 21 (students and trainees)following amounts.educational institution in the United States.of the former treaty may continue to claim those• Payments from abroad for full-time study benefits for as long as the individual would haveAn individual who is a resident of Thailand at or training. been entitled to them under that treaty.the time he or she becomes temporarily present

• A grant, allowance, or award from a gov-in the United States and who is temporarily pres-ernmental, religious, charitable, scientific,ent in the United States for a period not longer Venezuelaliterary, or educational organization tothan 1 year as a participant in a program spon-study or engage in research.sored by the U.S. government for the primary An individual who is a resident of Venezuela on

purpose of training, research, or study is exempt the date of arrival in the United States and who• Income from personal services performedfrom U.S. income tax on up to $10,000 of inis temporarily in the United States primarily toin the United States of up to $4,000 in anycome from personal services for that training, study at a university or other recognized educa-tax year.research, or study. tional institution in the United States, obtain pro-

fessional training, or study or do research as aThe individual is entitled to this exemption forrecipient of a grant, allowance, or award from aa maximum of 5 years.Trinidad and Tobago governmental, religious, charitable, scientific, lit-erary, or educational organization is exemptAn individual who is a resident of Trinidad andfrom U.S. income tax on the following amounts.TurkeyTobago on the date of arrival in the United

States and who is temporarily in the United • Payments from abroad, other than com-A student, apprentice, or business trainee whoStates primarily to study at a university or other pensation for personal services, for main-is a resident of Turkey immediately before visit-accredited educational institution in the United tenance, education, study, research, oring the United States and is in the United StatesStates, obtain professional training, or study or training.for the purpose of full-time education or trainingdo research as a recipient of a grant, allowance, • The grant, allowance, or award.is exempt from U.S. income tax on amountsor award from a governmental, religious, chari-received from sources outside the United Statestable, scientific, literary, or educational organi- • Income from personal services performedfor the individual’s maintenance, education, orzation is exempt from U.S. income tax on the in the United States of up to $5,000 for

following amounts. training. each tax year.




An individual is generally entitled to the bene- with a trade or business carried on by Austria or with a business carried on by Belgium, its politi-fit of this exemption for a maximum of 5 years its political subdivisions or local authorities. cal subdivisions, or local authorities.from the date of arrival in the United States. Thisexemption will also apply to any additional pe- Former treaty. Wages, salaries, similar in-

Bangladeshriod of time that a full-time student needs to come, and pensions and annuities paid by, orcomplete the educational requirements as a from public funds of, Belgium, its political subdi-

Income, other than a pension, paid by Ban-candidate for a postgraduate or professional de- visions, or its local authorities, to citizens ofgladesh, its political subdivisions, or local au-gree from a recognized educational institution. Belgium (or to citizens of countries other thanthorities to an individual for services performedAn individual who is a resident of Venezuela the United States or Belgium who come to thefor the paying governmental body is exempton the date of arrival in the United States and United States and are employed by Belgium orfrom U.S. income tax. However, the exemptionwho is in the United States as an employee of, or its political subdivisions or local authorities) fordoes not apply if the services are performed inunder contract with, a resident of Venezuela is performing governmental functions are exemptthe United States by a resident of the Unitedexempt from U.S. income tax for a period of 12 from U.S. tax.States who either:months on up to $8,000 received for personal However, these exemptions do not apply to

services if the individual is in the United States • Is a U.S. citizen, or payments for services performed in connectionprimarily to: with a trade or business carried on by Belgium or• Did not become a U.S. resident only to

its political subdivisions or local authorities.• Acquire technical, professional, or busi- perform the services.ness experience from a person other thanthat resident of Venezuela, or Pensions paid from the public funds of Ban-

Canadagladesh, its political subdivisions, or local au-• Study at an educational institution.thorities for services performed for Bangladesh, Wages, salaries, and similar income (other thanits political subdivisions, or local authorities to anThese provisions do not apply to income from pensions) paid by Canada or by a Canadianindividual for services performed for the payingresearch carried on mainly for the private benefit political subdivision or local authority to a citizengovernmental body are exempt from U.S. in-of any person rather than in the public interest. of Canada for performing governmental func-come tax unless the recipient is both a resident tions are exempt from U.S. income tax. Thisand citizen of the United States. exemption does not apply, however, to pay-Wages and Pensions This exemption does not apply to income or ments for services performed in connection withPaid by a Foreign pensions for services performed in connection a trade or business carried on by Canada or itswith a business carried on by Bangladesh, itsGovernment political subdivisions or local authorities.political subdivisions, or local authorities.

Also see Publication 597, Information on theWages, salaries, pensions, and annuities paidUnited States–Canada Income Tax Treaty.by the governments of the following countries to

their residents who are present in the United BarbadosStates as nonresident aliens generally are ex-

China, People’s Republic ofIncome, including a pension, paid from the pub-empt from U.S. income tax. The conditionslic funds of Barbados, or its political subdivisionsunder which the income is exempt are stated for Income, other than a pension, paid by the Peo-or local authorities, to a citizen of Barbados foreach of the countries listed. ple’s Republic of China or its political subdivi-performing governmental functions is exempt

sions or local authorities to an individual forfrom U.S. income tax.Exemption under U.S. tax law. Employees ofservices performed for the paying governmentalHowever, this exemption does not apply toforeign countries who do not qualify under a taxbody is exempt from U.S. income tax. However,payments for services in connection with a busi-treaty provision and employees of internationalthe exemption does not apply to payments forness carried on by Barbados or its political sub-organizations should see if they can qualify forservices performed in the United States by adivisions or local authorities.exemption under U.S. tax law.resident of the United States who either:If you work for a foreign government in the

United States, your foreign government salary is • Is a U.S. citizen, orBelgiumexempt from U.S. tax if you perform services • Did not become a U.S. resident only tosimilar to those performed by U.S. government

perform the services.employees in that foreign country and that for-Note. See the effective dates of the neweign government grants an equivalent exemp-

Pensions paid by the People’s Republic oftreaty under What’s New at the beginning of thistion. If you work for an international organizationChina for services performed for China are ex-publication.in the United States, your salary from thatempt from U.S. income tax unless the recipient

source is exempt from U.S. tax. See chapter 10 New treaty. Wages, salaries, and similar inis both a citizen and a resident of the Unitedof Publication 519 for more information. come, other than a pension, paid by Belgium, its States.

political subdivisions, or local authorities to an These exemptions do not apply to income orindividual for services performed for the paying pensions for services performed in connectionAustralia governmental body is exempt from U.S. income with a business carried on by the People’s Re-tax. However, the exemption does not apply if public of China or its subdivisions or local au-Salaries, wages, and similar income, includingthe services are performed in the United States thorities.pensions, paid by Australia, its political subdivi-by a resident of the United States who either:sions, agencies, or authorities to its citizens

(other than U.S. citizens) for performing govern- • Is a U.S. national, orCommonwealth ofmental functions as an employee of any of the

• Did not become a U.S. resident only to Independent States (C.I.S.)above entities are exempt from U.S. income tax.perform the services.

Wages, salaries, and similar income paid by thePensions paid by, or out of funds created by, C.I.S. or a member of the C.I.S. to its citizens forAustria

Belgium, its political subdivisions, or local au- personal services performed as an employee ofWages, salaries, similar income, and pensions thorities for services performed for Belgium, its a governmental agency or institution of theand annuities paid from public funds of Austria, political subdivisions, or local authorities to an C.I.S. or a member of the C.I.S. (excluding localits political subdivisions, or its local authorities, individual for services performed for the paying government employees) in the discharge of gov-to citizens of Austria for performing governmen- governmental body are exempt from U.S. in- ernmental functions are exempt from U.S. in-tal functions as an employee are exempt from come tax unless the recipient is both a resident come tax. For this purpose, persons engaged inU.S. tax. and national of the United States. commercial activities are not considered en-

gaged in the discharge of governmental func-However, this exemption does not apply to However, these exemptions do not apply totions.payments for services performed in connection payments for services performed in connection




Treaty as modified. Wages, salaries, andCyprus Estoniasimilar income, other than a pension, paid by

Wages, salaries, and similar income, including Income, other than a pension, paid by or from Germany, its political subdivisions, local authori-public funds of Estonia, its political subdivisions,pensions, annuities, and similar benefits, paid ties, or instrumentalities to an individual for serv-or local authorities to an individual for services ices performed for the paying governmentalfrom public funds of Cyprus to a citizen of Cy-performed as an employee for the paying gov- body is exempt from U.S. income tax. However,prus for labor or personal services performed as

the exemption does not apply if the services areernmental body in the discharge of governmen-an employee of Cyprus in the discharge of gov-performed in the United States by a resident oftal functions is exempt from U.S. income tax.ernmental functions are exempt from U.S. in-the United States who either:However, the exemption does not apply if thecome tax.

services are performed in the United States by a • Is a U.S. national, orresident of the United States who either:

• Did not become a U.S. resident only toCzech Republic • Is a U.S. citizen, or perform the services.Income, including a pension, paid from the pub- • Did not become a U.S. resident only to

Pensions paid by, or out of funds created by,lic funds of the Czech Republic, its political sub- perform the services.Germany, its political subdivisions, local authori-divisions, or local authorities to a Czech citizenties, or instrumentalities for services performedPensions paid by or from the public funds offor services performed in the discharge of gov-for the paying governmental body are exemptEstonia, its political subdivisions, or local author-ernmental functions is exempt from U.S. income from U.S. income tax unless the recipient is bothities for services performed for Estonia are ex-tax. This exemption does not apply to income a resident and a national of the United States.empt from U.S. income tax unless the recipientpaid for services performed in connection with a This exemption does not apply to income oris both a resident and citizen of the Unitedbusiness carried on by the Czech Republic, its pensions for services performed in connectionStates.

political subdivisions, or local authorities. with a business carried on by Germany, its politi-cal subdivisions, local authorities, or instrumen-talities.FinlandDenmarkUnmodified treaty. Wages, salaries, and sim-Income, other than a pension, paid by Finland,

Income, other than a pension, paid from public ilar income and pensions paid by Germany, itsits political subdivisions, statutory bodies, or lo-funds of Denmark, its political subdivisions, or Laender, or municipalities, or their public pen-cal authorities to an individual for services per-local authorities to an individual for services per- sion funds are exempt from U.S. income tax ifformed for the paying governmental body is

paid to individuals other than U.S. citizens andformed for the paying governmental body in the exempt from U.S. income tax. However, theother than individuals admitted to the Uniteddischarge of governmental functions is exempt exemption does not apply to payments for serv-States for permanent residence.from U.S. income tax. However, the exemption ices performed in the United States by a U.S.

does not apply if the services are performed in resident who either:the United States by a resident of the United Greece• Is a U.S. citizen, orStates who either:

• Did not become a U.S. resident only to Wages, salaries, and similar income and pen-• Is a U.S. national, orperform the services. sions paid by Greece or its subdivisions to indi-

• Did not become a U.S. resident only to viduals living in the United States for servicesPensions paid by Finland for services per-perform the services. rendered to Greece or its subdivisions are ex-

formed for Finland are exempt from U.S. income empt from U.S. income tax. This exemptionPensions paid from the public funds of Den- tax unless the recipient is a resident and citizen does not apply to citizens of the United States or

mark, its political subdivisions, or local authori- of the United States. alien residents of the United States.ties for services performed for Denmark are These exemptions do not apply to income orexempt from U.S. income tax unless the recipi- pensions for services performed in connection

Hungarywith a trade or business carried on by Finland orent is a resident and a national of the Unitedits political subdivisions, statutory bodies, or lo-States. Income (other than a pension) paid by the Re-cal authorities.These exemptions do not apply to income or public of Hungary or its political subdivisions for

labor or personal services performed for thepensions for services performed in connectionpaying governmental body is exempt from U.S.with a trade or business carried on by Denmark, France tax. However, the exemption does not apply toits political subdivisions, or local authorities.payments for services performed in the UnitedIncome, including pensions, paid by the FrenchStates by a resident of the United States whoGovernment or a local authority thereof to aneither:Egypt individual in the United States for services per-

formed for France (or for a local authority of • Is a U.S. citizen, orWages, salaries, and similar income, includingFrance) in the discharge of governmental func- • Did not become a resident of the Unitedpensions, annuities, and similar benefits, paid tions is exempt from U.S. tax. This exemption States only to perform the services.from public funds of the Arab Republic of Egypt does not apply to a person who is both a resi-

to a citizen of Egypt (or to a citizen of another dent and citizen of the United States and not a Pensions paid by Hungary for services per-country who comes to the United States specifi- French national. formed for Hungary are exempt from U.S. in-cally to work for the Government of Egypt) for This exemption does not apply to any income tax unless the recipient is both a citizenlabor or personal services performed as an em- come or pensions paid because of services (or and a resident of the United States.ployee of the national Government of Egypt, or past services) performed in connection with a These exemptions do not apply to income orany of its agencies, in the discharge of govern- business carried on by the French Government pensions for services performed in connectionmental functions are exempt from U.S. income (or a local authority thereof). with a trade or business carried on by Hungarytax. or its subdivisions.

This exemption does not apply to U.S. citi-Germanyzens or to alien residents of the United States. IcelandThe exemption also does not apply to payments

for services performed in connection with a Note. See the effective dates of the protocol Wages, salaries, and similar income, includingtrade or business carried on by Egypt or any of under What’s New at the beginning of this publi- pensions and similar benefits, paid by or fromits agencies. cation. public funds of the Republic of Iceland, a political




subdivision, or a local authority to a citizen of with a business carried on by Ireland or its subdi- governmental body is exempt from U.S. incomeIceland (other than a U.S. citizen or one admit- visions or local authorities. tax. However, the exemption does not apply ifted to the United States for permanent resi- the services are performed in the United Statesdence) for labor or personal services performed by a resident of the United States who either:

Israelfor Iceland or its political subdivisions or local • Is a U.S. citizen, orauthorities in the discharge of governmentalWages, salaries, and similar income, includingfunctions are exempt from U.S. tax. • Did not become a U.S. resident only topensions and similar benefits, paid from public perform the services.funds by the national government of Israel or itsagencies, for services performed in the dis-India Pensions paid by, or out of funds to whichcharge of governmental functions, are exempt contributions are made by, Japan, its political

Income, other than a pension, paid by India, its from U.S. income tax. This exemption does not subdivisions, or local authorities for servicespolitical subdivisions, or local authorities to an apply to citizens of the United States or alien performed for Japan are exempt from U.S. in-individual for services performed for the paying residents of the United States. come tax unless the recipient is a resident andgovernmental body is exempt from U.S. income citizen of the United States.tax. However, the exemption does not apply if

These exemptions do not apply to income orItalythe services are performed in the United Statespensions for services performed in connectionby a U.S. resident who either:with a business carried on by Japan, its politicalIncome, other than a pension, paid by Italy or by

• Is a U.S. citizen, or subdivisions, or local authorities.an Italian political or administrative subdivisionor local authority to an individual for services• Did not become a U.S. resident only toperformed for the paying governmental body isperform the services.

Kazakhstanexempt from U.S. income tax. However, theexemption does not apply to payments for serv-Pensions paid by India for services performed Income, other than a pension, paid by Kazakh-ices performed in the United States by a residentfor India are exempt from U.S. tax unless the stan, or its subdivisions or local authorities to anof the United States who either:individual is both a resident and citizen of the individual for government services is exempt

United States. • Is a U.S. citizen, or from U.S. tax. However, the exemption does notThese exemptions do not apply to income or

apply if the services are performed in the United• Did not become a U.S. resident only topensions for services performed in connectionStates by a U.S. resident who either:perform the services.with a business carried on by India, its subdivi-

sions, or local authorities. • Is a U.S. citizen, orThe spouse and dependent children of an indi-vidual, however, are not subject to the second • Did not become a U.S. resident solely forrestriction if that individual is receiving exempt the purpose of performing the services.Indonesia income for governmental services performed for

These exemptions do not apply to income forItaly and that individual does not come underIncome, other than a pension, paid by Indone- services performed in connection with a busi-either of the restrictions.sia, its political subdivisions, or local authorities ness.to an individual for services performed for the Pensions paid by Italy for services performed

Pensions paid by Kazakhstan, or its subdivi-paying governmental body is exempt from U.S. for Italy are exempt from U.S. income tax unlesssions or local authorities for services performedincome tax. However, the exemption does not the recipient is both a citizen and a resident offor Kazakhstan is exempt from U.S. tax unlessapply if the services are performed in the United the United States.the individual is both a resident and citizen of theStates by a U.S. resident who either: These exemptions do not apply to income orUnited States.pensions for services performed in connection• Is a U.S. citizen, or

with a trade or business carried on by Italy or its• Did not become a U.S. resident only to subdivisions or local authorities.

Korea, Republic ofperform the services.

Wages, salaries, and similar income, includingPensions paid by Indonesia for services per- Jamaicapensions and similar benefits, paid from publicformed for Indonesia are exempt from U.S. tax.funds of the Republic of Korea to a citizen ofIncome, other than a pension, paid by the Gov-These exemptions do not apply to income orKorea (other than a U.S. citizen or an individualernment of Jamaica or its political subdivisionspensions for services performed in connectionadmitted to the United States for permanentor local authorities for personal services per-with a trade or business carried on by Indonesia,residence) for services performed as an em-formed for the paying governmental body is ex-its subdivisions, or local authorities.

empt from U.S. income tax. ployee of Korea discharging government func-tions are exempt from U.S. income tax.This exemption does not apply to payments

for services performed in the United States byIrelandan individual who is a citizen and resident of the

Income, other than a pension, paid by Ireland or LatviaUnited States.its political subdivisions or local authorities to an Pensions paid by Jamaica for services per-

Income, other than a pension, paid by or fromindividual for services performed for the paying formed for Jamaica generally are exempt frompublic funds of Latvia, its political subdivisions,governmental body is exempt from U.S. income U.S. income tax. However, if the recipient of theor local authorities to an individual for servicestax. However, the exemption does not apply to pension is a citizen and resident of the Unitedperformed as an employee for the paying gov-payments for services performed in the United States and was a U.S. citizen at the time theernmental body in the discharge of governmen-States by a resident of the United States who services were performed, the pension is taxabletal functions is exempt from U.S. income tax.either: in the United States.However, the exemption does not apply if theThese exemptions do not apply to income or• Is a U.S. citizen, or services are performed in the United States by apensions for services performed in connectionresident of the United States who either:• Did not become a U.S. resident only to with a trade or business carried on by Jamaica

perform the services. or its subdivisions or local authorities. • Is a U.S. citizen, or

• Did not become a U.S. resident only toPensions paid by Ireland for services per-perform the services.formed for Ireland are exempt from U.S. income Japan

tax unless the recipient is both a resident andPensions paid by or from the public funds ofcitizen of the United States. Income, other than a pension, paid by Japan, its

Latvia, its political subdivisions, or local authori-These exemptions do not apply to income or political subdivisions, or local authorities to anties for services performed for Latvia are exemptpensions for services performed in connection individual for services performed for the paying




from U.S. income tax unless the recipient is both These exemptions do not apply to income or authorities in the discharge of governmentala resident and citizen of the United States. pensions connected with commercial or indus- functions are exempt from U.S. income tax.

trial activities carried on by Mexico, its politicalsubdivisions, or local authorities.

Lithuania Pakistan

Income, other than a pension, paid by or from Income, including pensions and annuities, paidMoroccopublic funds of Lithuania, its political subdivi- to certain individuals by or on behalf of the Gov-sions, or local authorities to an individual for Wages, salaries, and similar income, including ernment of Pakistan or the Government of aservices performed as an employee for the pay- pensions and similar benefits, paid from public Province in Pakistan or one of its local authori-ing governmental body in the discharge of gov- funds of the Kingdom of Morocco to a citizen of ties for services performed in the discharge ofernmental functions is exempt from U.S. income Morocco (other than a U.S. citizen or an individ- functions of that Government or local authority istax. However, the exemption does not apply if ual admitted to the United States for permanent exempt from U.S. income tax. To be exemptthe services are performed in the United States residence) for labor or personal services per- from tax, these payments must be made to citi-by a resident of the United States who either: formed for Morocco or for any of its political zens of Pakistan who do not have immigrant

subdivisions or local authorities in the discharge• Is a U.S. citizen, or status in the United States. This exemption doesof governmental functions are exempt from U.S.not apply to payments for services performed in• Did not become a U.S. resident only to income tax.connection with any trade or business carried onperform the services.for profit.

