Publication 901 by TomDonnelly

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									             Publication 901
             (Rev. April 2008)                    Contents
             Cat. No. 46849F                      What’s New . . . . . . . . . . . . . . . . . . . . .     1
Department
of the                                            Reminders . . . . . . . . . . . . . . . . . . . . . .    2
Treasury
Internal
             U.S. Tax                             Introduction . . . . . . . . . . . . . . . . . . . . .
                                                  Application of Treaties . . . . . . . . . . . . .
                                                                                                           2
                                                                                                           2
Revenue
Service
             Treaties                             Tax Exemptions Provided by
                                                      Treaties . . . . . . . . . . . . . . . .   .....     2
                                                      Personal Services Income . . . .           .....     3
                                                      Professors, Teachers, and
                                                          Researchers . . . . . . . . . .        . . . . . 15
                                                      Students and Apprentices . . . .           . . . . . 19
                                                      Wages and Pensions Paid by a
                                                          Foreign Government . . . . .           . . . . . 28
                                                  Explanation of Tables . . . . . . . . . .       . . . . 33
                                                     Table 1 - Tax Rates on Income
                                                         Other Than Personal Service
                                                         Income . . . . . . . . . . . . . . .     . . . . 34
                                                     Table 2 - Exempt Personal
                                                         Services Income . . . . . . . .          . . . . 38
                                                     Table 3 - List of Tax Treaties . . .         . . . . 50
                                                  How To Get Tax Help . . . . . . . . . . . . . . 51



                                                  What’s New
                                                  New tax treaties and protocols. The United
                                                  States has exchanged instruments of ratification
                                                  for a new income tax treaty with Belgium and
                                                  new protocols for the income tax treaties with
                                                  Denmark, Finland, and Germany. The provi-
                                                  sions of these treaties and protocols are in-
                                                  cluded in the appropriate areas of this
                                                  publication. The effective dates are as follows:
                                                        Belgium. The provisions relating to with-
                                                  holding tax at source are effective for amounts
                                                  paid or credited on or after February 1, 2008. For
                                                  other taxes, the treaty is effective for tax periods
                                                  beginning on or after January 1, 2008. A person
                                                  entitled to benefits under the previous treaty can
                                                  elect to have that treaty apply in its entirety for a
                                                  twelve-month period following the date the new
                                                  treaty would otherwise apply.
                                                      Denmark. The provisions relating to with-
                                                  holding tax at source are effective for amounts
                                                  paid or credited on or after February 1, 2008. For
                                                  other 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 paid
                                                  or credited on or after February 1, 2008. How-
                                                  ever, the provisions for dividends exempt under
                                                  Article 10(3) as amended by this protocol are
                                                  effective January 1, 2007. For other taxes, the
                                                  protocol is effective for tax years beginning on or
                                                  after January 1, 2008.
                                                       Germany. The provisions relating to with-
                                                  holding tax at source are effective for amounts
                                                  paid or credited on or after January 1, 2007. For
                                                  other taxes, the treaty is effective for tax years
                                                  beginning on or after January 1, 2008. A person
                                                  entitled to benefits under the treaty before modi-
                Get forms and other information   fication by this protocol can elect to have the
                                                  unmodified treaty apply in its entirety for a
                faster 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 Treaties
                                                      clude 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 a
reduces your tax. If you take the position that           You can email us at *taxforms@irs.gov. (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 are
generally must disclose that position on your         ject line. Although we cannot respond individu-       exempt from U.S. income taxes on certain items
affected return. See Application of Treaties,         ally to each email, we do appreciate your             of income they receive from sources within the
later.                                                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 of
U.S. – U.S.S.R. income tax treaty. The
                                                        Ordering forms and publications. Visit              income.
U.S. – U.S.S.R. income tax treaty remains in ef-
                                                      www.irs.gov/formspubs to download forms and                If the treaty does not cover a particular kind
fect for the following members of the Common-
                                                      publications, call 1-800-829-3676, or write to the    of income, or if there is no treaty between your
wealth of Independent States: Armenia,
                                                      address shown in the How To Get Tax Help              country and the United States, you must pay tax
Azerbaijan, Belarus, Georgia, Kyrgyzstan,
                                                      section under Mail.                                   on the income in the same way and at the same
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 United
tiated 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 the
in this publication under Commonwealth of Inde-       itself.                                               state in which you live to find out if that state
pendent 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
U.S. – China income tax treaty does not apply to                                                                 Tax treaties reduce the U.S. taxes of re-
                                                      the following address:                                sidents of foreign countries. With certain excep-
Hong Kong.