NetherlandsPensions paid by or from the public funds ofLithuania, its political subdivisions, or local au- PhilippinesIncome, other than a pension, paid by thethorities for services performed for Lithuania are

Netherlands, its political subdivisions, or localexempt from U.S. income tax unless the recipi- Wages, salaries, and similar income, includingauthorities to an individual for services per-ent is both a resident and citizen of the United pensions, annuities, and similar benefits, paidformed for the paying governmental body is ex-States. from public funds of the Republic of the Philip-empt from U.S. income tax. However, thepines to a citizen of the Philippines (or to aexemption does not apply if the services arecitizen of another country other than the Unitedrendered in the United States and the individualLuxembourgStates who comes to the United States specifi-is a U.S. resident who either:cally to work for the Government of the Philip-Income, other than a pension, paid by Luxem- • Is a U.S. national, or pines) for labor or personal services performedbourg, its political subdivisions, or local authori-

ties to an individual for services performed for • Did not become a U.S. resident solely for as an employee of the national Government ofthe paying governmental body is exempt from the purpose of performing the services. the Philippines or any of its agencies in theU.S. income tax. However, the exemption does discharge of governmental functions are exemptnot apply if the services are performed in the Pensions paid by the Netherlands for services from U.S. income tax.United States by a resident of the United States performed for the Netherlands are exempt fromwho either: U.S. income tax unless the individual is both a

resident and national of the United States. Poland• Is a U.S. citizen, orThese exemptions do not apply to income or

Wages, salaries, and similar income, including• Did not become a U.S. resident only to pensions for services performed in connectionpensions, annuities, and similar benefits, paidperform the services. with a business carried on by the Netherlands,from public funds of Poland to a citizen of Polandits political subdivisions, or local authorities.(other than a U.S. citizen or one admitted to thePensions paid by Luxembourg, its political

subdivisions, or local authorities for services United States for permanent residence) for laborperformed for Luxembourg are exempt from New Zealand or personal services performed as an employeeU.S. income tax unless the recipient is both a of the national Government of Poland in the

Income (other than pensions) paid by the Gov-resident and citizen of the United States. discharge of governmental functions are exempternment of New Zealand, its political subdivi-These exemptions do not apply to income or from U.S. income tax.sions, or local authorities for services performedpensions for services performed in connectionin the discharge of governmental functions iswith a trade or business carried on by Luxem-exempt from U.S. income tax. However, thebourg, its political subdivisions, or local authori- Portugalincome is not exempt if the services are per-ties.formed in the United States by a U.S. citizen Income, other than a pension, paid by Portugal,resident in the United States or by a resident of its political or administrative subdivisions, or lo-the United States who did not become a residentMexico cal authorities to an individual for services per-only to perform the services. formed for the paying governmental body is

Income, other than a pension, paid by Mexico, Pensions paid by New Zealand in considera- exempt from U.S. income tax. However, theits political subdivisions, or local authorities to an tion for past governmental services are exempt exemption does not apply to payments for serv-individual for services performed for the paying from U.S. income tax unless paid to U.S. citizens ices performed in the United States by a U.S.governmental body is exempt from U.S. income resident in the United States. resident who either:tax. However, the exemption does not apply if These exemptions do not apply to payments

• Is a U.S. national, orthe services are performed in the United States for services performed in connection with anyby a U.S. resident who either: trade or business carried on for profit by the • Did not become a U.S. resident only to

Government of New Zealand (or its subdivisions• Is a U.S. national, or perform the services.or local authorities).

• Did not become a resident of the UnitedPensions paid by Portugal for services per-States solely for purposes of performing

formed for Portugal are exempt from U.S. in-the services. Norway come tax unless the recipient is a resident andnational of the United States.Pensions paid by Mexico, its political subdivi- Wages, salaries, and similar income, including

These exemptions do not apply to income orsions, or local authorities for services performed pensions and similar benefits paid by or frompensions for services performed in connectionfor the paying governmental body are exempt public funds of Norway or its political subdivi-with a business carried on by Portugal or itsfrom U.S. income tax unless the individual is sions or local authorities to a citizen of Norwaypolitical or administrative subdivisions, or localboth a resident and national of the United for labor or personal services performed for Nor-

States. way or any of its political subdivisions or local authorities.




• Did not become a U.S. resident solely forRomania South Africathe purpose of performing the services.

Wages, salaries, and similar income, including Income, other than a pension, paid by Southpensions, annuities, and similar benefits, paid Africa or its political subdivisions or local authori- Pensions paid by Sweden, its political subdivi-from public funds of Romania to a citizen of ties to an individual for services performed for sions, or local authorities for services performedRomania (other than a U.S. citizen or one admit- the paying governmental body is exempt from for Sweden are exempt from U.S. tax unless theted to the United States for permanent resi- U.S. income tax. However, the exemption does individual is both a resident and citizen of thedence) for labor or personal services performed not apply to payments for services performed in United States.as an employee of the national Government of the United States by a resident of the United

These exemptions do not apply to income orRomania in the discharge of governmental func- States who either:pensions for services performed in connectiontions are exempt from U.S. income tax. • Is a U.S. citizen, or with a business carried on by Sweden, its politi-cal subdivisions, or local authorities.• Did not become a U.S. resident only to

Russia perform the services.

Income, other than a pension, paid by Russia, its SwitzerlandPensions paid by South Africa for servicesrepublics, or local authorities to an individual for performed for South Africa are exempt from U.S.

Income, other than a pension, paid by Switzer-government services is exempt from U.S. tax. income tax unless the recipient is both a residentland or its political subdivisions or local authori-However, the exemption does not apply if the and citizen of the United States.

services are performed in the United States by a ties to an individual for services performed forThese exemptions do not apply to income orU.S. resident who either: the paying governmental body is exempt from

pensions for services performed in connectionU.S. income tax. However, the exemption does• Is a U.S. citizen, or with a business carried on by South Africa or itsnot apply to payments for services performed insubdivisions or local authorities.• Did not become a U.S. resident solely for the United States by a resident of the United

the purpose of performing the services. States who either:

Spain • Is a U.S. citizen, orPensions paid by Russia, its republics, or lo-cal authorities for services performed for Russia • Did not become a U.S. resident only toIncome, other than a pension, paid by Spain, itsare exempt from U.S. tax unless the individual is political subdivisions, or local authorities to an perform the services.both a resident and citizen of the United States. individual for services performed for the paying

These exemptions do not apply to income or governmental body is exempt from U.S. income Pensions paid by Switzerland for servicespensions for services performed in connection tax. However, the exemption does not apply to performed for Switzerland are exempt from U.S.with a business. payments for services performed in the United income tax unless the recipient is both a resident

States by a resident of the United States who and citizen of the United States.either: These exemptions do not apply to income orSlovak Republic

• Is a U.S. citizen, or pensions for services performed in connectionIncome, including a pension, paid from the pub- with a business carried on by Switzerland or its• Did not become a U.S. resident only tolic funds of the Slovak Republic, its political subdivisions or local authorities.perform the services.subdivisions, or local authorities to a Slovakcitizen for services performed in the discharge of

Pensions paid by Spain, its political subdivi-governmental functions is exempt from U.S. in- Thailandsions, or local authorities for services performedcome tax. This exemption does not apply tofor Spain are exempt from U.S. tax unless the Income, other than a pension, paid by Thailandincome paid for services performed in connec-individual is both a citizen and resident of thetion with a business carried on by the Slovak or its political subdivisions or local authorities toUnited States.Republic, its political subdivisions, or local au- an individual for services performed for the pay-

These exemptions do not apply to income orthorities. ing governmental body is exempt from U.S. in-pensions for services performed in connection come tax. However, the exemption does notwith a trade or business carried on by Spain, its apply to payments for services performed in the

Slovenia subdivisions, or local authorities. United States by a resident of the United Stateswho either:Income, other than a pension, paid from public

funds of Slovenia, its political subdivisions, or • Is a U.S. citizen, orSri Lankalocal authorities to an individual for services per- • Did not become a U.S. resident only toIncome, including a pension, paid from the pub-formed for the paying governmental body in the

perform the services.lic funds of Sri Lanka, its political subdivisions, ordischarge of governmental functions is exemptlocal authorities to a citizen or national of Srifrom U.S. income tax. However, the exemption

Pensions paid by Thailand for services per-Lanka for services performed for Sri Lanka in thedoes not apply if the services are performed informed for Thailand are exempt from U.S. in-discharge of functions of a governmental naturethe United States by a resident of the Unitedcome tax unless the recipient is both a residentis exempt from U.S. income tax. This exemptionStates who either:and citizen of the United States.does not apply to income paid for services per-• Is a U.S. citizen, or formed in connection with a business carried on These exemptions do not apply to income or

by Sri Lanka, its political subdivisions, or local• Did not become a U.S. resident only to pensions for services performed in connectionauthorities.perform the services. with a business carried on by Thailand or its

subdivisions or local authorities.Pensions paid from the public funds of Slove-

Swedennia, its political subdivisions, or local authoritiesfor services performed for Slovenia in the dis- Trinidad and Tobago

Income, other than a pension, paid by Sweden,charge of governmental functions are exemptits political subdivisions, or local authorities to an Wages, salaries, and similar income and pen-from U.S. income tax unless the recipient is bothindividual for services performed for the paying sions, annuities, and similar benefits paid by ora resident and citizen of the United States.governmental body is exempt from U.S. income from the public funds of the Government of Trini-tax. However, the exemption does not apply if dad and Tobago to a national of that country forthe services are performed in the United States services performed for Trinidad and Tobago inby a U.S. resident who either: the discharge of governmental functions are ex-

empt from U.S. tax.• Is a U.S. citizen, or




subdivisions, or local authorities to an individual rents, and royalties. The income code numbersTunisiashown in this table are the same as the incomefor services performed for the paying govern-

Income, other than a pension, paid by Tunisia, codes on Form 1042-S, Foreign Person’s U.S.mental body is exempt from U.S. income tax.its political subdivisions, or local authorities to a Source Income Subject to Withholding.However, the exemption does not apply if theTunisian citizen for personal services performed services are performed in the United States by ain the discharge of governmental functions is Interest. If you are a nonresident alien whoresident of the United States who either:exempt from U.S. income tax. receives interest that is not effectively con-• Is a U.S. citizen, orPensions paid by Tunisia, its political subdi- nected with the conduct of a U.S. trade or busi-visions, or local authorities for services per- ness, you do not include the interest in income if• Did not become a U.S. resident only toformed for Tunisia are exempt from U.S. income it is paid on deposits with banks, on accounts orperform the services.tax unless the recipient is a U.S. citizen. deposits with certain financial institutions, or on

These exemptions do not apply to income or certain amounts held by insurance companies. Pensions paid by, or funds created by, thepensions for services performed in connection These amounts are exempt from U.S. tax evenUnited Kingdom, its political subdivisions, or lo-with a trade or business carried on by Tunisia, its though they are considered to be income from acal authorities for services performed for thepolitical subdivisions, or local authorities. U.S. source. Also exempt from U.S. tax (al-United Kingdom are exempt from U.S. incomethough considered from U.S. sources) is certaintax unless the recipient is both a resident andportfolio interest on obligations issued after Julycitizen of the United States.Turkey18, 1984. See Publication 519 for more informa-

These exemptions do not apply to income or tion.Income, other than a pension, paid by Turkey or pensions for services performed in connectionits political subdivisions or local authorities to an

with a business carried on by the United King-individual for services performed for the paying Table 2dom, its political subdivisions, or local authori-governmental body is exempt from U.S. incometies. This table lists the different kinds of personaltax. However, the exemption does not apply to

service income that may be fully or partly ex-payments for services performed in the Unitedempt from U.S. income tax. You must meet all ofStates by a resident of the United States who Venezuela the treaty requirements before the item of in-either:come can be exempt from U.S. income tax. TheIncome, other than a pension, paid by Vene-• Is a U.S. citizen, or income code numbers shown in this table are

zuela, its political subdivisions, or local authori-the same as the income codes on Form 1042-S,• Did not become a U.S. resident only to ties to an individual for services performed for Foreign Person’s U.S. Source Income Subjectperform the services.

the paying governmental body is exempt from to Withholding.U.S. income tax. However, the exemption doesPensions paid by Turkey for services per-not apply to payments for services performed informed for Turkey are exempt from U.S. income Independent personal services. The termthe United States by a resident of the Unitedtax unless the recipient is both a resident and “independent personal services” generallyStates who either:citizen of the United States. means services you perform for your own ac-

These exemptions do not apply to income or count if you receive the income and bear the• Is a U.S. citizen, orpensions for services performed in connection losses arising from those services. Examples of• Did not become a U.S. resident only towith a business carried on by Turkey or its subdi- these services are those provided by physi-

perform the services.visions or local authorities. cians, lawyers, engineers, dentists, and ac-countants who perform personal services as

Pensions paid by Venezuela, its political sub- sole proprietors or partners.divisions, or local authorities for services per-Ukraineformed for Venezuela are exempt from U.S. Dependent personal services. DependentIncome, other than a pension, paid from public income tax unless the recipient is both a resident personal services usually are those you performfunds of Ukraine, its political subdivisions, or and citizen of the United States. for someone else as an employee.local authorities to an individual for services per-

These exemptions do not apply to paymentsformed in the discharge of governmental func-or pensions for services performed in connec- Table 3tions is exempt from U.S. income tax. However,tion with a business carried on by Venezuela, itsthe exemption does not apply if the services are

This table lists the countries that have tax trea-political subdivisions, or local authorities.performed in the United States by a resident ofties with the United States. Some treaties arethe United States who either:published in the Cumulative Bulletins (C.B.),

• Is a U.S. citizen, or which contain official matters of the InternalRevenue Service. The column headed Citation• Did not become a U.S. resident only to Explanation shows the number of the C.B. and the page onperform the services.which a particular treaty may be found.of Tables

Regulations implementing some treatiesPensions paid by, or by funds created by,were issued as Treasury Decisions (T.D.). OtherUkraine, its political subdivisions, or local au- The paragraphs below describe the tables thattreaties are explained by Treasury explanation.thorities for services performed for Ukraine are follow and provide additional information thatThe fifth column lists the T.D. numbers and theexempt from U.S. income tax unless the recipi- may make the tables more useful to you. Be-C.B. in which each T.D. or Treasury explanationent is both a resident and citizen of the United cause there is an effective date election avail-is printed.States. able for the new treaty with Belgium and the

These exemptions do not apply to income or You can buy volumes of the C.B. from theprotocol with Germany, two entries are shownpensions for services performed in connection Government Printing Office or you are welcomefor those countries. The effective date of thesewith a trade or business carried on by Ukraine, to read them in most Internal Revenue Serviceitems is shown under What’s New at the begin-its political subdivisions, or local authorities. offices. Many public libraries and business orga-ning of this publication.

nizations subscribe to a commercial tax servicethat publishes the treaties and regulations orTable 1United Kingdom explanations.

This table lists the income tax rates on suchIncome, other than a pension, paid from thepublic funds of the United Kingdom, its political income as interest, dividends, capital gains,




Tab

le 1

.Ta

x R

ates

on

Inco

me

Oth

er T

han

Per

sona

l Ser

vice

Inc

om

e U

nder

Cha

pte

r 3,

Int

erna

l Rev

enue

Co

de,

and

Inc

om

e Ta

x Tr

eati

esIn

com

e C

od

e N

umb

erC

oun

try

of

Res

iden

ce o

f P

ayee

Nam

eC

od

e

12

36

79

1011

1213

1421

Inte

rest

Pai

d b

yU

.S.

Ob

ligo

rsG

ener

al

Inte

rest

on R

eal

Prop

erty

Mor

tgag

es

Inte

rest

Paid

to

aC

ontr

ollin

gFo

reig

nC

orpo

ra-

tion

Div

iden

ds

Pai

d b

yU

.S.

Co

rpo

ra-

tio

ns—

Gen

eral

a

Qua

lifyi

ngfo

r D

irect

Div

iden

dR

atea,

bC

apit

alG

ains

vIn

dus

tria

lR

oya

ltie

s

Co

pyr

ight

Ro

yalt

ies

Mo

tio

nP

ictu

res

and

Tel

evis

ion

Oth

er

Rea

lPr

oper

tyIn

com

ean

dN

atur

alR

esou

rces

Roy

altie

s v

Pen

sio

nsan

dA

nnui

ties

Soci

alSe

curit

yPa

ymen

t u

AS

BB

BE

CA

g,tt

,uu 10 g 5g 15 g 10

g,ff

,tt,

uu10 g 5

g 15

g,ff10

g,tt

,uu 10 g 5g 15 g 10

g,p

p15

g,x 15 g 15

g, x15

g,p

p,x

x 5

g,x 5 g 5

g,x 5

30 g,l 0

g,l 0

r 30

g 0 g 5 g 0 g 0

g 5 g 5 h 0

g 10

g 5 g 5 g 0 g 0

30d0

d,f 0

30 30 30

d,f 0 15

30 30 30 0C

H

CY

EZ

g 10g 10

g 10

n 030

30g 10

g 10g 10

g 0g,

ff0

g 0

g 10 30 g 15g,

x 15

g 10 30 g 5g,

x 5

30 o 0g,

l 0g,

l 0

g,w10 0 g 0

g 10

g 10 0 g 0 g 0

g 10 0 g 0 g 0

30d

, m

m0

d,f 0

30 30 30

30 d,f 0

30 30 30 30

EG

FI FR GM

GR

30 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30

0 30 30 30 30ee

30 30 0 0 0 30 0 30 30 30 30 30 30 30

h 15

g,oo

0 g 0

g,m0 h 0

30

g,ff

,oo 0

g,ff0

g,m

,ff0 h 0

h 15

g,oo

0 g 0 g 0 30

h 15

g,zz

,ab15

b,g

,pp15

h 5

g,xx

,zz,

ab5

g,x 5 30

h,l 0

g,l 0

g,l 0

g,l 0

h 0 g 0 g 5

h 0 g 0 g 0

g,d

d0 30

g 15 g 0 g 0 g 0

d,f 0

d,f 0

d0

HU

IC IN ID EI

g 0 g 0g,

aa15 g 10 g 0

g 0 g 0g,

aa15 g 10 g,ff0

g 0 g 0g,

aa15 g 10

g 15 g 15g,

x 25 g 15

g 5 g 5g,

x 15

g 10

g,l 0

g,l 0 30

g,l,z

0

g 0 g 0g,

bb10

g,b

b10 g 0

g 0 30 g 15 g 10 g 0

g 0 g 0g 15 g 10 g 0

d,f 0

d,f 0

d,f,

q15 d,f 0

IS IT JM JA KZ

g,aa

,ii17

1 ⁄2g 15 g 12

1 ⁄2

g,w

w,z

z,ac

10g 10

g,aa

,ff,ii17

1 ⁄2g 15 g 12

1 ⁄2

g,ff

,ww

,zz,

ac10

g,ff10

g,aa

,ii17

1 ⁄2g 15 g 1

21 ⁄2

g,w

w,z

z,ac

10g 10

g,x 25 g 15 g 15

g,w

,zz,

ab10

g,gg

15

g,x 12

1 ⁄2e,

g 5g 10

e,g,

ww

,zz,

ab5

g,gg

5

g,cc

0g,

l 0g,

l 0

g,l 0

g,l 0

g 15g,

s 10 g 10

g,w

w0

g,jj 10

g 10 g 8g 10

g,w

w0

g 10

g 10 g 5g 10

g,w

w0

g 10

f 0

d,f,

p0

d,f 0

d0

d,f 0

KS

MX

MO

NL

NZ

NO

g 12

g,q

q15 g 15 g 0

g 10 g 0

g 12

g,ff

,qq15 g 15 g 0

g 10 g 0

g 12 g 15 g 15 g 0

g 10 g 0

g 15

g,p

p,v

v 10 g 15 g 15

g 15 g 15

g 10

g,p

p,v

v,xx

5g 10 g 5

g 15 g 15

g,l 0

g,hh

0

g,l 0

g,l 0

g,l 0

g,l 0

g 15 g 10 h 10 g 0

g 10 g 0

g 10 g 10 g 10g,

dd0

g 10 h 0

g 10 g 10 g 10 g 0

g 10 g 0

d,f 0

d0

d,f 0

d,f,

t 0

d0

d,f 0

Aus

tral

ia

Bar

bad

osB

elgi

um (

old

tre

aty)

Can

ada

Chi

na,

Peo

ple

’s R

ep.

ofC

omm

onw

ealth

of

Ind

epen

den

t S

tate

sC

ypru

sC

zech

Rep

ublic

Egy

pt

Finl

and

Fran

ce

Ger

man

y (a

s m

odifi

ed)

Gre

ece

Hun

gary

Icel

and

Ind

ia

Ind

ones

iaIr

elan

dIs

rael

Italy

Jam

aica

Jap

anK

azak

hsta

nK

orea

, R

ep.

of

Mex

ico

Mor

occo

Net

herla

nds

New

Zea

land

Nor

way

AU

g,m0

g,m0

g,x 15

g,x 5

g 0g 10

g 030

030

Aus

tria

g,m

,ff0

g,l 0

g 0g,

l 030

Est

onia

Latv

ia

EN

LG LH

g,oo

10

g,oo

10

g,oo

10

g,ff

,oo 10

g,ff

,oo 10

g,ff

,oo 10

g,oo

10

g,oo

10

g,oo

10

g,x 15

g,x 15

g,x 15

g,x 5

g,x 5

g,x 5

g,l 0

g,b

b5

g 10 g 10 g 10

g 10 g 10 g 10

30 30 30

d,f 0

d,f 0

Lith

uani

a

g,l 0

g,l 0

g,b

b5

g,b

b5

d,f 0

30 30 30

DA

g,oo

0g,

ff,o

o 0D

enm

ark

g,oo

0g,

zz,a

b15

g,xx

,zz,

ab5

g 0g 0

g 0g 0

3030

d,m

m,s

s 30

Luxe

mb

ourg

LUg,

h 0g,

ff,h0

g,h 0

g,x 15

g,x 5

g 0g 0

g 0g 0

30d0

30

g,p

p15

g,p

p5

Bel

gium

(ne

w t

reat

y)B

E

GM

30 30 30

0 0 30

g 0g 0

g,m0

g,x 15 30

g,x 5

g,xx

,zz,

ab5

g,l 0

g 0 g 0

g,d

d0

g 0d0

d,f 0

g,zz

,ab15

30h 0

h 0d

,f 0

Ger

man

y

g,m15

g,m

,ff15

g,m15

g,zz

,ab15

g,xx

,zz,

ab5

g,l 0

g 0g 0

g 030

d,f 0

30

BG

g,m

,yy 10

g,m

,yy 10

g,p

p15

g,p

p10

g 10g 10

g 1030

d,f,

q0

30B

angl

ades

hg,

m,ff

,yy 10

g,hh

0

30d




Tab

le 1

.Ta

x R

ates

on

Inco

me

Oth

er T

han

Per

sona

l Ser

vice

Inc

om

e U

nder

Cha

pte

r 3,

Int

erna

l Rev

enue

Co

de,

and

Inc

om

e Ta

x Tr

eati

esIn

com

e C

od

e N

umb

erC

oun

try

of

Res

iden

ce o

f P

ayee

Nam

eC

od

e

12

36

79

1011

1213

1421

Inte

rest

Pai

d b

yU

.S.