                                                          Department of the Treasury                        tions, they do not reduce the U.S. taxes of U.S.
U.S. – United Kingdom income tax treaty.                  Office of Public Correspondence                   citizens or residents. U.S. citizens and residents
Generally, the treaty is effective for tax periods        1500 Pennsylvania Ave. NW — Rm. 3419              are subject to U.S. income tax on their world-
beginning on or after January 1, 2004. However,           Washington, D.C. 20220                            wide income.
an individual who was otherwise entitled to                                                                      Treaty provisions generally are reciprocal
treaty benefits under Article 21 (students and        If you have specific questions about a treaty,        (apply to both treaty countries); therefore, a U.S.
trainees) of the former treaty can continue to        you can get this information from most Internal       citizen or resident who receives income from a
apply that provision.                                 Revenue Service offices or from:                      treaty country may refer to the tables in this
                                                                                                            publication to see if a tax treaty might affect the
U.S. – Japan income tax treaty. Generally,                Internal Revenue Service                          tax to be paid to that foreign country. Foreign
the treaty is effective for tax periods beginning         International Returns Section                     taxing authorities sometimes require certifica-
on or after January 1, 2005. However, an individ-         P.O. Box 920                                      tion from the U.S. Government that an applicant
ual who was entitled to treaty benefits under             Bensalem, PA 19020-8518                           filed an income tax return as a U.S. citizen or
Article 19 (teachers and researchers) or Article                                                            resident, as part of the proof of entitlement to the
20 (students and trainees) of the former treaty         Tax questions. If you have a tax question,          treaty benefits. For more information, see Publi-
as of March 30, 2004, can continue to apply           check the information available on www.irs.gov        cation 686.
those provisions.                                     or call 1-800-829-1040.
                                                                                                            Disclosure of a treaty-based position that
                                                                                                            reduces your tax. If you take the position that
                                                      Useful Items                                          any U.S. tax is overruled or otherwise reduced
                                                      You may want to see:
                                                                                                            by a U.S. treaty (a treaty-based position), you
Introduction                                                                                                generally must disclose that position on Form
                                                        Publication
This publication will tell you whether a tax treaty                                                         8833 and attach it to your return. If you are not
between the United States and a particular              ❏ 519     U.S. Tax Guide for Aliens                 required to file a return because of your
country offers a reduced rate of, or possibly a                                                             treaty-based position, you must file a return any-
                                                        ❏ 597     Information on the United
complete exemption from, U.S. income tax for                                                                way to report your position. The filing of Form
                                                                  States – Canada Income Tax Treaty
residents of that particular country.                                                                       8833 does not apply to a reduced rate of with-
    Tables in the back of this publication show         ❏ 686     Certification for Reduced Tax Rates       holding tax on noneffectively connected income,
the countries that have income tax treaties with                  in Tax Treaty Countries                   such as dividends, interest, rents or royalties, or
the United States, the tax rates on different kinds                                                         to a reduced rate of tax on pay received for
                                                        Form (and Instructions)                             services performed as an employee, including
of income, and the kinds of income that are
                                                                                                            pensions, annuities, and social security. For
exempt from tax.                                         ❏ 8833 Treaty-Based Return Position
                                                                                                            more information, see Publication 519 and the
          You should use this publication only for               Disclosure Under Section 6114 or
                                                                                                            Form 8833 instructions.
                                                                 7701(b)
  !       quick reference. It is not a complete
                                                          See How To Get Tax Help near the end of
                                                                                                                If you fail to file Form 8833, you may have to
 CAUTION
          guide to all provisions of every income                                                           pay a $1,000 penalty. Corporations are subject
tax treaty.                                           this publication for information about getting
                                                                                                            to a $10,000 penalty for each failure.
                                                      these publications and forms.

Comments and suggestions. We welcome
your comments about this publication and your
suggestions for future editions.                                                                            Tax Exemptions
   You can write to us at the following address:
                                                                                                            Provided by Treaties
      Internal Revenue Service                                                                              In addition to the tables in the back of this publi-
      Individual Forms and Publications Branch                                                              cation, this publication contains discussions of
      SE: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 of
      Washington, 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 United
     formed in the United States.                          employer or company that is not a resident       States, they are taxed on the income attributable
                                                           of the United States, and                        to the fixed base.
  • Pay of a professor, teacher, or researcher
     who teaches or performs research in the             • The pay is not deductible in determining           Income that residents of Bangladesh receive
     United States for a limited time.                     the taxable income of the trade or busi-         for services performed in the United States as
                                                           ness 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 meet
     studies by a foreign student or apprentice
                                                                                                            the following requirements.
     who is here for study or experience.                These exemptions do not apply to public en-
  • Wages, salaries, and pensions paid by a            tertainers (such as theater, motion picture, ra-       • They are in the United States for no more
                                                       dio, or television entertainers, musicians, and           than 183 days in any 12-month period be-
     foreign government.
                                                       athletes) from Australia who earn more than               ginning or ending in the tax year.
                                                       $10,000 in gross receipts, including reimbursed        • Their income is paid by, or on behalf of, an
Personal Services Income                               expenses, from their entertainment activities in          employer who is not a U.S. resident.
                                                       the United States during the tax year.
Pay for certain personal services performed in                                                                • Their income is not borne by a permanent
the United States is exempt from U.S. income                                                                     establishment or a fixed base that the em-
tax if you are a resident of one of the countries      Austria                                                   ployer has in the United States.
discussed below, if you are in the United States
for a limited number of days, and if you meet          Income that residents of Austria receive for per-       These exemptions do not apply to pubic en-
certain other conditions. For this purpose, the        sonal services as independent contractors or         tertainers (such as theater, motion picture, ra-
word “day” means a day during any part of which        self-employed individuals (independent per-          dio, or television entertainers, musicians, and
you are physically present in the United States.       sonal services) in the United States is exempt       athletes) from Bangladesh who earn more than
                                                       from U.S. income tax if they do not have a fixed     $10,000 in gross receipts, including reimbursed
Terms defined. Several terms appear in                 base regularly available to them in the United       expenses, from their entertainment activities in
many of the discussions that follow. The exact         States for performing the services. If they have a   the United States during the tax year. Regard-
meanings of the terms are determined by the            fixed base available in the United States, they      less of these limits, income of Bangladesh enter-
particular tax treaty under discussion; thus, the      are taxed on the income attributable to the fixed    tainers is exempt from U.S. income tax if their
meanings vary among treaties. The definitions          base.                                                visit to the United States is wholly or mainly
that follow are, therefore, general definitions that       Income that residents of Austria receive for     supported by public funds of Bangladesh, its
may not give the exact meaning intended by a           services performed in the United States as em-       political subdivisions, or local authorities.
particular treaty.                                     ployees (dependent personal services) is ex-             Income received from employment as a
                                                       empt from U.S. income tax if the residents meet
    The terms fixed base and permanent estab-                                                               member of the regular complement of a ship or
                                                       the following requirements.
lishment generally mean a fixed place of busi-                                                              an aircraft operated by a Bangladesh enterprise
ness, such as a place of management, a branch,           • They are in the United States for no more        in international traffic is exempt from U.S. tax. If
an office, a factory, a warehouse, or a mining             than 183 days in any 12-month period be-         the ship or aircraft is operated by a U.S. enter-
site, through which an enterprise carries on its           ginning or ending in the tax year.               prise, the income is subject to U.S. tax.
business.                                                • Their income is paid by, or on behalf of, an         If the resident of Bangladesh is a share-
    The term borne by generally means having               employer who is not a U.S. resident.             holder in a U.S. corporation, these exemptions
ultimate financial accounting responsibility for or                                                         do not apply to director’s fees received as a
providing the monetary resources for an expen-           • Their income is not borne by a permanent         member of the board of directors of the U.S.
diture or payment, even if another entity in an-           establishment or a fixed base that the em-       corporation. The amount received by the share-
other location actually made the expenditure or            ployer has in the United States.                 holder that is more than the amount paid to a
payment.                                                                                                    director that is not a shareholder is subject to
                                                          These exemptions do not apply to public en-       U.S. tax at the rate of 15%.