Ob

ligo

rsG

ener

al

Inte

rest

on R

eal

Prop

erty

Mor

tgag

es

Inte

rest

Paid

to

aC

ontr

ollin

gFo

reig

nC

orpo

ra-

tion

Div

iden

ds

Pai

d b

yU

.S.

Co

rpo

ra-

tio

ns—

Gen

eral

a

Qua

lifyi

ngfo

r D

irect

Div

iden

dR

atea,

bC

apit

alG

ains

vIn

dus

tria

lR

oya

ltie

s

Co

pyr

ight

Ro

yalt

ies

Mo

tio

nP

ictu

res

and

Tel

evis

ion

Oth

er

Rea

lPr

oper

tyIn

com

ean

dN

atur

alR

esou

rces

Roy

altie

s v

Pen

sio

nsan

dA

nnui

ties

Soci

alSe

curit

yPa

ymen

t u

Sp

ain

Sw

eden

Trin

idad

& T

obag

oTu

nisi

a

SP

SW

TD TS

g 10 g 0 30 g 15

g 10 g,ff0 30 g 15

g 10 g 0 30 g 15

g,x 15

g,zz

,ab15 30

g,x 20

g,x 10

g,xx

,zz,

ab5

30g,

x 14

g,l 0

g,l 0 30 g,l 0

g,y 8 g 0

g 15g,

bb10

g,y 8 g 0 30 g 15

g,y 5 g 0 g 0

g 15

30d

,f 0

30 30 30

d0

d,f 0 f 0

30 30 30 30

Oth

er C

ount

ries

3030

3030

3030

3030

3030

3030

Sw

itzer

land

g,m0

g,m

,ff0

g,m0

g,x 15

g,x 5

g 0g 0

g 0d0

3015

l 0Th

aila

ndTH

g,aa

15g,

aa,ff15

g,aa

15g,

x 15g,

x 1030

bb8

5ll 15

30d

,f 030

Turk

eyTU

g,i,a

a 15g,

i,aa,

ff15

g,i,a

a 15g,

x 20g,

x 15g,

l 0b

b5

1010

30d0

30

3030

LOg 0

g,ff0

g 0g,

x 15g,

x 5g,

l 0g 10

g 0g 0

d,f 0

Slo

vak

Rep

ublic

3030

SF

g,m0

g,m

,ff0

g,m0

g,x 15

g,x 5

l 0g 0

g 0g 0

d,k

k 15S

outh

Afr

ica

30 300 30

RO

RS

g 10 g 0

g 10 g,ff0

g 10 g 0

g 10g,

gg10

g 10g,

gg5

g,l 0

g,l 0

g 15 g 0

g 10 g 0

g 10 g 0

d,f 0d0

Rom

ania

Rus

sia

VE

g,ff

,nn,

oo10

g,ff

,nn,

oo10

g,p

p15

g,p

p5

g 10d

,mm0

g,nn

,oo 10

Ven

ezue

lag,

l 0g,

bb5

g 10

SZ

3030

Ukr

aine

UP

g 0g,

ff0

g 0g,

gg15

g,gg

5g 0

g 10g 10

g 1030

d0

30

3030

SI

g 5g,

ff5

g 5g,

pp15

g,p

p5

g 0g 5

g 5g 5

d,f 0

Slo

veni

a

0U

Kg,

ff,o

o,w

w0

g,oo

,ww0

g,p

p,w

w15

g,p

p,w

w,x

x 5g,

ww0

d,f 0

g,oo

,ww0

Uni

ted

Kin

gdom

g 0g,

ww0

g,w

w0

3030 30 30 30

30 30 30 30

PK

RP

PL

PO

30 g 15 g 0g 10

30 g 15 g 0g,

ff10

30 g 15 g 0g 10

30 g 25 g 15g,

x 15

h 15 g 20 g 5g,

x 5

g,l 030 g,l 0

g,l 0

h 0g 15 g 10 g 10

30 g 15 g 10 g 10

h 0g 15 g 10 g 10

d,j 0

q30 30 d,f 0

Pak

ista

nP

hilip

pin

esP

olan

dP

ortu

gal

3030

CE

g,m10

g,m

,ff10

g,m10

g,rr15

g,hh0

g 0g 1

0g,

s 10

d,m

m0

Sri

Lank

ag,

rr15




a b c d e f g h

No

U.S

. tax

is im

pose

d on

a d

ivid

end

paid

by

a U

.S. c

orpo

ratio

n th

atre

ceiv

ed a

t le

ast

80%

of

its g

ross

inc

ome

from

an

activ

e fo

reig

nbu

sine

ss f

or t

he 3

-yea

r pe

riod

befo

re t

he d

ivid

end

is d

ecla

red.

The

red

uced

rat

e ap

plie

s to

div

iden

ds

pai

d b

y a

sub

sid

iary

to

a fo

reig

n p

aren

t co

rpor

atio

n th

at h

as t

he r

equi

red

per

cent

age

of s

tock

ow

ners

hip

. In

som

e ca

ses,

the

inco

me

of th

e su

bsi

dia

rym

ust

mee

t ce

rtai

n re

qui

rem

ents

(e.

g.,

a ce

rtai

n p

erce

ntag

e of

its t

otal

inc

ome

mus

t co

nsis

t of

inc

ome

othe

r th

an d

ivid

end

san

d in

tere

st).

The

exem

ptio

n or

red

uctio

n in

rat

e ap

plie

s on

ly if

the

rec

ipie

ntis

sub

ject

to

tax

on t

his

inco

me

in t

he c

ount

ry o

f re

sid

ence

.O

ther

wis

e, a

30%

rat

e ap

plie

s.E

xem

ptio

n d

oes

not

app

ly t

o U

.S.

Gov

ernm

ent

(fed

eral

, st

ate,

or l

ocal

) p

ensi

ons

and

ann

uitie

s; a

30%

rat

e ap

plie

s to

the

sep

ensi

ons

and

ann

uitie

s. F

or th

is p

urp

ose,

railr

oad

retir

emen

t tie

r2,

dua

l, an

d s

upp

lem

enta

l b

enef

its a

re n

ot c

onsi

der

ed U

.S.

Gov

ernm

ent

pen

sion

s or

ann

uitie

s. U

.S.

Gov

ernm

ent

pen

sion

sp

aid

to

an i

ndiv

idua

l w

ho i

s b

oth

a re

sid

ent

and

nat

iona

l of

Ban

glad

esh,

B

elgi

um,

Chi

na,

Den

mar

k,

Est

onia

, Fi

nlan

d,

Ger

man

y,

Hun

gary

, In

dia

, Ir

elan

d,

Italy

, La

tvia

, Li

thua

nia,

Luxe

mb

ourg

, M

exic

o,

the

Net

herla

nds,

P

ortu

gal,

Rus

sia,

Slo

veni

a, S

outh

Afr

ica,

Sp

ain,

Sw

itzer

land

, Tha

iland

, Tur

key,

the

Uni

ted

Kin

gdom

, or

Ven

ezue

la a

re e

xem

pt

from

U.S

. ta

x. U

.S.

Gov

ernm

ent

pen

sion

s p

aid

to

an

in

div

idua

l w

ho

is

bot

h a

resi

den

t an

d c

itize

n of

Kaz

akst

an, N

ew Z

eala

nd, o

r S

wed

en a

reex

emp

t fr

om U

.S.

tax.

For I

taly

, the

red

uced

rate

is 1

0% if

the

fore

ign

corp

orat

ion

owns

10%

to

50%

of

the

votin

g st

ock

(for

a 12

-mon

th p

erio

d)

of t

heco

mp

any

pay

ing

the

div

iden

ds.

For

Jap

an,

div

iden

ds

rece

ived

from

a m

ore

than

50%

ow

ned

cor

por

ate

sub

sid

iary

are

exe

mp

tif

cert

ain

cond

ition

s ar

e m

et.

Incl

udes

alim

ony.

The

exem

ptio

n or

red

uctio

n in

rate

doe

s no

t ap

ply

if th

e re

cip

ient

has

a p

erm

anen

t es

tab

lishm

ent

in t

he U

nite

d S

tate

s an

d t

hep

rop

erty

giv

ing

rise

to t

he in

com

e is

eff

ectiv

ely

conn

ecte

d w

ithth

is p

erm

anen

t est

ablis

hmen

t. U

nder

cer

tain

trea

ties,

exe

mp

tion

or re

duc

tion

in ra

te a

lso

doe

s no

t ap

ply

if th

e p

rop

erty

pro

duc

ing

the

inco

me

is e

ffec

tivel

y co

nnec

ted

with

a f

ixed

bas

e in

the

Uni

ted

Sta

tes

from

whi

ch t

he r

ecip

ient

per

form

s in

dep

end

ent

per

sona

l se

rvic

es.

Eve

n w

ith t

he t

reat

y, i

f th

e in

com

e is

not

effe

ctiv

ely

conn

ecte

d w

ith a

tra

de

or b

usin

ess

in t

he U

nite

dS

tate

s b

y th

e re

cip

ient

, th

e re

cip

ient

will

be

cons

ider

ed a

s no

tha

ving

a p

erm

anen

t es

tab

lishm

ent

in t

he U

nite

d S

tate

s un

der

Inte

rnal

Rev

enue

Cod

e se

ctio

n 89

4(b

).Th

e ex

emp

tion

or re

duc

tion

in ra

te d

oes

not a

pp

ly if

the

reci

pie

ntis

eng

aged

in a

tra

de

or b

usin

ess

in t

he U

nite

d S

tate

s th

roug

ha

per

man

ent

esta

blis

hmen

t th

at

is

in

the

Uni

ted

S

tate

s.H

owev

er, i

f the

inco

me

is n

ot e

ffec

tivel

y co

nnec

ted

with

a t

rad

eor

bus

ines

s in

the

Uni

ted

Sta

tes

by

the

reci

pie

nt,

the

reci

pie

ntw

ill b

e co

nsid

ered

as

not

havi

ng a

per

man

ent

esta

blis

hmen

t in

the

Uni

ted

Sta

tes

to a

pp

ly t

he r

educ

ed t

reat

y ra

te t

o th

at it

emof

inco

me.

i

l m n o p q r s t u v

Con

tinge

nt in

tere

st t

hat

doe

s no

t q

ualif

y as

por

tfol

io in

tere

st is

trea

ted

as

a d

ivid

end

and

is

sub

ject

to

the

rate

und

er c

olum

n6

or 7

.

Exe

mp

tion

doe

s no

t ap

ply

to g

ains

from

the

sale

of r

eal p

rop

erty

.H

owev

er,

for

U.S

. re

al p

rop

erty

tha

t w

as o

wne

d c

ontin

uous

lysi

nce

June

18,

198

0, b

y a

Net

herla

nds

resi

den

t, th

e ta

xab

le g

ain

may

be

limite

d t

o th

e ap

pre

ciat

ion

afte

r 19

84.

For

det

ails

, se

eA

rtic

le 1

4(2)

of

the

trea

ty.

The

exem

ptio

n ap

plie

s on

ly t

o in

tere

st o

n cr

edits

, lo

ans,

and

othe

r in

deb

ted

ness

co

nnec

ted

w

ith

the

finan

cing

of

tr

ade

bet

wee

n th

e U

nite

d S

tate

s an

d t

he C

.I.S

. m

emb

er.

It d

oes

not

incl

ude

inte

rest

from

the

cond

uct o

f a g

ener

al b

anki

ng b

usin

ess.

The

exem

ptio

n ap

plie

s on

ly t

o ga

ins

from

the

sal

e or

oth

erd

isp

ositi

on o

f p

rop

erty

acq

uire

d b

y gi

ft o

r in

herit

ance

.Th

e ex

emp

tion

doe

s no

t ap

ply

if t

he r

ecip

ient

was

a r

esid

ent

ofth

e U

nite

d S

tate

s w

hen

the

pen

sion

was

ear

ned

or

whe

n th

ean

nuity

was

pur

chas

ed.

Ann

uitie

s p

aid

in

retu

rn f

or o

ther

tha

n th

e re

cip

ient

’s s

ervi

ces

are

exem

pt.

For

Ban

glad

esh,

exe

mp

tion

doe

s no

t ap

ply

to

annu

ity r

ecei

ved

for

ser

vice

s re

nder

ed.

Gen

eral

ly,

if th

e p

rop

erty

was

ow

ned

by

the

Can

adia

n re

sid

ent

on S

epte

mb

er 2

6, 1

980,

not

as

par

t of

the

bus

ines

s p

rop

erty

of a

per

man

ent

esta

blis

hmen

t or

fix

ed b

ase

in t

he U

.S.,

the

taxa

ble

gai

n is

lim

ited

to

the

app

reci

atio

n af

ter

1984

. C

apita

lga

ins

on

per

sona

l p

rop

erty

no

t b

elon

ging

to

a

per

man

ent

esta

blis

hmen

t or

fix

ed b

ase

of t

he t

axp

ayer

in

the

U.S

. ar

eex

emp

t.Th

e ra

te f

or r

oyal

ties

with

res

pec

t to

tan

gib

le p

erso

nal p

rop

erty

is 7

% (

5% in

the

cas

e of

Sri

Lank

a).

The

exem

ptio

n d

oes

not

app

ly i

f (1

) th

e re

cip

ient

was

a U

.S.

resi

den

t d

urin

g th

e 5-

year

per

iod

bef

ore

the

dat

e of

pay

men

t,(2

) the

am

ount

was

pai

d fo

r em

plo

ymen

t per

form

ed in

the

Uni

ted

Sta

tes,

and

(3)

the

am

ount

is

not

a p

erio

dic

pay

men

t, o

r is

alu

mp

-sum

pay

men

t in

lieu

of

a rig

ht t

o re

ceiv

e an

ann

uity

.A

pp

lies

to 8

5% o

f th

e so

cial

sec

urity

pay

men

ts r

ecei

ved

fro

mth

e U

.S.

Gov

ernm

ent.

The

eff

ectiv

e ra

te o

n th

e to

tal

soci

alse

curit

y p

aym

ents

rec

eive

d i

s 85

% o

f th

e ra

te s

how

n in

the

tab

le.

Thes

e ra

tes

also

ap

ply

to

the

soci

al s

ecur

ity e

qui

vale

ntp

ortio

n of

tie

r 1

railr

oad

ret

irem

ent

ben

efits

(in

com

e co

de

22)

rece

ived

from

the

U.S

. The

rem

aind

er o

f tie

r 1,

all

of t

ier

2, d

ual,

and

sup

ple

men

tal r

ailro

ad r

etire

men

t b

enef

its (i

ncom

e co

de

23)

are

taxe

d a

s sh

own

in c

olum

n 14

,“P

ensi

ons

and

Ann

uitie

s.”

Gai

ns o

n th

e d

isp

ositi

on o

f U

.S.

real

pro

per

ty i

nter

ests

are

cons

ider

ed e

ffec

tivel

y co

nnec

ted

with

a U

.S.

trad

e or

bus

ines

san

d t

hus

are

sub

ject

to

grad

uate

d r

ates

of

tax

rath

er t

han

the

flat

per

cent

age

show

n in

thi

s co

lum

n.

The

rate

is

15

%

(30%

fo

r G

erm

any

and

S

witz

erla

nd)

for

cont

inge

nt in

tere

st t

hat

doe

s no

t q

ualif

y as

por

tfol

io in

tere

st.

w x y z aa

bb cc dd ff gg hh

ii jj

Tax

imp

osed

on

70%

of

gros

s ro

yalti

es f

or r

enta

ls o

f in

dus

tria

l,co

mm

erci

al,

or s

cien

tific

eq

uip

men

t.Th

e ra

te i

n co

lum

n 6

app

lies

to d

ivid

end

s p

aid

by

a re

gula

ted

inve

stm

ent

com

pan

y (R

IC)

or a

rea

l es

tate

inv

estm

ent

trus

t(R

EIT

). H

owev

er,

that

rat

e ap

plie

s to

div

iden

ds

pai

d b

y a

RE

ITon

ly i

f th

e b

enef

icia

l ow

ner

of t

he d

ivid

end

s is

an

ind

ivid

ual

hold

ing

less

tha

n a

10%

inte

rest

(25

% in

the

cas

e of

Por

tuga

l,S

pai

n, a

nd T

unis

ia)

in t

he R

EIT

.R

oyal

ties

not

taxe

d a

t th

e 5%

or

8% r

ate

are

taxe

d a

t a

10%

rate

, un

less

foo

tnot

e (g

) ap

plie

s.Th

e ex

emp

tion

doe

s no

t ap

ply

if t

he r

ecip

ient

of

the

gain

is a

nin

div

idua

l who

is p

rese

nt in

the

Uni

ted

Sta

tes

for

mor

e th

an 1

19d

ays

dur

ing

the

year

.Th

e ra

te i

s 10

% i

f th

e in

tere

st i

s p

aid

on

a lo

an g

rant

ed b

y a

ban

k or

sim

ilar

finan

cial

inst

itutio

n. F

or T

haila

nd,

the

10%

rat

eal

so a

pp

lies

to i

nter

est

from

an

arm

’s l

engt

h sa

le o

n cr

edit

ofeq

uip

men

t, m

erch

and

ise,

or

serv

ices

.

This

is

the

rate

for

roy

altie

s fo

r th

e us

e of

, or

the

rig

ht t

o us

e,in

dus

tria

l, co

mm

erci

al,

and

sci

entif

ic e

qui

pm

ent.

The

rat

e fo

rro

yalti

es f

or in

form

atio

n co

ncer

ning

ind

ustr

ial,

com

mer

cial

and

scie

ntifi

c kn

ow-h

ow is

sub

ject

to

the

rate

in c

olum

n 12

.Th

e ex

emp

tion

doe

s no

t ap

ply

to

gain

fro

m t

he s

ale

or o

ther

dis

pos

ition

of

pro

per

ty d

escr

ibed

in A

rtic

le 1

4(2)

(c)

(cop

yrig

hts

of li

tera

ry,

artis

tic,

or s

cien

tific

wor

ks).

The

exem

ptio

n d

oes

not

app

ly t

o ci

nem

atog

rap

hic

item

s, o

rw

orks

on

film

, ta

pe,

or

othe

r m

eans

of

rep

rod

uctio

n fo

r us

e in

rad

io o

r te

levi

sion

bro

adca

stin

g.

for

serv

ices

per

form

ed f

or t

he U

nite

d S

tate

s, i

ts s

ubd

ivis

ions

,or

loca

l aut

horit

ies.

Exe

mp

tion

or re

duc

ed ra

te d

oes

not a

pp

ly to

an

exce

ss in

clus

ion

for

a re

sid

ual

inte

rest

in

a re

al e

stat

e m

ortg

age

inve

stm

ent

cond

uit

(RE

MIC

).Th

e ra

te i

n co

lum

n 6

app

lies

to d

ivid

end

s p

aid

by

a re

gula

ted

inve

stm

ent

com

pan

y (R

IC).

Div

iden

ds

pai

d b

y a

real

est

ate

inve

stm

ent

trus

t (R

EIT

) ar

e su

bje

ct t

o a

30%

rat

e.Th

e ex

emp

tion

doe

s no

t ap

ply

to

a sa

le o

f a

U.S

. co

mp

any’

sst

ock

rep

rese

ntin

g ow

ners

hip

of

50%

or

mor

e.

An

elec

tion

can

be

mad

e to

tre

at t

his

inte

rest

inc

ome

as i

f it

wer

e in

dus

tria

l an

d c

omm

erci

al p

rofit

s ta

xab

le u

nder

art

icle

8of

the

tre

aty.