                                                       tertainers (such as theater, motion picture, ra-
Australia                                              dio, or television entertainers, musicians, and
                                                       athletes) from Austria who earn more than            Barbados
Income that residents of Australia receive for         $20,000 in gross receipts, including reimbursed
performing personal services as independent            expenses, from their entertainment activities in     Income that residents of Barbados receive for
contractors or self-employed individuals (inde-        the United States during the tax year.               performing personal services as independent
pendent personal services) in the United States            Income received by a resident of Austria for     contractors or self-employed individuals (inde-
during the tax year is exempt from U.S. income         services performed as an employee and mem-           pendent personal services) in the United States
tax if the residents:                                  ber of the regular complement of a ship or air-      during the tax year is exempt from U.S. income
                                                       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.
     183 days during the tax year, and                                                                        • Are in the United States for no more than
                                                                                                                 89 days during the tax year,
  • Do not have a fixed base regularly avail-
     able to them in the United States for the         Bangladesh                                             • Earn net income for independent services
     purpose of performing the services.                                                                         provided to U.S. residents that is not more
                                                       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), and
States, they are taxed on the income attributable      contractors or self-employed individuals (inde-
to the fixed base.                                     pendent personal services) in the United States        • Do not have a regular base available in
                                                       during the tax year is exempt from U.S. income            the United States for performing the serv-
  Pay that residents of Australia receive for la-
                                                       tax if the residents:                                     ices.
bor or personal services performed in the United
States as employees (dependent personal serv-            • Are in the United States for no more than        If they have a regular base available in the
ices), including services as a director of a com-          183 days in any 12-month period begin-           United States but otherwise meet the conditions
pany, is exempt from U.S. income tax if:                   ning or ending in the tax year, or               for exemption, they are taxed only on the income
                                                                                                            attributable to the regular base.
  • The residents are in the United States for           • Do not have a fixed base regularly avail-
     no more than 183 days during the tax                  able to them in the United States for the          Income that residents of Barbados receive for
     year,                                                 purpose of performing the services.              personal services performed in the United



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 available
ices) is exempt from U.S. tax if the residents         tertainers (such as theater, motion picture, ra-           in the United States, they are taxed on the in-
meet four requirements.                                dio, or television artists, musicians, or athletes)        come attributable to the fixed base.
                                                       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,
     than 183 days during the calendar year.                                                                      personal services performed as employees (de-
                                                       from their entertainment activities in the United          pendent personal services) in the United States
  • The income earned in the calendar year in          States during the tax year.                                is exempt from U.S. tax if it is not more than
     the United States is not more than $5,000.            Income received by a resident of Belgium for           $10,000 for the year. If the income is more than
                                                       services 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.                       craft operated in international traffic is exempt            • The residents are present in the United
  • The income is not borne by a permanent             from U.S. income tax.                                           States for no more than 183 days during
                                                                                                                       the calendar year, and
     establishment or regular base of the em-
     ployer in the United States.                      Former treaty. Income that residents of                      • The income is not borne by a U.S. resi-
                                                       Belgium receive for performing personal serv-                   dent employer or by a permanent estab-
   Income of a Barbadian resident from employ-         ic es as i n d e p e n d e n t c o n t r a c t o r s o r        lishment or fixed base of an employer in
ment as a member of the regular complement of          self-employed individuals (independent per-                     the United States.
a ship or aircraft operated in international traffic   sonal services) in the United States during the
is exempt from U.S. tax.                               tax year is exempt from U.S. income tax if the                These exemptions do not apply to public en-
                                                       residents:                                                 tertainers (such as theater, motion picture, ra-
    These exemptions do not apply to Barbadian
resident public entertainers (such as theater,           • Are present in the United States less than             dio, or television artists, musicians, or athletes)
motion picture, radio, or television artists, musi-         183 days during the tax year, and                     from Canada who derive more than $15,000 in
                                                                                                                  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 United
more than $250 per day or $4,000 in the tax                 States for a period or periods that total
year, not including reimbursed expenses, from                                                                     States during the calendar year. However, the
                                                            more than 182 days during the tax year.
their entertainment activities in the United                                                                      exemptions do apply, regardless of this $15,000
States. However, the exemptions do apply re-           If they do not meet condition (2), they are taxed          limit, to athletes participating in team sports in
gardless of these limits on gross receipts if the      on the income attributed to the fixed base.                leagues with regularly scheduled games in both
entertainer’s visit to the United States is sub-                                                                  Canada and the United States.