If th

e p

aym

ents

wer

e fo

r the

use

of,

or th

e rig

ht to

use

, ind

ustr

ial,

com

mer

cial

, or

sci

entif

ic e

qui

pm

ent,

an

elec

tion

may

be

mad

eto

com

put

e th

e ta

x on

a n

et b

asis

as

if su

ch i

ncom

e w

ere

attr

ibut

able

to

a p

erm

anen

t es

tab

lishm

ent

or f

ixed

bas

e in

the

U.S

.kk

The

red

uced

rat

e d

oes

not

app

ly if

the

dis

trib

utio

n is

sub

ject

to

a p

enal

ty f

or e

arly

with

dra

wal

. A

nnui

ties

that

wer

e p

urch

ased

whi

le t

he a

nnui

tant

was

not

a r

esid

ent

of t

he U

nite

d S

tate

s ar

eno

t ta

xab

le in

the

Uni

ted

Sta

tes.

llTh

e ra

te is

5%

for r

oyal

ties

on th

e us

e of

any

cop

yrig

ht o

f lite

rary

,ar

tistic

, or

sci

entif

ic w

ork,

incl

udin

g so

ftw

are.

mm

Doe

s no

t ap

ply

to a

nnui

ties.

For

Den

mar

k, a

nnui

ties

are

exem

pt.

nnTh

e ra

te i

s 4.

95%

if

the

inte

rest

is

ben

efic

ially

ow

ned

by

afin

anci

al in

stitu

tion

(incl

udin

g an

insu

ranc

e co

mp

any)

.

qq

The

rate

is 4

.9%

for

inte

rest

der

ived

fro

m (

1) lo

ans

gran

ted

by

ban

ks a

nd in

sura

nce

com

pan

ies

and

(2) b

ond

s or

sec

uriti

es th

atar

e re

gula

rly a

nd s

ubst

antia

lly tr

aded

on

a re

cogn

ized

sec

uriti

esm

arke

t.

The

rate

is

10

%

for

inte

rest

no

t d

escr

ibed

in

th

ep

rece

din

g se

nten

ce a

nd p

aid

(i) b

y b

anks

or

(ii) b

y th

e b

uyer

of

mac

hine

ry a

nd e

qui

pm

ent

to t

he s

elle

r d

ue t

o a

sale

on

cred

it.

ooTh

e ra

te is

15%

for i

nter

est d

eter

min

ed w

ith re

fere

nce

to (a

) rec

eipt

s,sa

les,

inco

me,

pro

fits

or o

ther

cas

h flo

w o

f th

e de

btor

or

a re

late

dpe

rson

, (b

) an

y ch

ange

in t

he v

alue

of

any

prop

erty

of

the

debt

oror

a r

elat

ed p

erso

n, o

r (c

) any

div

iden

d, p

artn

ersh

ip d

istr

ibut

ion,

or

sim

ilar

paym

ent

mad

e by

the

deb

tor

or r

elat

ed p

erso

n.p

pTh

e ra

te i

n co

lum

n 6

app

lies

to d

ivid

end

s p

aid

by

a re

gula

ted

inve

stm

ent c

omp

any

(RIC

) or r

eal e

stat

e in

vest

men

t tru

st (R

EIT

).H

owev

er,

that

rat

e ap

plie

s to

div

iden

ds

pai

d b

y a

RE

IT o

nly

ifth

e b

enef

icia

l ow

ner

of t

he d

ivid

end

s is

(a) a

n in

div

idua

l hol

din

gno

t m

ore

than

a 1

0% in

tere

st in

the

RE

IT,

(b)

a p

erso

n ho

ldin

gno

t m

ore

than

5%

of

any

clas

s of

the

RE

IT’s

sto

ck a

nd t

hed

ivid

end

s ar

e p

aid

on

stoc

k th

at i

s p

ublic

ly t

rad

ed,

or (

c) a

per

son

hold

ing

not

mor

e th

an a

10%

int

eres

t in

the

RE

IT a

ndth

e R

EIT

is d

iver

sifie

d.

j k

Exe

mp

tion

is n

ot a

vaila

ble

whe

n p

aid

fro

m a

fun

d u

nder

an

emp

loye

es’

pen

sion

or

annu

ity p

lan,

if

cont

ribut

ions

to

it ar

ed

educ

tible

und

er U

.S.

tax

law

s in

det

erm

inin

g ta

xab

le i

ncom

eof

the

em

plo

yer.

Ap

plie

s to

100

% o

f the

soc

ial s

ecur

ity a

nd o

ther

pub

lic p

ensi

ons

rece

ived

fro

m t

he U

.S.

gove

rnm

ent.

eeU

.S.

soci

al s

ecur

ity b

enef

its p

aid

to

ind

ivid

uals

who

are

bot

hre

sid

ents

and

nat

iona

ls o

f In

dia

are

exe

mp

t fr

om t

ax if

the

y ar

e




ssG

ener

ally

, if

the

per

son

was

rec

eivi

ng p

ensi

on d

istr

ibut

ions

bef

ore

Mar

ch 3

1, 2

000,

the

dis

trib

utio

ns c

ontin

ue t

o b

e ex

emp

tfr

om U

.S.

tax.

ttIn

tere

st d

eter

min

ed w

ith r

efer

ence

to

the

pro

fits

of t

he is

suer

or

one

of it

s as

soci

ated

ent

erp

rises

is t

axed

at

15%

.

uuIn

tere

st r

ecei

ved

by

a fin

anci

al in

stitu

tion

is e

xem

pt.

vvD

ivid

end

s re

ceiv

ed b

y a

trus

t, c

omp

any,

or

othe

r or

gani

zatio

nop

erat

ed

excl

usiv

ely

to

adm

inis

ter

or

pro

vid

e p

ensi

on,

retir

emen

t, o

r ot

her

emp

loye

e b

enef

its g

ener

ally

are

exe

mp

t if

cert

ain

cond

ition

s ar

e m

et.

ww

Exe

mp

tion

doe

s no

t ap

ply

to

amou

nt p

aid

und

er,

or a

s p

art

of,

a co

ndui

t ar

rang

emen

t.

xxD

ivid

end

s re

ceiv

ed f

rom

an

80%

-ow

ned

cor

por

ate

sub

sid

iary

are

exem

pt

if ce

rtai

n co

nditi

ons

are

met

.

rrTh

e ra

te a

pp

lies

to d

ivid

end

s p

aid

by

a re

al e

stat

e in

vest

men

ttr

ust

(RE

IT) o

nly

if th

e b

enef

icia

l ow

ner

of t

he d

ivid

end

s is

(a) a

nin

div

idua

l ho

ldin

g le

ss t

han

a 10

% i

nter

est

in t

he R

EIT

, (b

) a

per

son

hold

ing

not

mor

e th

an 5

% o

f an

y cl

ass

of t

he R

EIT

’sst

ock

and

the

div

iden

ds

are

pai

d o

n st

ock

that

is p

ublic

ly tr

aded

,or

(c) a

per

son

hold

ing

not m

ore

than

a 1

0% in

tere

st in

the

RE

ITan

d t

he R

EIT

is d

iver

sifie

d.

acIn

tere

st i

s ex

emp

t if

(a)

pai

d t

o ce

rtai

n fin

anci

al i

nstit

utio

ns,

or(b

) p

aid

on

ind

ebte

dne

ss f

rom

the

sal

e on

cre

dit

of e

qui

pm

ent

or m

erch

and

ise.

yyTh

e ra

te is

5%

for

inte

rest

(a)

ben

efic

ially

ow

ned

by

a b

ank

orot

her

finan

cial

ins

titut

ion

(incl

udin

g an

ins

uran

ce c

omp

any)

or

(b)

pai

d d

ue t

o a

sale

on

cred

it of

any

ind

ustr

ial,

com

mer

cial

,or

sci

entif

ic e

qui

pm

ent,

or

of a

ny m

erch

and

ise

to a

n en

terp

rise.

zzA

mou

nts

pai

d t

o a

pen

sion

fun

d t

hat

are

not

der

ived

fro

m t

heca

rryi

ng o

n of

a b

usin

ess,

dire

ctly

or

ind

irect

ly,

by

the

fund

are

exem

pt.

Thi

s in

clud

es a

mou

nts

pai

d b

y a

RE

IT o

nly

if th

eco

nditi

ons

in f

ootn

ote

ab

are

met

. Fo

r S

wed

en,

to b

e en

title

dto

the

exe

mp

tion,

the

pen

sion

fun

d m

ust

not

sell

or m

ake

aco

ntra

ct t

o se

ll th

e ho

ldin

g fr

om w

hich

the

div

iden

d is

der

ived

with

in 2

mon

ths

of t

he d

ate

the

pen

sion

fun

d a

cqui

red

the

hold

ing.

abTh

e ra

te i

n co

lum

n 6

app

lies

to d

ivid

end

s p

aid

by

a re

gula

ted

inve

stm

ent c

omp

any

(RIC

) or r

eal e

stat

e in

vest

men

t tru

st (R

EIT

).H

owev

er,

that

rat

e ap

plie

s to

div

iden

ds

pai

d b

y a

RE

IT o

nly

ifth

e b

enef

icia

l ow

ner

of t

he d

ivid

end

s is

(a)

an

ind

ivid

ual

orp

ensi

on f

und

hol

din

g no

t m

ore

than

a 1

0% i

nter

est

in t

heR

EIT

,(b) a

per

son

hold

ing

not

mor

e th

an 5

% o

f an

y cl

ass

of t

heR

EIT

’s s

tock

and

the

div

iden

ds

are

pai

d o

n st

ock

that

is p

ublic

lytr

aded

, or

(c) a

per

son

hold

ing

not

mor

e th

an a

10%

inte

rest

inth

e R

EIT

and

the

RE

IT is

div

ersi

fied

. Div

iden

ds

pai

d to

a p

ensi

onfu

nd fr

om a

RIC

, or

a R

EIT

that

mee

ts th

e ab

ove

cond

ition

s, a

reex

emp

t. F

or S

wed

en,

the

pen

sion

fun

d m

ust

also

sat

isfy

the

req

uire

men

ts in

foo

tnot

e (z

z).




Tab

le 2

.C

om

pen

sati

on

for

Per

sona

l Ser

vice

s P

erfo

rmed

in U

nite

d S

tate

s E

xem

pt

fro

m U

.S.

Inco

me

Tax

Und

er I

nco

me

Tax

Trea

ties

Co

untr

y(1

)C

od

e1

(2)

Cat

ego

ry o

f P

erso

nal S

ervi

ces

Pur

po

se(3

)

Max

imum

Pre

senc

ein

U.S

.(4

)R

equi

red

Em

plo

yer

or

Pay

er(5

)

Max

imum

Am

oun

t o

fC

om

pen

sati

on

(6)

Tre

aty

Art

icle

Cit

atio

n(7

)

Aus

tral

ia

Bar

bad

os

Bel

giu

m (

old

tre

aty)

Bel

giu

m (

new

tre

aty)

16 20 17 20 19 16 20 17 20 19 15 16 20 17 18 19 16 20 19

Any

con

trac

tor

Any

for

eign

res

iden

t

No

limit

$10,

00025

14 17 15 17 20

Any

con

trac

tor

Any

for

eign

res

iden

t

Any

for

eign

res

iden

t

$10,

00025

No

limit

No

limit

Any

for

eign

con

trac

tor

Any

U.S

. co

ntra

ctor

Any

con

trac

tor

Any

for

eign

res

iden

tA

ny U

.S.

or f

orei

gn r

esid

ent

Any

for

eign

res

iden

t

No

limit

No

limit

$5,0

00$2

50 p

er d

ayor

$4,

000

p.a

.6

$5,0

00$2

50 p

er d

ayor

$4,

000

p.a

.6

14 14 17 15 17 20

Any

U.S

. or

for

eign

res

iden

t5

Any

con

trac

tor

Any

con

trac

tor

Bel

gian

res

iden

tU

.S.

educ

atio

nal i

nstit

utio

n

Any

for

eign

res

iden

t

Oth

er f

orei

gn o

r U

.S.

resi

den

tB

elgi

an r

esid

ent

Bel

gian

res

iden

t

U.S

. G

over

nmen

t or

its

cont

ract

or

No

limit

No

limit

No

limit

No

limit

No

limit

$3,0

00

$5,0

00

$5,0

00$2

,000

p.a

.

$10,

000

21(1

)14

(2)(a

)(b)

14(2

)(c)

15 20 21(1

)21

(2)(b

)21

(1)

21(2

)(a)

21(3

)

No

limit

Any

U.S

. or

for

eign

res

iden

t

No

limit

Any

for

eign

res

iden

tN

o lim

it

16 19(1

)(a)

Ind

epen

den

t p

erso

nal s

ervi

ces22

Pub

lic e

nter

tain

men

tD

epen

den

t p

erso

nal s

ervi

ces15

Pub

lic e

nter

tain

men

t15

Stu

dyi

ng a

nd t

rain

ing:

Rem

ittan

ces

or a

llow

ance

s10

Ind

epen

den

t p

erso

nal s

ervi

ces7,

22

Pub

lic e

nter

tain

men

t

Dep

end

ent

per

sona

l ser

vice

s7,15

Pub

lic e

nter

tain

men

tS

tud

ying

and

tra

inin

g:20

Rem

ittan

ces

or a

llow

ance

s10

Sch

olar

ship

or

fello

wsh

ip g

rant

Ind

epen

den

t p

erso

nal s

ervi

ces22

Pub

lic e

nter

tain

men

tD

epen

den

t p

erso

nal s

ervi

ces15

Teac

hing

4

Stu

dyi

ng a

nd t

rain

ing:

Rem

ittan

ces

or a

llow

ance

sC

omp

ensa

tion

dur

ing

trai

ning

Com

pens

atio

n w

hile

gai

ning

exp

erie

nce2

Com

pen

satio

n un

der

U.S

.G

over

nmen

t p

rogr

am

Ind

epen

den

t p

erso

nal s

ervi

ces54

Pub

lic e

nter

tain

men

t

Stu

dyi

ng a

nd t

rain

ing:

10

Rem

ittan

ces

or a

llow

ance

s

183

day

s18

3 d

ays

183

day

s18

3 d

ays

No

limit

89 d

ays

89 d

ays

No

limit

183

day

sN

o lim

it

No

limit

5 ye

ars

182

day

s90

day

s18

2 d

ays

2 ye

ars

5 ye

ars

12 c

onse

c. m

o.5

year

s12

con

sec.

mo.

1 ye

ar

No

limit

No

limit57

Aus

tria

16 20 17 20 19

Any

con

trac

tor

Any

con

trac

tor

Any

U.S

. or

for

eign

res

iden

t

14 17 17 20A

ny f

orei

gn r

esid

ent

No

limit

$20,

000

p.a

.25

No

limit

$20,

000

p.a

.25

No

limit

15

Ind

epen

den

t p

erso

nal s

ervi

ces22

Pub

lic e

nter

tain

men

tD

epen

den

t p

erso

nal s

ervi

ces15

Stu

dyi

ng a

nd t

rain

ing:

Rem

ittan

ces

or a

llow

ance

s10

No

limit

No

limit

183

day

sN

o lim

it

3 ye

ars11

Pub

lic e

nter

tain

men

tA

ny f

orei

gn r

esid

ent

17D

epen

den

t p

erso

nal s

ervi

ces15

,24

183

day

sA

ny f

orei

gn r

esid

ent

$20,

000

p.a

.2514

18Te

achi

ng4

2 ye

ars

Any

U.S

. ed

ucat

iona

l or

rese

arch

inst

itutio

n19

(2)

Ban

gla

des

h15 16 20 17 18 19

Any

U.S

. or

for

eign

res

iden

t5

Any

con

trac

tor

Any

con

trac

tor

Any

for

eign

res

iden

t

Any

U.S

. or

for

eign

res

iden

t

Any

for

eign

res

iden

t

No

limit

No

limit

No

limit

No

limit

No

limit

$10,

0003

0

$8,0

00 p

.a.

21(2

)15 18 16 21

(1)

21(2

)21

(2)

Sch

olar

ship

or

fello

wsh

ip g

rant

4

Ind

epen

den

t p

erso

nal s

ervi

ces22

Pub

lic e

nter

tain

men

tD

epen

den

t p

erso

nal s

ervi

ces15

Teac

hing

or

rese

arch

4

Stu

dyi

ng a

nd t

rain

ing:

4

Rem

ittan

ces

or a

llow

ance

sC

ompe

nsat

ion

durin

g st

udy

or t

rain

ing

2 ye

ars1

1

183

day

sN

o lim

it18

3 d

ays

2 ye

ars

20A

ny c

ontr

acto

r$1

0,00

030

18P

ublic

ent

erta

inm

ent

No

limit

2 ye

ars1

12

year

s11

Any

U.S

. or

for

eign

res

iden

t

Can

ada

16 17 19

Any

con

trac

tor

No

limit12

Any

U.S

. or

for

eign

res

iden

t$1

0,00

0A

ny f

orei

gn r

esid

ent15

No

limit12

Any

for

eign

res

iden

tN

o lim

it

XIV

XV

XV

XX

Ind

epen

den

t p

erso

nal s

ervi

ces22

Dep

end

ent

per

sona

l ser

vice

s

Stu

dyi

ng a

nd t

rain

ing:

Rem

ittan

ces

or a

llow

ance

s10

No

limit

No

limit

183

day

s

No

limit

20P

ublic

ent

erta

inm

ent

No

limit

Any

con

trac

tor

$15,

000

p.a

.25X

VI

20P

ublic

ent

erta

inm

ent3

No

limit

Any

U.S

. or

for

eign

res

iden

t$1

5,00

0 p

.a.25

XV

I

Com

pen

satio

n d

urin

g st

udy

or t

rain

ing

No

limit57

Any

U.S

. or

for

eign

res

iden

t$9

,000

p.a

.19

(1)(b

)




Tab

le 2

.(C

ontin

ued

)

Co

untr

y(1

)C

od

e1

(2)

Cat

ego

ry o

f P

erso

nal S

ervi

ces

Pur

po

se(3

)

Max

imum

Pre

senc

ein

U.S

.(4

)R

equi

red

Em

plo

yer

or

Pay

er(5

)

Max

imum

Am

oun

t o

fC

om

pen

sati

on

(6)

Tre

aty

Art

icle

Cit

atio

n(7

)

Co

mm

onw

ealt

h o

fIn

dep

end

ent

Sta

tes

Cyp

rus

Cze

ch R

epub

lic

15 16 17 18 19 15 16 20 17 20 19 15 16 20 17 20 18 19

Sch

olar

ship

or

fello

wsh

ip g

rant

Ind

epen

den

t p

erso

nal s

ervi

ces

Dep

end

ent

per

sona

l ser

vice

sTe

achi

ng4,

18

Stu

dyi

ng a

nd t

rain

ing:

Rem

ittan

ces

or a

llow

ance

sC

ompe

nsat

ion

whi

le g

aini

ng e

xper

ienc

eC

omp

ensa

tion

und

er U

.S.

Gov

ernm

ent

pro

gram

Sch

olar

ship

or

fello

wsh

ip g

rant

Ind

epen

den

t p

erso

nal s

ervi

ces22

Pub

lic e

nter

tain

men

t

Dep

end

ent

per

sona

l ser

vice

s15

Dire

ctor

s’ f

ees

Pub

lic e

nter

tain

men

t

Stu

dyi

ng a

nd t

rain

ing:

Rem

ittan

ces

or a

llow

ance

s

Com

pen

satio

n d

urin

g tr

aini

ng

Com

pens

atio

n w

hile

gai

ning

exp

erie

nce2

Com

pen

satio

n un

der

U.S

.G

over

nmen

t p

rogr

am

Sch

olar

ship

or

fello

wsh

ip g

rant

Ind

epen

den

t p

erso

nal s

ervi

ces22

Pub

lic e

nter

tain

men

tD

epen

den

t p

erso

nal s

ervi

ces7,

15

Pub

lic e

nter

tain

men

tTe

achi

ng4,

35

Stu

dyi

ng a

nd t

rain

ing:

4

Rem

ittan

ces

and

allo

wan

ces

Com

pen

satio

n d

urin

g tr

aini

ngC

ompe

nsat

ion

whi

le g

aini

ng e

xper

ienc

e2

Com

pen

satio

n un

der

U.S

.G

over

nmen

t p

rogr

am

183

day

s18

3 d

ays

5 ye

ars

2 ye

ars

1 ye

ar

Gen

eral

ly,

5ye

ars

182

day

s

12 c

onse

c. m

os.

5 ye

ars

1 ye

ar

No

limit

182

day

sN

o lim

itN

o lim

it

Gen

eral

ly,

5ye

ars

Gen

eral

ly,

5ye

ars

1 ye

ar

1 ye

ar

5 ye

ars

183

day

s18

3 d

ays

183

day

s18

3 d

ays

2 ye

ars

5 ye

ars

5 ye

ars

1 ye

ar

Any

U.S

. or

for

eign

res

iden

tA

ny U

.S.

or f

orei

gn c

ontr

acto

rA

ny U

.S.

or f

orei

gn r

esid

ent

Any

U.S

. ed

ucat

iona

l or

scie

ntifi

c in

stitu

tion

Any

U.S

. or

for

eign

res

iden

tC

.I.S

. re

sid

ent

Any

U.S

. or

for

eign

res

iden

t

Any

U.S

. or

for

eign

res

iden

t5

Any

con

trac

tor

U.S

. co

rpor

atio

n

Any

for

eign

res

iden

t

Cyp

rus

resi

den

t

U.S

. G

over

nmen

t or

its

cont

ract

or

Any

con

trac

tor

Any

for

eign

res

iden

t

Any

U.S

. or

for

eign

res

iden

t

Any

U.S

. or

for

eign

res

iden

t

Any

U.S

. or

for

eign

res

iden

t5

Any

con

trac

tor

Any

con

trac

tor

Any

for

eign

res

iden

tA

ny f

orei

gn r

esid

ent

Any

U.S

. ed

ucat

iona

l or

rese

arch

inst

itutio

n

Any

for

eign

res

iden

tA

ny U

.S.

or f

orei

gn r

esid

ent

Cze

ch r

esid

ent

U.S

. G

over

nmen

t

Lim

ited

19

No

limit

No

limit

No

limit

Lim

ited

19

No

limit19

No

limit

No

limit

No

limit

$500

per

day

or

$5,0

00 p

.a.6

No

limit

No

limit21

$500

per

day

or

$5,0

00 p

.a.6

No

limit

$2,0

00 p

.a.

$7,5

00

$10,

000

$20,

000

p.a

.30

$5,0

00 p

.a.

$8,0

00

No

limit

No

limit

$20,

000

p.a

.30N

o lim

it

No

limit

No

limit

$10,

000

VI(1

)V

I(2)

VI(2

)V

I(1)

VI(1

)V

I(1)

VI(1

)

21(1

)17 19

(1)

18 20 19(1

)

21(1

)

21(1

)21

(2)

21(3

)

21(1

)14 18 15 18 21

(5)

21(1

)21

(1)

21(2

)

21(3

)

Den

mar

k16 17 19

Ind

epen

den

t p

erso

nal s

ervi

ces22

Dep

end

ent

per

sona

l ser

vice

s15

Stu

dyi

ng a

nd t

rain

ing:

4

Rem

ittan

ces

or a

llow

ance

s10

183

day

s

3 ye

ars11

Any

con

trac

tor

Any

con

trac

tor

Any

for

eign

res

iden

tA

ny f

orei

gn r

esid

ent

Any

for

eign

res

iden

t

$20,

000

p.a

.25

$20,

000

p.a

.25N

o lim

it

No

limit

No

limit

14 17 15 17 20

Pub

lic e

nter

tain

men

t

Pub

lic e

nter

tain

men

t

20 20

No

limit

No

limit

183

day

s

Chi

na,

Peo

ple

’s R

ep.

of

15 16 20 17 20 18 19

Any

U.S

. or

for

eign

res

iden

t5N

o lim

itA

ny c

ontr

acto

rN

o lim

itA

ny c

ontr

acto

rN

o lim

itA

ny f

orei

gn r

esid

ent

No

limit

Any

U.S

. or

for

eign

res

iden

tN

o lim

itU

.S.

educ

atio

nal o

r re

sear

ch in

stitu

teN

o lim

it

Any

for

eign

res

iden

tN

o lim

it

Any

U.S

. or

for

eign

res

iden

t$5

,000

p.a

.

20(b

)13 16 14 16 19 20

(a)

20(c

)

Sch

olar

ship

or

fello

wsh

ip g

rant

Ind

epen

den

t p

erso

nal s

ervi

ces22

Pub

lic e

nter

tain

men

t29

Dep

end

ent

per

sona

l ser

vice

s7,15

Pub

lic e

nter

tain

men

t29

Teac

hing

4

Stu

dyi

ng a

nd t

rain

ing:

Rem

ittan

ces

or a

llow

ance

sC

omp

ensa

tion

dur

ing

trai

ning

or

whi

lega

inin

g ex

per

ienc

e

No

spec

ific

limit

183

day

sN

o lim

it18

3 d

ays

No

limit

3 ye

ars

No

spec

ific

limit

No

spec

ific

limit




Tab

le 2

.(C

ontin

ued

)

Co

untr

y(1

)C

od

e1

(2)

Cat

ego

ry o

f P

erso

nal S

ervi

ces

Pur

po

se(3

)

Max

imum

Pre

senc

ein

U.S

.(4

)R

equi

red

Em

plo

yer

or

Pay

er(5

)

Max

imum

Am

oun

t o

fC

om

pen

sati

on

(6)

Tre

aty

Art

icle

Cit

atio

n(7

)E

gyp

t

Finl

and

Fran

ce

Ger

man

y

15 16 20 17 20 18 19 16 20 17 20 19 15 16 20 17 20 18 19 15 16 20 17 20 18 19

Sch

olar

ship

or

fello

wsh

ip g

rant

Ind

epen

den

t p

erso

nal s

ervi

ces

Pub

lic e

nter

tain

men

tD

epen

den

t p

erso

nal s

ervi

ces14

,15

Pub

lic e

nter

tain

men

tTe

achi

ng4

Stu

dyi

ng a

nd t

rain

ing:

Rem

ittan

ces

or a

llow

ance

sC

omp

ensa

tion

dur

ing

trai

ning

Com

pens

atio

n w

hile

gai

ning

exp

erie

nce2

Com

pen

satio

n un

der

U.S

.G

over

nmen

t p

rogr

am

Gen

eral

ly, 5

yea

rs89

day

sN

o lim

it89

day

sN

o lim

it2

year

s

Gen

eral

ly, 5

yea

rsG

ener

ally

, 5 y

ears

12 c

onse

c. m

os.

1 ye

ar

Any

U.S

. or

for

eign

res

iden

t5

Any

con

trac

tor

Any

con

trac

tor

Egy

ptia

n re

sid

ent

Any

U.S

. or

for

eign

res

iden

tU

.S.

educ

atio

nal i

nstit

utio

n

Any

for

eign

res

iden

tU

.S.

or a

ny f

orei

gn r

esid

ent

Egy

ptia

n re

sid

ent

U.S

. G

over

nmen

t or

its

cont

ract

or

No

limit

No

limit

$400

per

day

No

limit

$400

per

day

No

limit

No

limit

$3,0

00 p

.a.

$7,5

00

$10,

000

23(1

)15 17 16 17 22 23

(1)

23(1

)23

(2)

23(3

)

Ind

epen

den

t p

erso

nal s

ervi

ces22

Pub

lic e

nter

tain

men

tD

epen

den

t p

erso

nal s

ervi

ces15

Pub

lic e

nter

tain

men

tS

tud

ying

and

tra

inin

g:R

emitt

ance

s or

allo

wan

ces10

No

limit

No

limit

183

day

sN

o lim

it

No

limit

Any

con

trac

tor

Any

con

trac

tor

Any

for

eign

res

iden

tA

ny U

.S.

or f

orei

gn r

esid

ent

Any

for

eign

res

iden

t

No

limit

No

limit

No

limit

$20,

000

p.a

.25

$20,

000

p.a

.25

14 17 15 17 20

Sch

olar

ship

or

fello

wsh

ip g

rant

Ind

epen

den

t p

erso

nal s

ervi

ces22

Pub

lic e

nter

tain

men

tD

epen

den

t p

erso

nal s

ervi

ces7,

15

Pub

lic e

nter

tain

men

tTe

achi

ng4,

39

Stu

dyi

ng a

nd t

rain

ing:

4

Rem

ittan

ces

or a

llow

ance

sC

omp

ensa

tion

dur

ing

stud

y or

trai

ning

Com

pens

atio

n w

hile

gai

ning

exp

erie

nce2

5 ye

ars40

No

limit

No

limit

183

day

sN

o lim

it2

year

s40

5 ye

ars40

12 c

onse

c. m

os.

5 ye

ars

12 c

onse

c. m

os.

Any

U.S

. or

for

eign

res

iden

t5

Any

con

trac

tor

Any

con

trac

tor

Any

for

eign

res

iden

tA

ny U

.S.

or f

orei

gn r

esid

ent

U.S

. ed

ucat

iona

l or

rese

arch

inst

itutio

n

Any

for

eign

res

iden

t

Fren

ch r

esid

ent

Oth

er f

orei

gn o

r U

.S.

resi

den

tFr

ench

res

iden

t

No

limit

No

limit

$10,

00030

No

limit

$10,

00030

No

limit

No

limit

$8,0

00$5

,000

p.a

.$8

,000

21(1

)14 17 15 17 20 21

(1)

21(2

)21

(1)

21(2

)

Sch

olar

ship

or

fello

wsh

ip g

rant

Ind

epen

den

t p

erso

nal s

ervi

ces22

Pub

lic e

nter

tain

men

t22

Dep

end

ent

per

sona

l ser

vice

s15,2

4

Pub

lic e

nter

tain

men

t15

Teac

hing

4

Stu

dyi

ng a

nd t

rain

ing:

Rem

ittan

ces

or a

llow

ance

s10

Com

pens

atio

n du

ring

stud

y or

trai

ning

Com

pens

atio

n w

hile

gai

ning

exp

erie

nce2

No

limit

No

limit

No

limit

183

day

s18

3 d

ays

2 ye

ars

No

limit

4 ye

ars

1 ye

ar

Any

U.S

. or

for

eign

res

iden

t5

Any

con

trac

tor

Any

con

trac

tor

Any

for

eign

res

iden

tA

ny f

orei

gn r

esid

ent

U.S

. ed

ucat

iona

l or

rese

arch

inst

itutio

n

Any

for

eign

res

iden

tA

ny U

.S.

or f

orei

gn r

esid

ent

Any

Ger

man

ent

erp

rise

or f

orei

gnor

gani

zatio

n or

inst

itutio

n

No

limit

20(3

)N

o lim

it14

$20,

000

p.a

.3017

No

limit

15$2

0,00

0 p

.a.30

17N

o lim

it20

(1)

No

limit

20(2

)$5

,000

p.a

.20

(4)

$10,

00028

20(5

)

Est

oni

a15 17 19

No

limit

No

limit

No

limit

Sch

olar

ship

or

fello

wsh

ip g

rant

s4

Dep

end

ent

per

sona

l ser

vice

s7,15

Stu

dyi

ng a

nd t

rain

ing:

4

Rem

ittan

ces

or a

llow

ance

s

5 ye

ars

183

day

s

5 ye

ars

20P

ublic

ent

erta

inm

ent

20P

ublic

ent

erta

inm

ent

No

limit

No

limit

Any

for

eign

res

iden

tA

ny c

ontr

acto

r

Any

U.S

. or

for

eign

res

iden

t

Any

for

eign

res

iden

t

$20,

00030

$20,

00030

20(1

)

17 15 17 20(1

)

16N

o lim

itIn

dep

end

ent

per

sona

l ser

vice

s22A

ny c

ontr

acto

r14

Com

pen

satio

n d

urin

g tr

aini

ng

Com

pen

satio

n w

hile

gai

ning

exp

erie

nce2

Com

pen

satio

n un

der

U.S

.G

over

nmen

t p

rogr

am

183

day

s

1 ye

ar

12 c

onse

c. m

os.

12 c

onse

c. m

os.

5 ye

ars

Any

U.S

. or

for

eign

res

iden

t5

Est

onia

n re

sid

ent

Est

onia

n re

sid

ent

Oth

er f

orei

gn o

r U

.S.

resi

den

t

U.S

. G

over

nmen

t or

its

cont

ract

or

$8,0

00$5

,000

p.a

.

$8,0

00

$10,

000

20(2

)20

(1)

20(2

)

20(3

)




Tab

le 2

.(C

ontin

ued

)

Co

untr

y(1

)C

od

e1

(2)

Cat

ego

ry o

f P

erso

nal S

ervi

ces

Pur

po

se(3

)

Max

imum

Pre

senc

ein

U.S

.(4

)R

equi

red

Em

plo

yer

or

Pay

er(5

)

Max

imum

Am

oun

t o

fC

om

pen

sati

on

(6)

Tre

aty

Art

icle

Cit

atio

n(7

)

Icel

and

Ind

ia

Ind

one

sia

15 16 20 17 18 19 16 20 17 20 18 19 15 16 20 17 20 18 19

Sch

olar

ship

and

fel

low

ship

gra

ntIn

dep

end

ent

per

sona

l ser

vice

s22

Pub

lic e

nter

tain

men

tD

epen

den

t p

erso

nal s

ervi

ces15

Teac

hing

4

Stu

dyi

ng a

nd t

rain

ing:

Rem

ittan

ces

or a

llow

ance

sC

omp

ensa

tion

dur

ing

trai

ning

Com

pens

atio

n w

hile

gai

ning

exp

erie

nce2

Com

pen

satio

n un

der

U.S

.G

over

nmen

t p

rogr

am

5 ye

ars

182

day

s90

day

s18

2 d

ays

2 ye

ars

5 ye

ars

5 ye

ars

12 c

onse

c. m

o.

1 ye

ar

Any

U.S

. or

for

eign

res

iden

t5

Any

con

trac

tor

Any

con

trac

tor

Icel

and

res

iden

t16

U.S

. ed

ucat

iona

l ins

titut

ion

Any

for

eign

res

iden

tU

.S.

or a

ny f

orei

gn r

esid

ent

Icel

and

res

iden

t

U.S

. G

over

nmen

t or

its

cont

ract

or

No

limit

No

limit

$100

per

day

No

limit

No

limit

No

limit

$2,0

00 p

.a.

$5,0

00

$10,

000

22(1

)18 18 19 21 22

(1)

22(1

)22

(2)

22(3

)

Ind

epen

den

t p

erso

nal s

ervi

ces7,

22

Pub

lic e

nter

tain

men

t22

Dep

end

ent

per

sona

l ser

vice

s7,15

Pub

lic e

nter

tain

men

t15

Teac

hing

4

Stu

dyi

ng a

nd t

rain

ing:

Rem

ittan

ces

or a

llow

ance

s

89 d

ays

89 d

ays

183

day

s18

3 d

ays

2 ye

ars

No

limit

Any

con

trac

tor

Any

con

trac

tor

Any

for

eign

res

iden

tA

ny f

orei

gn r

esid

ent

U.S

. ed

ucat

iona

l ins

titut

ion

Any

for

eign

res

iden

t27

No

limit

$1,5

00 p

.a.26

No

limit

No

limit

$1,5

00 p

.a.26

No

limit

15 18 16 18 22 21(1

)

Sch

olar

ship

and

fel

low

ship

gra

nt5

year

sA

ny U

.S.

or f

orei

gn r

esid

ent5

Ind

epen

den

t p

erso

nal s

ervi

ces22

119

day

sA

ny c

ontr

acto

rP

ublic

ent

erta

inm

ent43

No

limit

Any

con

trac

tor

Dep

end

ent

per

sona

l ser

vice

s1511

9 d

ays

Any

for

eign

res

iden

tP

ublic

ent

erta

inm

ent43

No

limit

Any

U.S

. or

for

eign

res

iden

tTe

achi

ng4,

392

year

sU

.S.

educ

atio

nal i

nstit

utio

nS

tud

ying

and

tra

inin

g:R

emitt

ance

s or

allo

wan

ces

5 ye

ars

Any

for

eign

res

iden

tC

omp

ensa

tion

dur

ing

trai

ning

Com

pens

atio

n w

hile

gai

ning

exp

erie

nce

5 ye

ars

Any

for

eign

or

U.S

. re

sid

ent

12 c

onse

c. m

o.A

ny U

.S.

or f

orei

gn r

esid

ent

No

limit

No

limit

$2,0

00 p

.a.25

No

limit

$2,0

00 p

.a.25

No

limit

No

limit

$2,0

00 p

.a.

$7,5

00

19(1

)15 17 16 17 20 19

(1)

19(1

)19

(2)

Irel

and

16 17 19

Ind

epen

den

t p

erso

nal s

ervi

ces22

Dep

end

ent

per

sona

l ser

vice

s15,2

3

Stu

dyi

ng a

nd t

rain

ing:

Rem

ittan

ces

or a

llow

ance

s10

No

limit

183

day

sN

o lim

it

1 ye

ar11

Any

con

trac

tor

Any

for

eign

res

iden

tA

ny U

.S.

or f

orei

gn r

esid

ent

Any

for

eign

res

iden

t

No

limit

14 15 17 20

No

limit

$20,

000

p.a

.25

No

limit

20P

ublic

ent

erta

inm

ent

20P

ublic

ent

erta

inm

ent

No

limit

Any

con

trac

tor

$20,

000

p.a

.2517

Ger

man

y (a

s m

od

ified

)

Hun

gar

y

15 17 18 19 16 17 18 19

Sch

olar

ship

or

fello

wsh

ip g

rant

No

limit

183

day

sN

o lim

it2

year

s

No

limit

Dep

end

ent

per

sona

l ser

vice

s15,2

4

Pub

lic e

nter

tain

men

t

Stu

dyi

ng a

nd t

rain

ing:

10

Rem

ittan

ces

or a

llow

ance

s

Any

U.S

. or

for

eign

res

iden

t5

Any

for

eign

res

iden

t

U.S

. ed

ucat

iona

l or

rese

arch

inst

itutio

nA

ny U

.S.

or f

orei

gn r

esid

ent

Any

for

eign

res

iden

t

No

limit

No

limit

No

limit

No

limit

$20,

000

p.a

.30

20(3

)

15 17 20(1

)

20(2

)

Ind

epen

den

t p

erso

nal s

ervi

ces22

Dep

end

ent

per

sona

l ser

vice

s15

Teac

hing

4

Stu

dyi

ng a

nd t

rain

ing:

20

Rem

ittan

ces

or a

llow

ance

s10

183

day

s

2 ye

ars

No

limit

183

day

sA

ny c

ontr

acto

rA

ny f

orei

gn r

esid

ent

U.S

. ed

ucat

iona

l ins

titut

ion

Any

for

eign

res

iden

t

No

limit

13N

o lim

it14

No

limit

17

No

limit

18(1

)

Gre

ece

16 17 18 19

Ind

epen

den

t p

erso

nal s

ervi

ces

183

day

s18

3 d

ays

183

day

s18

3 d

ays

3 ye

ars

No

limit

Dep

end

ent

per

sona

l ser

vice

s

Teac

hing

Stu

dyi

ng a

nd t

rain

ing:

Rem

ittan

ces

or a

llow

ance

s

Gre

ek r

esid

ent

cont

ract

or

Any

for

eign

res

iden

t

U.S

. ed

ucat

iona

l ins

titut

ion

Oth

er f

orei

gn o

r U

.S.

resi

den

tG

reek

res

iden

tO

ther

for

eign

or

U.S

. re

sid

ent

cont

ract

orN

o lim

it$1

0,00

0N

o lim

it

No

limit

No

limit

$10,

000

X X X X XII

XIII

Com

pens

atio

n w

hile

gai

ning

exp

erie

nce2

Com

pen

satio

n d

urin

g st

udy

or t

rain

ing

Ind

epen

den

t p

erso

nal s

ervi

ces54

Teac

hing

4,56

4 ye

ars

1 ye

arA

ny U

.S.

or f

orei

gn r

esid

ent

Any

for

eign

res

iden

t$9

,000

p.a

.$1

0,00

02820

(5)

20(4

)

16 20




Tab

le 2

.(C

ontin

ued

)

Co

untr

y(1

)C

od

e1

(2)

Cat

ego

ry o

f P

erso

nal S

ervi

ces

Pur

po

se(3

)

Max

imum

Pre

senc

ein

U.S

.(4

)R

equi

red

Em

plo

yer

or

Pay

er(5

)

Max

imum

Am

oun

t o

fC

om

pen

sati

on

(6)

Tre

aty

Art

icle

Cit

atio

n(7

)

Ital

y

Jam

aica

Jap

an

16 20 17 20 18 19 16 20 17 20 18 19 16 20 17 20

Ind

epen

den

t p

erso

nal s

ervi

ces7,

22

Pub

lic e

nter

tain

men

tD

epen

den

t p

erso

nal s

ervi

ces7,

15

Pub

lic e

nter

tain

men

tTe

achi

ng4

Stu

dyi

ng a

nd t

rain

ing:

Rem

ittan

ces

or a

llow

ance

s

183

day

s90

day

s18

3 d

ays

90 d

ays

2 ye

ars

No

limit

Any

con

trac

tor

Any

con

trac

tor

Any

for

eign

res

iden

tA

ny U

.S.

or f

orei

gn r

esid

ent

U.S

. ed

ucat

iona

l ins

titut

ion

Any

for

eign

res

iden

t

No

limit

$12,

000

p.a

.25

No

limit

$12,

000

p.a

.25

No

limit

No

limit

14 17(1

)15 17

(1)

20 21

Ind

epen

den

t p

erso

nal s

ervi

ces22

Pub

lic e

nter

tain

men

t

Dep

end

ent

per

sona

l ser

vice

s15

Pub

lic e

nter

tain

men

t

Dire

ctor

s’ f

ees

Teac

hing

4,39

Stu

dyi

ng a

nd t

rain

ing:

20

Rem

ittan

ces

or a

llow

ance

s10

Com

pen

satio

n d

urin

g st

udy

Com

pens

atio

n w

hile

gai

ning

exp

erie

nce2

89 d

ays

89 d

ays

No

limit

183

day

sN

o lim

it

No

limit

2 ye

ars

No

limit

12 c

onse

c. m

o.12

con

sec.

mo.

Any

for

eign

con

trac

tor

Any

U.S

. co

ntra

ctor

Any

con

trac

tor

Any

for

eign

res

iden

tA

ny U

.S.

or f

orei

gn r

esid

ent

U.S

. re

sid

ent

U.S

. ed

ucat

iona

l ins

titut

ion

Any

for

eign

res

iden

tJa

mai

can

resi

den

tJa

mai

can

resi

den

t

No

limit

$5,0

00 p

.a.

$400

per

day

or $

5,00

0 p

.a.6

$5,0

00 p

.a.