                                                           The exemption for independent personal
stantially supported by Barbadian public funds         services does not apply to individuals who are                 Pay received by a resident of Canada for
or if the entertainer’s services are provided to a     public entertainers (theater, motion picture, or           employment regularly done in more than one
nonprofit organization.                                television artists, musicians, or athletes), if they       country on a ship, aircraft, motor vehicle, or train
                                                       are in the United States for more than 90 days             operated by a Canadian resident is exempt from
                                                       during the tax year or if their pay for services as        U.S. tax.
Belgium                                                public entertainers is more than $3,000.
                                                            Income that residents of Belgium receive for
                                                       labor or personal services performed in the                China, People’s Republic of
   Note. See the effective dates of the new            United States as employees (dependent per-
treaty under What’s New at the beginning of this                                                                  Income that residents of the People’s Republic
                                                       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.
New treaty. Income that residents of Belgium                                                                      als (independent personal services) that they
receive for personal services as independent             • They are present in the United States less             perform during the tax year in the United States
contractors or self-employed individuals are                than 183 days during the tax year.                    is exempt from U.S. income tax if the residents:
subject to the provisions of Article 7 (Business         • They are employees of a resident of                      • Are present in the United States for no
Profits) of the treaty. Under that provision, busi-         Belgium or of a permanent establishment                    more than 183 days in the calendar year,
ness profits are exempt from U.S. income tax                in Belgium.                                                and
unless they have a permanent establishment in
                                                         • Their income is not borne by a permanent                 • Do not have a fixed base regularly avail-
the United States. If they have a permanent
                                                            establishment that the employer has in the                 able in the United States for performing
establishment available in the United States,
                                                            United States.                                             the services.
they are taxed on the income attributable to the
permanent establishment.                                                                                          If they have a fixed base available in the United
                                                          Income for services performed by an individ-
   Income that residents of Belgium receive for                                                                   States, they are taxable on the income attributa-
                                                       ual as an employee aboard a ship or an aircraft
services performed in the United States as em-                                                                    ble to the fixed base.
                                                       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’s
empt 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 as
the following requirements.                            regular complement of the ship or aircraft.                employees (dependent personal services) in the
  • They are in the United States for no more              These exemptions do not apply to fees re-              United States is exempt from U.S. tax if:
                                                       ceived by a resident of Belgium for services
     than 183 days in any 12-month period be-
                                                       performed as a director of a U.S. corporation if
                                                                                                                    • The residents are present in the United
     ginning or ending in the tax year.                                                                                States for no more than 183 days in the
                                                       the 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 the
     employer 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 permanent
     establishment that the employer has in the
                                                       Canada                                                       • The pay is not borne by a permanent es-
     United States.                                                                                                    tablishment or fixed base that the em-
                                                       Income that residents of Canada receive for                     ployer has in the United States.
   The exemption does not apply to directors’          personal services as independent contractors or
fees and similar payments received by a resi-          self-employed individuals (independent per-                  These exemptions do not apply to directors’
dent of Belgium for services performed in the          sonal services) that they perform during the tax           fees for service on the board of directors of a
United States as a member of the board of              year in the United States is exempt from U.S. tax          U.S. corporation.
directors of a company that is a resident of the       if they do not have a fixed base regularly avail-             These exemptions generally do not apply to
United States.                                         able to them in the United States for performing           income received as a public entertainer (such as

Page 4                                                                                                                              Publication 901 (April 2008)
a theater, motion picture, radio, or television         Czech Republic                                           Income that residents of Denmark receive for
artist, musician, or athlete). However, income of                                                             services performed in the United States as em-
athletes or public entertainers from China partic-      Income that residents of the Czech Republic           ployees (dependent personal services) is ex-
ipating in a cultural exchange program agreed           receive for performing personal services as in-       empt from U.S. income tax if the residents meet
upon by the U.S. and Chinese governments is             dependent contractors or self-employed individ-       the following requirements.
exempt from U.S. tax.                                   uals (independent personal services) in the
                                                        United States is exempt from U.S. income tax if         • They are in the United States for no more
                                                        the residents:                                             than 183 days in any 12-month period be-
Commonwealth of                                                                                                    ginning or ending in the tax year.