$400

per

day

or $

5,00

0 p

.a.6

$400

per

day

6

No

limit

No

limit

$7,5

00 p

.a.

$7,5

00 p

.a.

14 14 18 15 18 16 22 21(1

)21

(2)

21(2

)In

dep

end

ent

per

sona

l se

rvic

e 7,

54

Pub

lic e

nter

tain

men

tN

o lim

itA

ny c

ontr

acto

rD

epen

den

t p

erso

nal s

ervi

ces7,

1518

3 d

ays

Any

for

eign

res

iden

tP

ublic

ent

erta

inm

ent

Teac

hing

or

rese

arch

42

year

sA

ny U

.S.

educ

atio

nal i

nstit

utio

n

$10,

000

p.a

. 2516

No

limit

14

No

limit

20

Isra

el15 16 20 17 20 18 19

Sch

olar

ship

and

fel

low

ship

gra

ntIn

dep

end

ent

per

sona

l ser

vice

sP

ublic

ent

erta

inm

ent

Dep

end

ent

per

sona

l ser

vice

s14,1

5

Pub

lic e

nter

tain

men

tTe

achi

ng4,

37

Stu

dyi

ng a

nd t

rain

ing:

Rem

ittan

ces

or a

llow

ance

sC

omp

ensa

tion

dur

ing

stud

y or

trai

ning

Com

pens

atio

n w

hile

gai

ning

exp

erie

nce2

Com

pen

satio

n un

der

U.S

.G

over

nmen

t p

rogr

am

5 ye

ars

Any

U.S

. or

for

eign

res

iden

t5

182

day

sA

ny c

ontr

acto

rN

o lim

itA

ny c

ontr

acto

r18

2 d

ays

Isra

eli r

esid

ent16

No

limit

Any

U.S

. or

for

eign

res

iden

t2

year

sU

.S.

educ

atio

nal i

nstit

utio

n

5 ye

ars

Any

for

eign

res

iden

t

5 ye

ars

Any

U.S

. or

for

eign

res

iden

t12

con

sec.

mo.

Isra

eli r

esid

ent

1 ye

arU

.S.

Gov

ernm

ent

or it

s co

ntra

ctor

No

limit

No

limit

No

limit

No

limit

No

limit

$3,0

00 p

.a.

$7,5

00

$10,

000

$400

per

day

52

$400

per

day

52

24(1

)16 18 17 18 23 24

(1)

24(1

)24

(2)

24(3

)

Kaz

akhs

tan

15 16 17 19

Sch

olar

ship

or

fello

wsh

ip g

rant

445

year

s31A

ny U

.S.

or f

orei

gn r

esid

ent5

Ind

epen

den

t p

erso

nal s

ervi

ces22

183

day

sA

ny c

ontr

acto

rD

epen

den

t p

erso

nal s

ervi

ces7,

1518

3 d

ays

Any

for

eign

res

iden

tS

tud

ying

and

tra

inin

g:4

Rem

ittan

ces

or a

llow

ance

s5

year

sA

ny f

orei

gn r

esid

ent

No

limit

19N

o lim

it14

No

limit

15

No

limit

19

18 19S

tud

ying

and

tra

inin

g:R

emitt

ance

s or

allo

wan

ces

No

limit

1 ye

ar 11

Any

U.S

. or

for

eign

res

iden

t

Any

for

eign

res

iden

t

$10,

000

p.a

. 25

No

limit

16 19

Ko

rea,

Rep

. o

f15 16 17 18 19

Sch

olar

ship

or

fello

wsh

ip g

rant

5 ye

ars

Any

U.S

. or

for

eign

res

iden

t5

Ind

epen

den

t p

erso

nal s

ervi

ces22

182

day

sA

ny c

ontr

acto

rD

epen

den

t p

erso

nal s

ervi

ces15

182

day

sK

orea

n re

sid

ent16

Teac

hing

42

year

sU

.S.

educ

atio

nal i

nstit

utio

nS

tud

ying

and

tra

inin

g:R

emitt

ance

s or

allo

wan

ces

5 ye

ars

Any

for

eign

res

iden

tC

omp

ensa

tion

dur

ing

trai

ning

Com

pens

atio

n w

hile

gai

ning

exp

erie

nce2

Com

pen

satio

n un

der

U.S

.G

over

nmen

t p

rogr

am

5 ye

ars

Any

for

eign

or

U.S

. re

sid

ent

1 ye

arK

orea

n re

sid

ent

1 ye

arU

.S.

Gov

ernm

ent

or it

s co

ntra

ctor

No

limit

21(1

)$3

,000

p.a

.18

$3,0

00 p

.a.

19N

o lim

it20

No

limit

21(1

)$2

,000

p.a

.21

(1)

$5,0

0021

(2)

$10,

000

21(3

)




Tab

le 2

.(C

ontin

ued

)

Co

untr

y(1

)C

od

e1

(2)

Cat

ego

ry o

f P

erso

nal S

ervi

ces

Pur

po

se(3

)

Max

imum

Pre

senc

ein

U.S

.(4

)R

equi

red

Em

plo

yer

or

Pay

er(5

)

Max

imum

Am

oun

t o

fC

om

pen

sati

on

(6)

Tre

aty

Art

icle

Cit

atio

n(7

)

Luxe

mb

our

g16 20 17 20 19

Ind

epen

den

t p

erso

nal s

ervi

ces22

Pub

lic e

nter

tain

men

tD

epen

den

t p

erso

nal s

ervi

ces15

,24

Pub

lic e

nter

tain

men

t

Stu

dyi

ng a

nd t

rain

ing:

Rem

ittan

ces

or a

llow

ance

s10

15 18 16 18 21(1

)

No

limit

$10,

00025

No

limit

$10,

00025

No

limit

Any

con

trac

tor

Any

con

trac

tor

Any

for

eign

res

iden

tA

ny f

orei

gn r

esid

ent

Any

U.S

. or

for

eign

res

iden

t

No

limit

183

day

sN

o lim

it

2 ye

ars11

Latv

ia15 17 19

No

limit

No

limit

No

limit

Sch

olar

ship

or

fello

wsh

ip g

rant

s4

Dep

end

ent

per

sona

l ser

vice

s7,15

Stu

dyi

ng a

nd t

rain

ing:

Rem

ittan

ces

or a

llow

ance

s

5 ye

ars

183

day

s

5 ye

ars

20P

ublic

ent

erta

inm

ent

20P

ublic

ent

erta

inm

ent

No

limit

No

limit

Any

for

eign

res

iden

tA

ny c

ontr

acto

r

Any

U.S

. or

for

eign

res

iden

t

Any

for

eign

res

iden

t

$20,

00030

$20,

00030

20(1

)

17 15 17 20(1

)

16N

o lim

itIn

dep

end

ent

per

sona

l ser

vice

s22A

ny c

ontr

acto

r14

Com

pen

satio

n d

urin

g tr

aini

ng

Com

pen

satio

n w

hile

gai

ning

exp

erie

nce2

Com

pen

satio

n un

der

U.S

.G

over

nmen

t p

rogr

am

183

day

s

1 ye

ar

12 c

onse

c. m

os.

12 c

onse

c. m

os.

5 ye

ars

Any

U.S

. or

for

eign

res

iden

t5

Latv

ian

resi

den

t

Latv

ian

resi

den

t

Oth

er f

orei

gn o

r U

.S.

resi

den

t

U.S

. G

over

nmen

t or

its

cont

ract

or

$8,0

00$5

,000

p.a

.

$8,0

00

$10,

000

20(2

)20

(1)

20(2

)

20(3

)

Lith

uani

a15 17 19

No

limit

No

limit

No

limit

Sch

olar

ship

or

fello

wsh

ip g

rant

s4

Dep

end

ent

per

sona

l ser

vice

s7,15

Stu

dyi

ng a

nd t

rain

ing:

Rem

ittan

ces

or a

llow

ance

s

5 ye

ars

183

day

s

5 ye

ars

20P

ublic

ent

erta

inm

ent

20P

ublic

ent

erta

inm

ent

No

limit

No

limit

Any

for

eign

res

iden

tA

ny c

ontr

acto

r

Any

U.S

. or

for

eign

res

iden

t

Any

for

eign

res

iden

t

$20,

00030

$20,

00030

20(1

)

17 15 17 20(1

)

16N

o lim

itIn

dep

end

ent

per

sona

l ser

vice

s22A

ny c

ontr

acto

r14

Com

pen

satio

n d

urin

g tr

aini

ng

Com

pen

satio

n w

hile

gai

ning

exp

erie

nce2

Com

pen

satio

n un

der

U.S

.G

over

nmen

t p

rogr

am

183

day

s

1 ye

ar

12 c

onse

c. m

os.

12 c

onse

c. m

os.

5 ye

ars

Any

U.S

. or

for

eign

res

iden

t5

Lith

uani

an r

esid

ent

Lith

uani

an r

esid

ent

Oth

er f

orei

gn o

r U

.S.

resi

den

t

U.S

. G

over

nmen

t or

its

cont

ract

or

$8,0

00$5

,000

p.a

.

$8,0

00

$10,

000

20(2

)20

(1)

20(2

)

20(3

)

Teac

hing

or

rese

arch

818

2 ye

ars

No

limit

Any

U.S

. or

for

eign

res

iden

tN

o lim

it21

(2)

Mo

rocc

o15 16 17 19

Sch

olar

ship

or

fello

wsh

ip g

rant

Ind

epen

den

t p

erso

nal s

ervi

ces12

,22

Dep

end

ent

per

sona

l ser

vice

s12,1

5

Stu

dyi

ng a

nd t

rain

ing:

Rem

ittan

ces

or a

llow

ance

sC

omp

ensa

tion

dur

ing

trai

ning

18 14 15 18 18

No

limit

$5,0

00N

o lim

it

No

limit

$2,0

00 p

.a.

Any

U.S

. or

for

eign

res

iden

t5

Any

con

trac

tor

Mor

occa

n re

sid

ent16

Any

for

eign

res

iden

tU

.S.

or a

ny f

orei

gn r

esid

ent

5 ye

ars

182

day

s18

2 d

ays

5 ye

ars

5 ye

ars

Mex

ico

16 20 17 20 19

Ind

epen

den

t p

erso

nal s

ervi

ces22

Pub

lic e

nter

tain

men

tD

epen

den

t p

erso

nal s

ervi

ces15

,23

Pub

lic e

nter

tain

men

tS

tud

ying

and

tra

inin

g:R

emitt

ance

s or

allo

wan

ces

14 18 15 18 21

No

limit

$3,0

00 p

.a.30

No

limit

$3,0

00 p

.a.30

No

limit

Any

con

trac

tor

Any

con

trac

tor

Any

for

eign

res

iden

tA

ny U

.S.

or f

orei

gn r

esid

ent

Any

for

eign

res

iden

t

183

day

sN

o lim

it18

3 d

ays

No

limit

No

limit

Net

herl

and

s15 16 20 17 20 18 19

Sch

olar

ship

or

fello

wsh

ip g

rant

33

Ind

epen

den

t p

erso

nal s

ervi

ces22

Pub

lic e

nter

tain

men

tD

epen

den

t p

erso

nal s

ervi

ces15

,23

Pub

lic e

nter

tain

men

tTe

achi

ng4,

34

Stu

dyi

ng a

nd t

rain

ing:

33

Rem

ittan

ces

or a

llow

ance

sC

ompe

nsat

ion

whi

le g

aini

ng e

xper

ienc

eC

omp

ensa

tion

whi

le r

ecip

ient

of

scho

lars

hip

or

fello

wsh

ip g

rant

22(2

)15 18 16 18 21

(1)

22(1

)22

(1)

22(2

)

No

limit

No

limit

$10,

000

p.a

.25

No

limit

$10,

000

p.a

.25

No

limit

No

limit

$2,0

00 p

.a.

$2,0

00 p

.a.36

Any

U.S

. or

for

eign

res

iden

t5

Any

con

trac

tor

Any

con

trac

tor

Any

for

eign

res

iden

tA

ny f

orei

gn r

esid

ent

U.S

. ed

ucat

iona

l ins

titut

ion

Any

for

eign

res

iden

tA

ny U

.S.

or f

orei

gn r

esid

ent

Any

U.S

. or

for

eign

res

iden

t

3 ye

ars

No

limit

No

limit

183

day

s18

3 d

ays

2 ye

ars

No

limit

No

limit

3 ye

ars




Tab

le 2

.(C

ontin

ued

)

Co

untr

y(1

)C

od

e1

(2)

Cat

ego

ry o

f P

erso

nal S

ervi

ces

Pur

po

se(3

)

Max

imum

Pre

senc

ein

U.S

.(4

)R

equi

red

Em

plo

yer

or

Pay

er(5

)

Max

imum

Am

oun

t o

fC

om

pen

sati

on

(6)

Tre

aty

Art

icle

Cit

atio

n(7

)

Pak

ista

n15 16 17 18 19

XIII

(1)

XI

XI

XII

XIII

(1)

XIII

(1)

XIII

(2)

XIII

(3)

Sch

olar

ship

or

fello

wsh

ip g

rant

Ind

epen

den

t p

erso

nal s

ervi

ces14

Dep

end

ent

per

sona

l ser

vice

s14

Teac

hing

Stu

dyi

ng a

nd t

rain

ing:

Rem

ittan

ces

or a

llow

ance

sC

omp

ensa

tion

dur

ing

trai

ning

Com

pens

atio

n w

hile

gai

ning

exp

erie

nce2

Com

pen

satio

n w

hile

und

er U

.S.

Gov

ernm

ent

pro

gram

No

limit

183

day

s18

3 d

ays

2 ye

ars

No

limit

No

limit

1 ye

ar

No

limit

Pak

ista

ni n

onp

rofit

org

aniz

atio

nP

akis

tani

res

iden

t co

ntra

ctor

Pak

ista

ni r

esid

ent

U.S

. ed

ucat

iona

l ins

titut

ion

Any

for

eign

res

iden

tU

.S.

or a

ny f

orei

gn r

esid

ent

Pak

ista

ni r

esid

ent

U.S

. G

over

nmen

t, it

s co

ntra

ctor

, or

any

fore

ign

resi

den

t em

plo

yer

No

limit

No

limit

No

limit

No

limit

No

limit

$5,0

00 p

.a.

$6,0

00

$10,

000

New

Zea

land

16 20 17 20 19

Ind

epen

den

t p

erso

nal s

ervi

ces22

Pub

lic e

nter

tain

men

tD

epen

den

t p

erso

nal s

ervi

ces15

Pub

lic e

nter

tain

men

t15

Stu

dyi

ng a

nd t

rain

ing:

Rem

ittan

ces

or a

llow

ance

s10

14 17 15 17 20

No

limit

$10,

00025

No

limit

$10,

00025

No

limit

Any

con

trac

tor

Any

con

trac

tor

Any

for

eign

res

iden

tA

ny f

orei

gn r

esid

ent

Any

for

eign

res

iden

t

183

day

s18

3 d

ays

183

day

s18

3 d

ays

No

limit

No

rway

15 16 20 17 18 19

16(1

)13 13 14 15 16

(1)

16(1

)16

(2)

16(3

)

Sch

olar

ship

or

fello

wsh

ip g

rant

Ind

epen

den

t p

erso

nal s

ervi

ces22

Pub

lic e

nter

tain

men

tD

epen

den

t p

erso

nal s

ervi

ces

Teac

hing

4

Stu

dyi

ng a

nd t

rain

ing:

Rem

ittan

ces

or a

llow

ance

sC

omp

ensa

tion

dur

ing

trai

ning

Com

pens

atio

n w

hile

gai

ning

exp

erie

nce2

Com

pen

satio

n un

der

U.S

.G

over

nmen

t p

rogr

am

5 ye

ars

182

day

s90

day

s18

2 d

ays

2 ye

ars

5 ye

ars

5 ye

ars

12 c

onse

c. m

o.

1 ye

ar

Any

U.S

. or

for

eign

res

iden

t5

Any

con

trac

tor

Any

con

trac

tor

Nor

weg

ian

resi

den

t16

U.S

. ed

ucat

iona

l ins

titut

ion

Any

for

eign

res

iden

tU

.S.

or a

ny f

orei

gn r

esid

ent

Nor

weg

ian

resi

den

t

U.S

. G

over

nmen

t or

its

cont

ract

or

No

limit

No

limit

$10,

000

p.a

.N

o lim

itN

o lim

it

No

limit

$2,0

00 p

.a.

$5,0

00

$10,

000

Phi

lipp

ines

15 16 20 17 20 18 19

Sch

olar

ship

or

fello

wsh

ip g

rant

Ind

epen

den

t p

erso

nal s

ervi

ces22

Pub

lic e

nter

tain

men

t

22(1

)15 15 17

Dep

end

ent

per

sona

l ser

vice

s15

Pub

lic e

nter

tain

men

t16 17

Teac

hing

4,38

21S

tud

ying

and

tra

inin

g:R

emitt

ance

s or

allo

wan

ces

Com

pen

satio

n d

urin

g st

udy

Com

pens

atio

n w

hile

gai

ning

exp

erie

nce2

Com

pen

satio

n w

hile

und

er U

.S.

Gov

ernm

ent

pro

gram

22(1

)22

(1)

22(2

)

22(3

)

5 ye

ars

89 d

ays

89 d

ays

No

limit

89 d

ays

No

limit

2 ye

ars

5 ye

ars

5 ye

ars

12 c

onse

c. m

o.

1 ye

ar

Any

U.S

. or

for

eign

res

iden

t5

Any

for

eign

con

trac

tor

Any

U.S

. re

sid

ent

Any

con

trac

tor

Any

Phi

lipp

ines

res

iden

t16

Any

U.S

. or

for

eign

res

iden

t

U.S

. ed

ucat

iona

l ins

titut

ion

Any

for

eign

res

iden

tA

ny U

.S.

or f

orei

gn r

esid

ent

Phi

lipp

ines

res

iden

t

U.S

. G

over

nmen

t or

its

cont

ract

or

No

limit

No

limit

$10,

000

p.a

.$1

00 p

er d

ayor

$3,

000

p.a

.N

o lim

it$1

00 p

er d

ayor

$3,

000

p.a

.N

o lim

it

No

limit

$3,0

00 p

.a.

$7,5

00 p

.a.

$10,

000

p.a

.

Po

land

15 16 17 18 19

Sch

olar

ship

or

fello

wsh

ip g

rant

Ind

epen

den

t p

erso

nal s

ervi

ces

Dep

end

ent

per

sona

l ser

vice

s15

Teac

hing

4

Stu

dyi

ng a

nd t

rain

ing:

Rem

ittan

ces

or a

llow

ance

sC

omp

ensa

tion

dur

ing

trai

ning

Com

pens

atio

n w

hile

gai

ning

exp

erie

nce2

Com

pen

satio

n w

hile

und

er U

.S.

Gov

ernm

ent

pro

gram

18(1

)15 16 17 18

(1)

18(1

)18

(2)

18(3

)

5 ye

ars

182

day

s18

2 d

ays

2 ye

ars

5 ye

ars

5 ye

ars

1 ye

ar

1 ye

ar

Any

U.S

. or

for

eign

res

iden

t5

Any

con

trac

tor

Any

for

eign

res

iden

tU

.S.

educ

atio

nal i

nstit

utio

n

Any

for

eign

res

iden

tU

.S.

or a

ny f

orei

gn r

esid

ent

Pol

ish

resi

den

t

U.S

. G

over

nmen

t or

its

cont

ract

or

No

limit

No

limit

No

limit

No

limit

No

limit

$2,0

00 p

.a.

$5,0

00

$10,

000




Tab

le 2

.(C

ontin

ued

)

Co

untr

y(1

)C

od

e1

(2)

Cat

ego

ry o

f P

erso

nal S

ervi

ces

Pur

po

se(3

)

Max

imum

Pre

senc

ein

U.S

.(4

)R

equi

red

Em

plo

yer

or

Pay

er(5

)

Max

imum

Am

oun

t o

fC

om

pen

sati

on

(6)

Tre

aty

Art

icle

Cit

atio

n(7

)

Ro

man

ia

Rus

sia

15 16 20 17 20 18 19 15 16 17 19

Sch

olar

ship

or

fello

wsh

ip g

rant

Ind

epen

den

t p

erso

nal s

ervi

ces49

Pub

lic e

nter

tain

men

tD

epen

den

t p

erso

nal s

ervi

ces15

Pub

lic e

nter

tain

men

tTe

achi

ng4

Stu

dyi

ng a

nd t

rain

ing:

Rem

ittan

ces

or a

llow

ance

sC

omp

ensa

tion

dur

ing

trai

ning

Com

pens

atio

n w

hile

gai

ning

exp

erie

nce2

Com

pen

satio

n w

hile

und

er U

.S.

Gov

ernm

ent

pro

gram

Sch

olar

ship

or

fello

wsh

ip g

rant

44

Ind

epen

den

t p

erso

nal s

ervi

ces22

Dep

end

ent

per

sona

l ser

vice

s7,15

,32

Stu

dyi

ng a

nd t

rain

ing:

4

Rem

ittan

ces

20(1

)14 14 15 15 19 20

(1)

20(1

)20

(2)

20(3

)18 13 14 18

No

limit

No

limit

$3,0

00N

o lim

it$2

,999

.99

No

limit

No

limit

$2,0

00 p

.a.