                                                          • Are present in the United States for no
Independent States
                                                            more than 183 days in any 12-month pe-              • Their income is paid by, or on behalf of, an
                                                            riod, and                                              employer who is not a U.S. resident.
Income that residents of a C.I.S. member re-
ceive for performing personal services in the             • Do not have a fixed base regularly avail-           • Their income is not borne by a permanent
United States is exempt from U.S. income tax if             able to them in the United States for per-             establishment or a fixed base that the em-
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.
   Pay received by an employee who is a mem-            If they have a fixed base available, they are            These exemptions do not apply to directors’
ber of the regular complement of a ship or air-         taxed only on income attributable to the fixed        fees and similar payments received by a resi-
craft operated in international traffic by a C.I.S.     base.                                                 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 the
                                                          Income that residents of the Czech Republic
exempt from U.S. tax.                                                                                         United States.
                                                        receive for employment in the United States
                                                        (dependent personal services) is exempt from              These exemptions do not apply to public
                                                        U.S. income tax if the following three require-       entertainers (such as theater, motion picture,
Cyprus                                                                                                        radio, or television artists, musicians, and ath-
                                                        ments are met.
Income that residents of Cyprus receive for per-                                                              letes) from Denmark who earn more than
                                                          • The resident is present in the United             $20,000 in gross receipts, including reimbursed
forming personal services as independent con-               States for no more than 183 days in any
tract ors o r se lf-em ploy ed indiv iduals                                                                   expenses, from their entertainment activities in
                                                            12-month period.                                  the United States during the tax year.
(independent personal services) in the United
States during the tax year is exempt from U.S.            • The income is paid by, or on behalf of, an            Income received by a resident of Denmark
income tax if the residents:                                employer who is not a U.S. resident.              for services performed as an employee and
                                                                                                              member of the regular complement of a ship or
  • Are present in the United States for less             • The income is not borne by a permanent            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            Egypt
     forming 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
   Pay received by residents of Cyprus from             bursed expenses, are more than $20,000 during         (independent personal services) in the United
services performed as employees (dependent              the tax year. Regardless of these limits, income      States during the tax year is exempt from U.S.
personal services), including services as an of-        of Czech entertainers and sportsmen is exempt         income tax if they are in the United States for no
ficer of a corporation, is exempt from U.S. in-         from U.S. income tax if their visit to the United     more than 89 days during the tax year.
come tax if:                                            States is substantially supported by public funds         Income that residents of Egypt receive for
                                                        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 services
  • The pay is paid by or for an employer who           States and the Czech Republic.                        performed by an officer of a corporation or com-
     is not a U.S. resident, and                             These exemptions do not apply to directors’      pany, is exempt from U.S. income tax if the
  • The pay is not borne by a permanent es-             fees and similar payments received by a resi-         residents meet four requirements.
                                                        dent of the Czech Republic as a member of the
     tablishment, fixed base, or trade or busi-                                                                 • They are in the United States for no more
     ness that the employer has in the United           board of directors of a company that is a resident         than 89 days during the tax year.
     States.                                            of the United States.
                                                             Income from employment as a member of              • They are employees of a resident of, or a
   Pay received by a Cyprus resident for per-           the regular complement of a ship or aircraft               permanent establishment in, Egypt.
forming personal services as an employee and            operated by a Czech enterprise in international         • Their income is not borne by a permanent
member 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 the
aircraft 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.
    These exemptions do not apply to Cyprus                                                                     • Their income is subject to Egyptian tax.
resident public entertainers (theater, motion pic-
ture, radio, or television artists, musicians, or       Denmark                                                  This exemption does not apply to pay re-
athletes) who receive gross receipts of more                                                                  ceived by a resident of Egypt who is an em-
than $500 per day or $5,000 for the tax year, not       Income that residents of Denmark receive for          ployee and member of the regular complement
including reimbursed expenses, from their en-           personal services as independent contractors or       of a ship or an aircraft operated in international
tertainment activities in the United States.            self-employed individuals (independent per-           traffic by a resident of the United States.
    Directors’ fees received by residents of Cy-        sonal services) in the United States is exempt             These exemptions do not apply to Egyptian
prus for service on the board of directors of a         from U.S. income tax if they do not have a fixed      resident public entertainers (theater, motion pic-
U.S. corporation are exempt from U.S. income            base regularly available to them in the United        ture, radio, or television artists, musicians, or
tax to the extent of a reasonable fixed amount          States for performing the services. If they have a    athletes), who earn income for services as pub-
payable to all directors for each day of attend-        fixed base available in the United States, they       lic entertainers if the gross amount of the income
ance at directors’ meetings held in the United          are taxed on the income attributable to the fixed     is more than $400 for each day they are in the
States.                                                 base.                                                 United States performing the services.

Publication 901 (April 2008)                                                                                                                              Page 5
Estonia                                                    • They are in the United States for no more                      Germany
                                                              than 183 days during any 12-month pe-
Income that residents of Estonia receive for per-             riod.
forming personal services as independent con-                                                                                 Note. See the effective dates of the protocol
tract ors o r se lf-em ploy ed indiv iduals                • Their income is paid by, or on behalf of, an                   under What’s New at the beginning of this publi-
(independent personal services) in the United                 employer who is not a resident of the                         cation.
States is exempt from U.S. income tax if the                  United States.
                                                                                                                            Treaty as modified. Income that residents of
residents:                                                 • Their income is not borne by a permanent                       Germany receive for personal services as inde-
  • Are in the United States for no more than                 establishment, fixed base, or trade or busi-                  pendent contractors or self-employed individu-
     183 days in any 12-month period begin-                   ness that the employer has in the United                      als are subject to the provisions of Article 7
     ning or ending in the tax year, and                      States.                                                       (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 permanent
     able 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 have
     forming 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 income
taxed on the income attributable to the fixed           dent of the United States.                                          attributable to the permanent establishment.
base.                                                       These exemptions do not apply to income                             Income that residents of Germany receive
                                                        residents of Finland receive as public entertain-                   for labor or personal services performed in the
  Income that residents of Estonia receive for
                                                        ers or sportsmen if the gross income, including                     United States as employees (dependent per-
services performed in the United States as em-
                                                        reimbursed expenses, is more than $20,000 for                       sonal services) is exempt from U.S. tax if the
ployees (dependent personal services) is ex-
                                                        their personal activities in the United States dur-                 residents meet three requirements.
empt from U.S. income tax if the following
requirements are met.                                   ing the calendar year.                                                • They are in the United States for no more
                                                                                                                                 than 183 days during the calendar year.
  • The resident is in the United States for no
     more than 183 days in any 12-month pe-             France                                                                • The income is paid by, or on behalf of, an
     riod beginning or ending in the tax year.                                                                                   employer who is not a resident of the
                                                        Income that residents of France receive for per-                         United States.
  • The income is paid by, or on behalf of, an
                                                        forming personal services as independent con-
     employer who is not a U.S. resident.                                                                                     • The income is not borne by a permanent
                                                        t r ac t or s o r s e l f - e m p l o y e d i n d i v i d u a l s
                                                                                                                                 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 for
                                                        in 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 exempt
dent 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 in
of 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 of
operated in international traffic by a United
                                                        the residents meet three requirements.                              directors of a company resident in the United
States enterprise is subject to U.S. tax.
                                                                                                                            States.
    These exemptions do not apply to income                • They are in the United States for no more
                                                                                                                                The exemption does not apply to income
residents of Estonia receive as public entertain-             than 183 days in any 12-month period.
                                                                                                                            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, or
television artists, or musicians) or sportsmen if
                                                              employer who is not a resident of the                         television artists, or musicians) or athletes if
their gross receipts, including reimbursed ex-
                                                              United States.                                                their gross receipts, including reimbursed ex-
penses, are more than $20,000 for their per-
                                                                                                                            penses, are more than $20,000 during the cal-
sonal activities in the United States during the           • Their income is not borne by a permanent                       endar year. Regardless of these limits, income
tax year. Regardless of these limits, income of               establishment or a fixed base that the em-
                                                                                                                            of German entertainers or athletes is exempt
Estonian entertainers or athletes is exempt from              ployer has in the United States.