$5,0

00

$10,

000

No

limit

No

limit

No

limit

No

limit

Any

U.S

. or

for

eign

res

iden

t5

Any

con

trac

tor

Any

con

trac

tor

Rom

ania

n re

sid

ent

Rom

ania

n re

sid

ent

U.S

. ed

ucat

iona

l ins

titut

ion

Any

for

eign

res

iden

tU

.S.

or a

ny f

orei

gn r

esid

ent

Rom

ania

n re

sid

ent

U.S

. G

over

nmen

t or

its

cont

ract

orA

ny U

.S.

or f

orei

gn r

esid

ent5

Any

con

trac

tor

Any

for

eign

res

iden

t

Any

for

eign

res

iden

t

5 ye

ars

182

day

s90

day

s18

2 d

ays

89 d

ays

2 ye

ars

5 ye

ars

5 ye

ars

1 ye

ar

1 ye

ar5

year

s31

183

day

s18

3 d

ays

5 ye

ars31

Po

rtug

al15 16 20 17 20 18 19

Sch

olar

ship

or

fello

wsh

ip g

rant

Ind

epen

den

t p

erso

nal s

ervi

ces22

Pub

lic e

nter

tain

men

tD

epen

den

t p

erso

nal s

ervi

ces7,

15

Pub

lic e

nter

tain

men

tTe

achi

ng4,

41

Stu

dyi

ng a

nd t

rain

ing:

4

Rem

ittan

ces

or a

llow

ance

sC

omp

ensa

tion

dur

ing

stud

y or

trai

ning

Com

pens

atio

n w

hile

gai

ning

exp

erie

nce2

23(1

)15 19 16 19 22 23

(1)

23(2

)23

(1)

23(2

)

No

limit

No

limit

$10,

000

p.a

.30

No

limit

$10,

000

p.a

.30

No

limit

No

limit

$8,0

00$5

,000

p.a

.$8

,000

Any

U.S

. or

for

eign

res

iden

t5

Any

con

trac

tor

Any

con

trac

tor

Any

for

eign

res

iden

tA

ny U

.S.

or f

orei

gn r

esid

ent

U.S

. ed

ucat

iona

l ins

titut

ion

Any

for

eign

res

iden

t

Por

tugu

ese

resi

den

tO

ther

for

eign

or

U.S

. re

sid

ent

Por

tugu

ese

resi

den

t

5 ye

ars

182

day

sN

o lim

it18

3 d

ays

No

limit

2 ye

ars

5 ye

ars

12 c

onse

c. m

os.

5 ye

ars

12 c

onse

c. m

os.

Slo

vak

Rep

ublic

15 16 20 17 20 18 19

Sch

olar

ship

or

fello

wsh

ip g

rant

Ind

epen

den

t p

erso

nal s

ervi

ces22

Pub

lic e

nter

tain

men

tD

epen

den

t p

erso

nal s

ervi

ces15

,24

Pub

lic e

nter

tain

men

tTe

achi

ng4,

35

Stu

dyi

ng a

nd t

rain

ing:

Rem

ittan

ces

or a

llow

ance

sC

omp

ensa

tion

dur

ing

trai

ning

Com

pens

atio

n w

hile

gai

ning

exp

erie

nce2

Com

pen

satio

n w

hile

und

er U

.S.

Gov

ernm

ent

pro

gram

21(1

)14 18 15 18 21

(5)

21(1

)21

(1)

21(2

)

21(3

)

No

limit

No

limit

$20,

000

p.a

.30

No

limit

$20,

000

p.a

.30

No

limit

No

limit

$5,0

00 p

.a.

$8,0

00

$10,

000

Any

U.S

. or

for

eign

res

iden

t5

Any

con

trac

tor

Any

con

trac

tor

Any

for

eign

res

iden

tA

ny f

orei

gn r

esid

ent

Any

U.S

. ed

ucat

iona

l or

rese

arch

inst

itutio

n

Any

for

eign

res

iden

tA

ny U

.S.

or f

orei

gn r

esid

ent

Slo

vak

resi

den

t

U.S

. G

over

nmen

t

5 ye

ars

183

day

s18

3 d

ays

183

day

s18

3 d

ays

2 ye

ars

5 ye

ars

5 ye

ars

12 c

onse

c. m

os.

1 ye

ar

Slo

veni

a15 16 20 17 20 18 19

Sch

olar

ship

or

fello

wsh

ip g

rant

4

Ind

epen

den

t p

erso

nal s

ervi

ces22

Pub

lic e

nter

tain

men

tD

epen

den

t p

erso

nal s

ervi

ces15

, 24

Pub

lic e

nter

tain

men

tTe

achi

ng o

r re

sear

ch4

Stu

dyi

ng a

nd t

rain

ing4

Rem

ittan

ces

or a

llow

ance

sC

omp

ensa

tion

dur

ing

trai

ning

Com

pens

atio

n w

hile

gai

ning

exp

erie

nce2

20(1

)14 17 15 17 20

(3)

20(1

)20

(2)

20(1

)20

(2)

No

limit

No

limit

$15,

000

p.a

.51

No

limit

$15,

000

p.a

.51

No

limit

No

limit

$8,0

00$5

,000

p.a

.$8

,000

Any

U.S

. or

for

eign

res

iden

t5

Any

con

trac

tor

Any

con

trac

tor

Any

for

eign

res

iden

tA

ny U

.S.

or f

orei

gn r

esid

ent

Any

U.S

. or

for

eign

res

iden

t

Any

for

eign

res

iden

tS

love

nian

res

iden

tO

ther

for

eign

or

U.S

. re

sid

ent

Slo

veni

an r

esid

ent

5 ye

ars47

No

limit

No

limit

183

day

sN

o lim

it2

year

s48

5 ye

ars47

12 m

os.

12 m

os.

5 ye

ars47




Tab

le 2

.(C

ontin

ued

)

Co

untr

y(1

)C

od

e1

(2)

Cat

ego

ry o

f P

erso

nal S

ervi

ces

Pur

po

se(3

)

Max

imum

Pre

senc

ein

U.S

.(4

)R

equi

red

Em

plo

yer

or

Pay

er(5

)

Max

imum

Am

oun

t o

fC

om

pen

sati

on

(6)

Tre

aty

Art

icle

Cit

atio

n(7

)

Sw

itze

rlan

d16 20 17 20 19

Ind

epen

den

t p

erso

nal s

ervi

ces22

Pub

lic e

nter

tain

men

tD

epen

den

t p

erso

nal s

ervi

ces7,

15

Pub

lic e

nter

tain

men

tS

tud

ying

and

tra

inin

g:R

emitt

ance

s or

allo

wan

ces10

14 17 15 17 20

No

limit

$10,

00025

No

limit

$10,

00025

No

limit

Any

con

trac

tor

Any

con

trac

tor

Any

for

eign

res

iden

tA

ny U

.S.

or f

orei

gn r

esid

ent

Any

for

eign

res

iden

t

No

limit

No

limit

183

day

sN

o lim

it

No

limit

Tha

iland

16 17 18 19

Ind

epen

den

t p

erso

nal s

ervi

ces22

Dep

end

ent

per

sona

l ser

vice

s15,2

3

Teac

hing

or

rese

arch

4,38

Stu

dyi

ng a

nd t

rain

ing:

Rem

ittan

ces

or a

llow

ance

s

15 15 16 19 23 22(1

)

Sch

olar

ship

or

fello

wsh

ip g

rant

15

Com

pen

satio

n d

urin

g tr

aini

ngC

omp

ensa

tion

whi

le g

aini

ng e

xper

ienc

e2

Com

pen

satio

n un

der

U.S

.G

over

nmen

t p

rogr

am

22(1

)

22(1

)22

(2)

22(3

)

No

limit

$10,

000

No

limit45

No

limit

No

limit

No

limit

$3,0

00 p

.a.

$7,5

00

$10,

000

Any

U.S

. or

for

eign

res

iden

t5

Any

for

eign

con

trac

tor

Any

for

eign

res

iden

t

Any

for

eign

res

iden

tA

ny U

.S.

or f

orei

gn r

esid

ent

Thai

res

iden

t

U.S

. G

over

nmen

t

5 ye

ars

89 d

ays

89 d

ays

183

day

sN

o lim

it

2 ye

ars

5 ye

ars

5 ye

ars

12 c

onse

c. m

os.

1 ye

ar

20P

ublic

ent

erta

inm

ent

No

limit

20P

ublic

ent

erta

inm

ent

Any

U.S

. re

sid

ent

Any

con

trac

tor

Any

U.S

. or

for

eign

res

iden

t

Any

U.S

. or

for

eign

res

iden

t

$100

per

day

or $

3,00

0 p

.a.9

$100

per

day

or $

3,00

0 p

.a.9

19

So

uth

Afr

ica

16 20 17 20 19

Ind

epen

den

t p

erso

nal s

ervi

ces22

Pub

lic e

nter

tain

men

tD

epen

den

t p

erso

nal s

ervi

ces15

,24

Pub

lic e

nter

tain

men

tS

tud

ying

and

tra

inin

g:R

emitt

ance

s or

allo

wan

ces10

14 17 15 17 20

No

limit

$7,5

0030

No

limit

$7,5

0030

No

limit

Any

con

trac

tor

Any

con

trac

tor

Any

for

eign

res

iden

tA

ny U

.S.

or f

orei

gn r

esid

ent

Any

for

eign

res

iden

t

No

limit

183

day

sN

o lim

it

1 ye

ar11

Sp

ain

15 16 20 17 20 19

Sch

olar

ship

or

fello

wsh

ip g

rant

Ind

epen

den

t p

erso

nal s

ervi

ces22

Pub

lic e

nter

tain

men

tD

epen

den

t p

erso

nal s

ervi

ces15

Pub

lic e

nter

tain

men

tS

tud

ying

and

tra

inin

g:4

Rem

ittan

ces

or a

llow

ance

sC

omp

ensa

tion

dur

ing

trai

ning

Com

pens

atio

n w

hile

gai

ning

exp

erie

nce2

22(1

)15 19 16 19 22

(1)

22(1

)22

(2)

No

limit

No

limit

$10,

000

p.a

.30

No

limit

$10,

000

p.a

.30

No

limit

$5,0

00 p

.a.

$8,0

00

Any

U.S

. or

for

eign

res

iden

t5

Any

con

trac

tor

Any

con

trac

tor

Any

for

eign

res

iden

tA

ny U

.S.

or f

orei

gn r

esid

ent

Any

for

eign

res

iden

t

Sp

anis

h re

sid

ent

5 ye

ars

No

limit

No

limit

183

day

sN

o lim

it

5 ye

ars

5 ye

ars

12 c

onse

c. m

o.A

ny U

.S.

or f

orei

gn r

esid

ent

183

day

s

Sw

eden

16 20 17 20 19

Ind

epen

den

t p

erso

nal s

ervi

ces22

Pub

lic e

nter

tain

men

tD

epen

den

t p

erso

nal s

ervi

ces15

,23

Pub

lic e

nter

tain

men

tS

tud

ying

and

tra

inin

g:R

emitt

ance

s or

allo

wan

ces10

14 18 15 18 21

No

limit

$6,0

0042

No

limit

$6,0

0042

No

limit

Any

con

trac

tor

Any

con

trac

tor

Any

for

eign

res

iden

tA

ny U

.S.

or f

orei

gn r

esid

ent

Any

for

eign

res

iden

t

No

limit

No

limit

183

day

sN

o lim

it

No

limit

Sri

Lan

ka16 20 17 20 19

Ind

epen

den

t p

erso

nal s

ervi

ces22

, 24

Pub

lic e

nter

tain

men

t22

Dep

end

ent

per

sona

l ser

vice

s15,

24

Pub

lic e

nter

tain

men

t15

Stu

dyi

ng a

nd t

rain

ing:

Rem

ittan

ces

or a

llow

ance

s10

Com

pen

satio

n w

hile

gai

ning

exp

erie

nce2

15 18 16 18 21(1

)21

(2)

No

limit

$6,0

00 p

.a.51

No

limit

$6,0

00 p

.a.51

No

limit

$6,0

00

Any

con

trac

tor

Any

con

trac

tor

Any

for

eign

res

iden

tA

ny f

orei

gn r

esid

ent

Any

for

eign

res

iden

tS

ri La

nkan

res

iden

t55

183

day

s18

3 d

ays

183

day

s18

3 d

ays

No

limit

1 ye

ar




Tab

le 2

.(C

ontin

ued

)

Co

untr

y(1

)C

od

e1

(2)

Cat

ego

ry o

f P

erso

nal S

ervi

ces

Pur

po

se(3

)

Max

imum

Pre

senc

ein

U.S

.(4

)R

equi

red

Em

plo

yer

or

Pay

er(5

)

Max

imum

Am

oun

t o

fC

om

pen

sati

on

(6)

Tre

aty

Art

icle

Cit

atio

n(7

)T

rini

dad

and

To

bag

o16 17 18 19

Ind

epen

den

t p

erso

nal s

ervi

ces13

Dep

end

ent

per

sona

l ser

vice

s13

Teac

hing

4

Stu

dyi

ng a

nd t

rain

ing:

Rem

ittan

ces

or a

llow

ance

s

17 17 17 17 18 19(1

)

Sch

olar

ship

or

fello

wsh

ip g

rant

15

Com

pen

satio

n d

urin

g tr

aini

ngC

ompe

nsat

ion

durin

g pr

ofes

sion

al tr

aini

ngC

ompe

nsat

ion

whi

le g

aini

ng e

xper

ienc

e2

Com

pen

satio

n un

der

U.S

.G

over

nmen

t p

rogr

am

19(1

)

19(1

)19

(1)

19(2

)

19(3

)

Tun

isia

16 17 19

Ind

epen

den

t p

erso

nal s

ervi

ces22

Dep

end

ent

per

sona

l ser

vice

s15

Stu

dyi

ng a

nd t

rain

ing:

10

Rem

ittan

ces

or a

llow

ance

s

14 17 15 17 20

Sch

olar

ship

or

fello

wsh

ip g

rant

1015

Com

pen

satio

n d

urin

g tr

aini

ng

20 20

Pub

lic e

nter

tain

men

t

Pub

lic e

nter

tain

men

t

20 20

Ukr

aine

No

limit

No

limit

$3,0

006

No

limit

$3,0

006

No

limit

No

limit

$2,0

00 p

.a.6

$5,0

00 p

.a.6

$5,0

006

$10,

0006

No

limit

$7,5

00 p

.a.

$7,5

00 p

.a.25

No

limit

$7,5

00 p

.a.25

No

limit

$4,0

00 p

.a.

Any

U.S

. or

for

eign

res

iden

t5

Any

for

eign

res

iden

t co

ntra

ctor

Any

U.S

. co

ntra

ctor

Any

for

eign

res

iden

tA

ny U

.S.

resi

den

tU

.S. e

duca

tiona

l ins

titut

ion

or U

.S. G

over

nmen

t

Any

for

eign

res

iden

tU

.S.

or a

ny f

orei

gn r

esid

ent

U.S

. or

any

for

eign

res

iden

tTr

inid

ad–T

obag

o re

sid

ent

U.S

. G

over

nmen

t or

its

cont

ract

or

Any

U.S

. or

for

eign

res

iden

t5

U.S

. re

sid

ent

cont

ract

orA

ny c

ontr

acto

rA

ny f

orei

gn r

esid

ent

Any

U.S

. or

for

eign

res

iden

t

Any

for

eign

res

iden

tA

ny U

.S.

or f

orei

gn r

esid

ent

5 ye

ars

183

day

s18

3 d

ays

183

day

s18

3 d

ays

2 ye

ars

5 ye

ars

5 ye

ars

5 ye

ars

1 ye

ar

1 ye

ar

5 ye

ars

183

day

sN

o lim

it18

3 d

ays

No

limit

5 ye

ars

5 ye

ars

Tur

key

16 20 17 20 19

Ind

epen

den

t p

erso

nal s

ervi

ces22

Pub

lic e

nter

tain

men

t46

Dep

end

ent

per

sona

l ser

vice

s15,2

4

Pub

lic e

nter

tain

men

t46

Stu

dyi

ng a

nd t

rain

ing:

Rem

ittan

ces

or a

llow

ance

s10

14 17 15 17 20(1

)

No

limit

$3,0

0053

No

limit

$3,0

0053

No

limit

Any

con

trac

tor

Any

con

trac

tor

Any

for

eign

res

iden

tA

ny U

.S.

or f

orei

gn r

esid

ent

Any

for

eign

res

iden

t

183

day

sN

o lim

it18

3 d

ays

No

limit

No

limit

18Te

achi

ng o

r re

sear

ch20

(2)

No

limit

2 ye

ars

Any

for

eign

res

iden

t

15 16 19

Sch

olar

ship

or

fello

wsh

ip g

rant

44

Ind

epen

den

t p

erso

nal s

ervi

ces22

,50

Stu

dyi

ng a

nd t

rain

ing:

Rem

ittan

ces

or a

llow

ance

s10

20 14 15 20

17D

epen

den

t p

erso

nal s

ervi

ces15

,23,

50

No

limit

No

limit

No

limit

No

limit

Any

con

trac

tor

Any

for

eign

res

iden

t

5 ye

ars31

183

day

s

5 ye

ars31

No

limit

Any

for

eign

res

iden

t

Any

U.S

. or

for

eign

res

iden

t5

16 20 20

Ind

epen

den

t p

erso

nal s

ervi

ces7,

54

Pub

lic e

nter

tain

men

t

Pub

lic e

nter

tain

men

tTe

achi

ng o

r re

sear

ch4

16 14 20A

17D

epen

den

t p

erso

nal s

ervi

ces15

, 24

$20,

000

p.a

.25

No

limit

No

limit

Any

con

trac

tor

Any

for

eign

res

iden

t

Any

U.S

. ed

ucat

iona

l ins

titut

ion

No

limit

183

day

s

2 ye

ars

Uni

ted

Kin

gd

om

18 19S

tud

ying

and

tra

inin

g:R

emitt

ance

s or

allo

wan

ces10

No

limit

No

limit57

Any

U.S

. or

for

eign

res

iden

t

Any

for

eign

res

iden

t

16$2

0,00

0 p

.a.25

No

limit

20




Tab

le 2

.(C

ontin

ued

)

Co

untr

y(1

)C

od

e1

(2)

Cat

ego

ry o

f P

erso

nal S

ervi

ces

Pur

po

se(3

)

Max

imum

Pre

senc

ein

U.S

.(4

)R

equi

red

Em

plo

yer

or

Pay

er(5

)

Max

imum

Am

oun

t o

fC

om

pen

sati

on

(6)

Tre

aty

Art

icle

Cit

atio

n(7

)

Ven

ezue

la15 17 19

No

limit

No

limit

No

limit

Sch

olar

ship

or

fello

wsh

ip g

rant

s4

Dep

end

ent

per

sona

l ser

vice

s15,2

4

Stu

dyi

ng a

nd t

rain

ing:

4

Rem

ittan

ces

or a

llow

ance

s

5 ye

ars47

183

day

s

5 ye

ars47

20P

ublic

ent

erta

inm

ent

20P

ublic

ent

erta

inm

ent

No

limit

No

limit

Any

for

eign

res

iden

tA

ny c

ontr

acto

r

Any

U.S

. or

for

eign

res

iden

t

Any

for

eign

res

iden

t

$6,0

0030

$6,0

0030

21(1

)

18 15 18 21(1

)

16N

o lim

itIn

dep

end

ent

per

sona

l ser

vice

s22,2

4A

ny c

ontr

acto

r14

Com

pen

satio

n d

urin

g tr

aini

ng

Com

pen

satio

n w

hile

gai

ning

exp

erie

nce2

12 m

os.

12 m

os.

5 ye

ars47

Any

U.S

. or

for

eign

res

iden

t5

Ven

ezue

lan

resi

den

t

Ven

ezue

lan

resi

den

t

Oth

er f

orei

gn o

r U

.S.

resi

den

t$8

,000

$5,0

00 p

.a.

$8,0

00

21(2

)21

(1)

21(2

)

18N

o lim

itTe

achi

ng4

2 ye

ars48

21(3

)A

ny U

.S.

or f

orei

gn r

esid

ent

No

limit




1 2 3 4 5 6 7 8 9 10 11 12 13 14

Ref

ers

to i

ncom

e co

de

num

ber

s un

der

whi

ch t

he i

ncom

e is

rep

orte

d

on

Form

s 10

42-S

. P

erso

nal

serv

ices

m

ust

be

per

form

ed b

y a

nonr

esid

ent

alie

n in

div

idua

l who

is a

res

iden

tof

the

sp

ecifi

ed t

reat

y co

untr

y.A

pp

lies

only

if t

rain

ing

or e

xper

ienc

e is

rec

eive

d fr

om a

per

son

othe

r th

an a

lien’

s em

plo

yer.

Em

plo

ymen

t w

ith a

tea

m w

hich

par

ticip

ates

in

a le

ague

with

regu

larly

sc

hed

uled

ga

mes

in

b

oth

coun

trie

s is

co

vere

dun

der

the

pro

visi

ons

for

dep

end

ent

per

sona

l ser

vice

s.D

oes

not

app

ly t

o co

mp

ensa

tion

for

rese

arch

wor

k p

rimar

ilyfo

r p

rivat

e b

enef

it.G

rant

mus

t b

e fr

om a

non

pro

fit o

rgan

izat

ion.

In

man

y ca

ses,

the

exem

ptio

n al

so a

pp

lies

to a

mou

nts

from

eith

er t

he U

.S.

orfo

reig

n go

vern

men

t. F

or I

ndon

esia

and

the

Net

herla

nds,

the

exem

ptio

n al

so a

pp

lies

if th

e am

ount

is

awar

ded

und

er a

tech

nica

l ass

ista

nce

pro

gram

ent

ered

into

by

the

Uni

ted

Sta

tes

or t

he f

orei

gn g

over

nmen

t, o

r its

pol

itica

l sub

div

isio

ns o

r lo

cal

auth

oriti

es.

Rei

mb

urse

d e

xpen

ses

are

not

take

n in

to a

ccou

nt i

n fig

urin

gan

y m

axim

um c

omp

ensa

tion

to w

hich

the

exe

mp

tion

app

lies.

For

Jap

an a

nd T

rinid

ad a

nd T

obag

o, o

nly

reim

bur

sed

tra

vel

exp

ense

s ar

e d

isre

gard

ed

in

figur

ing

the

max

imum

com

pen

satio

n.D

oes

not

app

ly

to

fees

of

a

fore

ign

dire

ctor

of

a

U.S

.co

rpor

atio

n.D

oes

not

app

ly t

o co

mp

ensa

tion

for

rese

arch

wor

k fo

r ot

her

than

the

U.S

. ed

ucat

iona

l ins

titut

ion

invo

lved

.E

xem

ptio

n d

oes

not a

pp

ly if

gro

ss re

ceip

ts e

xcee

d th

is a

mou

nt.

Inco

me

is

fully

ex

emp

t if

visi

t to

th

e U

nite

d

Sta

tes

issu

bst

antia

lly s

upp

orte

d b

y p

ublic

fun

ds

of t

he t

reat

y co

untr

yor

its

pol

itica

l sub

div

isio

ns o

r lo

cal a

utho

ritie

s.A

pp

lies

only

to

full-

time

stud

ent

or t

rain

ee.

The

time

limit

per

tain

s on

ly to

an

app

rent

ice

or b

usin

ess

trai

nee.

Doe

s no

t ap

ply

to

com

pen

satio

n p

aid

to

pub

lic e

nter

tain

ers

(act

ors,

art

ists

, m

usic

ians

, at

hlet

es,

etc.

).D

oes

not

app

ly t

o co

mp

ensa

tion

pai

d t

o p

ublic

ent

erta

iner

sth

at is

mor

e th

an $

100

a d

ay.

Exe

mp

tion

app

lies

only

if

the

com

pen

satio

n is

sub

ject

to

tax

in t

he c

ount

ry o

f re

sid

ence

.15 16 17 18 19 20

21 22 23 24 25 26 27

The

exem

ptio

n d

oes

not

app

ly

if th

e em

plo

yee’

sco

mp

ensa

tion

is b

orne

by

a p

erm

anen

t es

tab

lishm

ent

(or

inso

me

case

s a

fixed

b

ase)

th

at

the

emp

loye

r ha

s in

th

eU

nite

d S

tate

s.Th

e ex

emp

tion

also

ap

plie

s if

the

emp

loye

r is

a p

erm

anen

tes

tab

lishm

ent

in t

he t

reat

y co

untr

y b

ut i

s no

t a

resi

den

t of

the

trea

ty c

ount

ry.

This

ex

emp

tion

doe

s no

t ap

ply

in

ce

rtai

n ca

ses

if th

eem

plo

yee

is a

sub

stan

tial

owne

r of

tha

t em

plo

yer

and

the

emp

loye

r is

eng

aged

in c

erta

in d

efin

ed a

ctiv

ities

.Th

e ex

emp

tion

is

also

ex

tend

ed

to

jour

nalis

ts

and

corr

esp

ond

ents

who

are

tem

por

arily

in

the

U.S

. fo

r p

erio

ds

not

long

er t

han

2 ye

ars

and

who

rec

eive

com

pen

satio

n fr

omab

road

.A

lso

exem

pt

are

amou

nts

of u

p t

o $1

0,00

0 re

ceiv

ed f

rom

U.S

. so

urce

s to

p

rovi

de

ord

inar

y liv

ing

exp

ense

s.

For

stud

ents

, th

e am

ount

will

be

less

tha

n $1

0,00

0, d

eter

min

edon

a c

ase

by

case

bas

is.

A s

tud

ent

or t

rain

ee m

ay c

hoos

e to

be

trea

ted

as

a U

.S.

resi

den

t fo

r ta

x p

urp

oses

. If

the

choi

ce i

s m

ade,

it

may

not

be

chan

ged

w

ithou

t th

e co

nsen

t of

th

e U

.S.

com

pet

ent

auth

ority

.

Am

ount

s re

ceiv

ed i

n ex

cess

of

a re

ason

able

fix

ed a

mou

ntp

ayab

le t

o al

l d

irect

ors

for

atte

ndin

g m

eetin

gs i

n th

e U

nite

dS

tate

s ar

e ta

xab

le.

Exe

mp

tion

doe

s no

t ap

ply

to

the

exte

nt in

com

e is

att

ribut

able

to t

he r

ecip

ient

’s f

ixed

U.S

. b

ase.

For

res

iden

ts o

f Ic

elan

d,

Kor

ea,

and

Nor

way

, th

e fix

ed b

ase

mus

t b

e m

aint

aine

d f

orm

ore

than

18

2 d

ays;

fo

r re

sid

ents

of

M

oroc

co,

the

fixed

bas

e m

ust

be

mai

ntai

ned

for

mor

e th

an 8

9 d

ays.

Fees

pai

d t

o a

resi

den

t of

the

tre

aty

coun

try

for

serv

ices

as

ad

irect

or o

f a

U.S

. co

rpor

atio

n ar

e su

bje

ct t

o U

.S.

tax,

unl

ess

the

serv

ices

are

per

form

ed in

the

cou

ntry

of

resi

den

ce.

Fees

pai

d t

o a

resi

den

t of

the

tre

aty

coun

try

for

serv

ices

per

form

ed

in

the

Uni

ted

S

tate

s as

a

dire

ctor

of

a

U.S

.co

rpor

atio

n ar

e su

bje

ct t

o U

.S.

tax.

Exe

mp

tion

doe

s no

t ap

ply

if

gros

s re

ceip

ts

(incl

udin

gre

imb

urse

men

ts)

exce

ed t

his

amou

nt.

Exe

mp

tion

doe

s no

t ap

ply

if

net

inco

me

exce

eds

this

amou

nt.

Exe

mp

tion

doe

s no

t ap

ply

to

p

aym

ents

b

orne

b

y a

per

man

ent

esta

blis

hmen

t in

the

Uni

ted

Sta

tes

or p

aid

by

aU

.S.

citiz

en

or

resi

den

t or

th

e fe

der

al,

stat

e,

or

loca

lgo

vern

men

t.28 29 30 31 32 33 34 35 36 37 38

39 40 41 42 43 44

Exe

mp

tion

doe

s no

t ap

ply

if

com

pen

satio

n ex

ceed

s th

isam

ount

.Th

e ex

emp

tion

app

lies

only

to

in

com

e fr

om

activ

ities

per

form

ed u

nder

sp

ecia

l cu

ltura

l ex

chan

ge p

rogr

ams

agre

edto

by

the

U.S

. an

d C

hine

se g

over

nmen

ts.

Exe

mp

tion

doe

s no

t ap

ply

if g

ross

rec

eip

ts (

or c

omp

ensa

tion

for

Por

tuga

l), i

nclu

din

g re

imb

urse

men

ts,

exce

ed t

his

amou

nt.

Inco

me

is

fully

ex

emp

t if

visi

t to

th

e U

nite

d

Sta

tes

issu

bst

antia

lly s

upp

orte

d b

y p

ublic

fun

ds

of t

he t

reat

y co

untr

yor

its

pol

itica

l sub

div

isio

ns o

r lo

cal a

utho

ritie

s.Th

e 5-

year

lim

it p

erta

ins

only

to

trai

ning

or

rese

arch

.C

omp

ensa

tion

from

em

plo

ymen

t d

irect

ly c

onne

cted

with

ap

lace

of

bus

ines

s th

at i

s no

t a

per

man

ent

esta

blis

hmen

t is

exem

pt

if th

e al

ien

is

pre

sent

in

th

e U

nite

d

Sta

tes

for

ap

erio

d n

ot e

xcee

din

g 12

con

secu

tive

mon

ths.

Com

pen

satio

nfo

r te

chni

cal

serv

ices

dire

ctly

con

nect

ed w

ith t

he a

pp

licat

ion

of a

rig

ht o

r p

rop

erty

giv

ing

rise

to a

roy

alty

is

exem

pt

if th

ese

rvic

es a

re p

rovi

ded

as

par

t of

a c

ontr

act

gran

ting

the

use

of t

he r

ight

or

pro

per

ty.

Exe

mp

tion

doe

s no

t ap

ply

if,

d

urin

g th

e im

med

iate

lyp

rece

din

g p

erio

d,

the

ind

ivid

ual

clai

med

th

e b

enef

its

ofA

rtic

le 2

1.E

xem

ptio

n d

oes

not

app

ly

if,

dur

ing

the

imm

edia

tely

pre

ced

ing

per

iod

, th

e in

div

idua

l cl

aim

ed

the

ben

efits

of

Art

icle

22.

Exe

mp

tion

doe

s no

t ap

ply

if

the

ind

ivid

ual

eith

er (

a) c

laim

edth

e b

enef

it of

A

rtic

le

21(5

) d

urin

g a

pre

viou

s vi

sit,

or

(b

)d

urin

g th

e im

med

iate

ly p

rece

din

g p

erio

d,

clai

med

the

ben

efit

of A

rtic

le 2

1(1)

, (2

), or

(3)

.E

xem

ptio

n ap

plie

s on

ly

to

com

pen

satio

n fo

r p

erso

nal

serv

ices

per

form

ed i

n co

nnec

tion

with

, or

inc

iden

tal

to,

the

ind

ivid

ual’s

stu

dy,

res

earc

h, o

r tr

aini

ng.

Exe

mp

tion

doe

s no

t ap

ply

if,

d

urin

g th

e im

med

iate

lyp

rece

din

g p

erio

d,

the

ind

ivid

ual

clai

med

th

e b

enef

its

ofA

rtic

le 2

4(1)

.E

xem

ptio

n d

oes

not

app

ly

if,

dur

ing

the

imm

edia

tely

pre

ced

ing

per

iod

, th

e in

div

idua

l cl

aim

ed

the

ben

efits

of

Art

icle

22(

1).

Exe

mp

tion

doe

s no

t ap

ply

if t

he in

div

idua

l pre

viou

sly

clai

med

the

ben

efit

of t

his

Art

icle

.Th

e co

mb

ined

per

iod

of

ben

efits

und

er A

rtic

les

20 a

nd 2

1(1)

cann

ot e

xcee

d 5

yea

rs.

Exe

mp

tion

doe

s no

t ap

ply

if

the

ind

ivid

ual

eith

er

(a)

pre

viou

sly

clai

med

the

ben

efit

of t

his

Art

icle

, or

(b

) d

urin

g th

eim

med

iate

ly p

rece

din

g p

erio

d,

clai

med

the

ben

efit

of A

rtic

le23

. Th

e b

enef

its u

nder

Art

icle

s 22

and

23

cann

ot b

e cl

aim

edat

the

sam

e tim

e.E

xem

ptio

n d

oes

not

app

ly

if gr

oss

rece

ipts

(in

clud

ing

reim

bur

sem

ents

) ex

ceed

thi

s am

ount

dur

ing

any

12-m

onth

per

iod

.Th

is p

rovi

sion

doe

s no

t ap

ply

if

the

com

pet

ent

auth

ority

of

the

trea

ty

coun

try

cert

ifies

th

at

the

visi

t is

su

bst

antia

llysu

pp

orte

d b

y th

at t

reat

y co

untr

y.A

pp

lies

to g

rant

s, a

llow

ance

s, a

nd o

ther

sim

ilar

pay

men

tsre

ceiv

ed f

or s

tud

ying

or

doi

ng r

esea

rch.

45A

$10

,000

lim

it ap

plie

s if

the

exp

ense

is b

orne

by

a p

erm

anen

tes

tab

lishm

ent

or a

fix

ed b

ase

in t

he U

nite

d S

tate

s.46

This

pro

visi

on d

oes

not a

pp

ly if

thes

e ac

tiviti

es a

re s

ubst

antia

llysu

pp

orte

d b

y a

nonp

rofit

org

aniz

atio

n or

by

pub

lic fu

nds

of th

etr

eaty

cou

ntry

or

its p

oliti

cal s

ubd

ivis

ions

or

loca

l aut

horit

ies.

47A

pp

lies

to a

ny a

dd

ition

al p

erio

d t

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57




Table 3. List of Tax Treaties (Updated through December 31, 2007)

Applicable TreasuryOfficial Text General Explanations

Country Symbol1 Effective Date Citation or Treasury Decision (T.D.)

Australia TIAS 10773 Dec. 1, 1983 1986-2 C.B. 220 1986-2 C.B. 246Protocol TIAS Jan. 1, 2004

Austria 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, 2005Belgium TIAS Jan. 1, 2008Canada2 TIAS 11087 Jan. 1, 1985 1986-2 C.B. 258 1987-2 C.B. 298

Protocol TIAS Jan. 1, 1996China, 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, 2007Germany 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 8151 Jan. 1, 1976 1976-1 C.B. 442 1976-1 C.B. 456India TIAS Jan. 1, 1991Indonesia TIAS 11593 Jan. 1, 1990Ireland TIAS Jan. 1, 1998Israel TIAS Jan. 1, 1995Italy TIAS 11064 Jan. 1, 1985 1992-1 C.B. 442 1992-1 C.B. 473Jamaica TIAS 10207 Jan. 1, 1982 1982-1 C.B. 257 1982-1 C.B. 291Japan TIAS Jan. 1, 2005Kazakhstan 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, 2001Mexico TIAS Jan. 1,1994

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. 303Norway 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. 454Pakistan TIAS 4232 Jan. 1, 1959 1960-2 C.B. 646 T.D. 6431, 1960-1 C.B. 755




Table 3. (continued)

Applicable TreasuryOfficial Text General Explanations

Country Symbol1 Effective Date Citation or Treasury Decision (T.D.)

Philippines TIAS 10417 Jan. 1, 1983 1984-2 C.B. 384 1984-2 C.B. 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 States-Canada Income Tax Treaty.3 The U.S.-U.S.S.R. income tax treaty applies to the countries of Armenia, Azerbaijan, Belarus, Georgia, Kyrgyzstan, Moldova, Tajikistan, Turkmenistan, and Uzbekistan.

or for a nominal charge. The clinics also provide • Figure your withholding allowances usingtax education and outreach for taxpayers with the withholding calculator online atHow To Get Tax Helplimited English proficiency or who speak English www.irs.gov/individuals.as a second language. Publication 4134, LowYou can get help with unresolved tax issues, • Determine if Form 6251 must be filed us-Income Taxpayer Clinic List, provides informa-order free publications and forms, ask tax ques-

ing our Alternative Minimum Tax (AMT)tion on clinics in your area. It is available at www.tions, and get information from the IRS in sev-Assistant.irs.gov or at your local IRS office.eral ways. By selecting the method that is best

for you, you will have quick and easy access to • Sign up to receive local and national taxtax help. Free tax services. To find out what services news by email.

are available, get Publication 910, IRS Guide toContacting your Taxpayer Advocate. The • Get information on starting and operatingFree Tax Services. It contains a list of free taxTaxpayer Advocate Service (TAS) is an inde- a small business.publications and describes other free tax infor-pendent organization within the IRS whose em-

mation services, including tax education andployees assist taxpayers who are experiencingassistance programs and a list of TeleTax top-economic harm, who are seeking help in resolv- Phone. Many services are available byics.ing tax problems that have not been resolved phone.Accessible versions of IRS published prod-through normal channels, or who believe that anucts are available on request in a variety ofIRS system or procedure is not working as italternative formats for people with disabilities. • Ordering forms, instructions, and publica-should.

You can contact the TAS by calling the TAS tions. Call 1-800-829-3676 to order cur-Internet. You can access the IRS web-toll-free case intake line at 1-877-777-4778 or rent-year forms, instructions, andsite at www.irs.gov 24 hours a day, 7TTY/TDD 1-800-829-4059 to see if you are eligi- publications, and prior-year forms and in-days a week to:ble for assistance. You can also call or write to structions. You should receive your order• E-file your return. Find out about commer-your local taxpayer advocate, whose phone within 10 days.cial tax preparation and e-file servicesnumber and address are listed in your local

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Get Help With Unresolved Tax Problems. You Click on Where’s My Refund. Wait at least • Solving problems. You can getcan file Form 911, Request for Taxpayer Advo- 6 weeks from the date you filed your re- face-to-face help solving tax problemscate Service Assistance (And Application for turn (3 weeks if you filed electronically). every business day in IRS Taxpayer As-Taxpayer Assistance Order), or ask an IRS em- Have your 2007 tax return available be- sistance Centers. An employee can ex-ployee to complete it on your behalf. For more cause you will need to know your social plain IRS letters, request adjustments toinformation, go to www.irs.gov/advocate. security number, your filing status, and the your account, or help you set up a pay-

exact whole dollar amount of your refund.Taxpayer Advocacy Panel (TAP). The ment plan. Call your local Taxpayer Assis-TAP listens to taxpayers, identifies taxpayer is- • Download forms, instructions, and publica- tance Center for an appointment. To findsues, and makes suggestions for improving IRS tions. the number, go to www.irs.gov/localcon-services and customer satisfaction. If you have

tacts or look in the phone book under• Order IRS products online.suggestions for improvements, contact the TAP,United States Government, Internal Reve-toll free at 1-888-912-1227 or go to • Research your tax questions online. nue Service.www.improveirs.org.

• Search publications online by topic or • TTY/TDD equipment. If you have accessLow Income Taxpayer Clinics (LITCs). keyword. to TTY/TDD equipment, callLITCs are independent organizations that pro-1-800-829-4059 to ask tax questions or to• View Internal Revenue Bulletins (IRBs)vide low income taxpayers with representation

published in the last few years.in federal tax controversies with the IRS for free order forms and publications.




• TeleTax topics. Call 1-800-829-4477 to lis- visit your local Taxpayer Assistance • Internal Revenue Bulletins.ten to pre-recorded messages covering Center where you can spread out your • Toll-free and email technical support.various tax topics. records and talk with an IRS representa-

• The CD which is released twice during thetive face-to-face. No appointment is nec-• Refund information. To check the status ofyear.essary, but if you prefer, you can call your

your 2007 refund, call 1-800-829-4477– The first release will ship the beginninglocal Center and leave a message re-

and press 1 for automated refund informa-of January 2008.questing an appointment to resolve a tax

tion or call 1-800-829-1954. Be sure to– The final release will ship the beginningaccount issue. A representative will call

wait at least 6 weeks from the date youof March 2008.you back within 2 business days to sched-

filed your return (3 weeks if you filed elec-ule an in-person appointment at your con-

tronically). Have your 2007 tax return Purchase the CD/DVD from National Techni-venience. To find the number, go to www.available because you will need to know cal Information Service (NTIS) at www.irs.gov/irs.gov/localcontacts or look in the phoneyour social security number, your filing cdorders for $35 (no handling fee) or callbook under United States Government, In-status, and the exact whole dollar amount 1-877-CDFORMS (1-877-233-6767) toll free toternal Revenue Service.of your refund. buy the CD/DVD for $35 (plus a $5 handling

fee). Price is subject to change.Mail. You can send your order forEvaluating the quality of our telephoneforms, instructions, and publications toservices. To ensure IRS representatives give CD for small businesses. Publicationthe address below. You should receiveaccurate, courteous, and professional answers, 3207, The Small Business Resource

a response within 10 days after your request iswe use several methods to evaluate the quality Guide CD for 2007, is a must for everyreceived.of our telephone services. One method is for a small business owner or any taxpayer about to

second IRS representative to listen in on or start a business. This year’s CD includes:National Distribution Centerrecord random telephone calls. Another is to ask

• Helpful information, such as how to pre-P.O. Box 8903some callers to complete a short survey at thepare a business plan, find financing forBloomington, IL 61702-8903end of the call.your business, and much more.

Walk-in. Many products and services After May 2008, send your order to the following • All the business tax forms, instructions,are available on a walk-in basis. address. and publications needed to successfully

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offices, libraries, and IRS offices to pick up 1201 N. Mitsubishi Motorway• Tax Map: an electronic research tool andcertain forms, instructions, and publica- Bloomington, IL 61704-6613

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• Tax law frequently asked questions.request adjustments to your tax account, An updated version of this CD is availableor help you set up a payment plan. If you • Tax Topics from the IRS telephone re- each year in early April. You can get a free copyneed to resolve a tax problem, have ques- sponse system. by calling 1-800-829-3676 or by visiting www.irs.tions about how the tax law applies to your gov/smallbiz.• Fill-in, print, and save features for most taxindividual tax return, or you’re more com-

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