                                                                                                                            from U.S. tax if their visit to the United States is
U.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-
                                                        ated in international traffic is exempt from tax in                 Unmodified treaty. Generally, the previous
                                                        the United States.                                                  discussion, other than the first paragraph, ap-
Finland                                                     These exemptions do not apply to public                         plies to the unmodified treaty. Under that treaty,
                                                        entertainers (such as theater, motion picture,                      the first paragraph would be as follows.
Income that residents of Finland receive for per-                                                                               Income that residents of Germany receive
forming personal services as independent con-           radio, or television artists, or musicians), or
                                                        sportsmen from France who earn more than                            for personal services as independent contrac-
tract ors o r se lf-em ploy ed indiv iduals                                                                                 tors or self-employed individuals (independent
(independent personal services) in the United           $10,000 in gross receipts, including reimbursed
                                                        expenses, from their entertainment activities in                    personal services) in the United States is ex-
States is exempt from U.S. income tax if they do                                                                            empt from U.S. income tax if the income is not
not have a fixed base regularly available to them       the United States during the tax year. Regard-
                                                        less of these limits, income of French entertain-                   attributable to a fixed base regularly available in
in the United States for performing the services.                                                                           the United States.
If they have a fixed base available in the United       ers or sportsmen is exempt from U.S. tax if their
States, they are taxed on the income attributable       visit is principally supported by public funds of
to the fixed base.                                      France.
                                                                                                                            Greece
     Income that residents of Finland receive for           These exemptions do not apply to directors’
labor or personal services performed in the             fees and similar payments received by a resi-                       Income that residents of Greece receive for la-
United States as employees (dependent per-              dent of France as a member of the board of                          bor or personal services (including practicing
sonal services) is exempt from U.S. income tax if       directors of a company that is a resident of the                    liberal and artistic professions) is exempt from
the residents meet three requirements.                  United States.                                                      U.S. income tax if they are in the United States

Page 6                                                                                                                                        Publication 901 (April 2008)
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-
and the pay is not more than $10,000. The pay,          than $100 per day.                                   sion artists, or musicians) or athletes if their net
regardless of amount, is exempt from U.S. in-              Income that residents of Iceland receive for      income is more than $1,500 during the tax year
come tax if it is for labor or personal services        labor or personal services performed in the          for their entertainment activities in the United
performed as employees of, or under contract            United States as employees (dependent per-           States. Regardless of this limit, the income of
with, a resident of Greece or a Greek corpora-          sonal services) is exempt from U.S. income tax if    Indian entertainers and athletes is exempt from
tion or other entity of Greece, and if the residents    the employees meet three requirements:               U.S. tax if their visit to the United States is wholly
are in the United States for no more than 183                                                                or substantially supported from the public funds
days during the tax year.                                 • They are in the United States for no more        of the Indian Government, its political subdivi-
                                                            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
                                                            resident of a state other than Iceland if the    Indonesia
Income that residents of Hungary receive for
                                                            permanent establishment is located in Ice-       Income that residents of Indonesia receive for
performing personal services as independent
                                                            land.                                            performing personal services as individual con-
contractors or self-employed individuals (inde-
pendent personal services) in the United States           • Their income is not borne by a permanent         tractors or self-employed individuals (indepen-
during the tax year is exempt from U.S. tax if the          establishment that the employer has in the       dent personal services) in the United States
residents:                                                  United States.                                   during the tax year is exempt from U.S. income
                                                                                                             tax if the residents:
  • Are in the United States for no more than
     183 days during the tax year, and
                                                            Income for services performed by an em-            • Are present in the United States for no
                                                        ployee 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
                                                        if the individual is a member of the regular com-      • Do not have a fixed base regularly avail-
If they have a fixed base available in the United                                                                 able to them in the United States for per-
States, they are taxed on the income attributable       plement of the ship or aircraft.
                                                                                                                  forming the services.
to the fixed base.
  Income that residents of Hungary receive for          India                                                  If they have a fixed base available, they are
labor or personal services performed in the                                                                  taxed only on the income attributable to the fixed
United States as employees (dependent per-              Income that residents of India receive for per-      base.
sonal services) is exempt from U.S. income tax if       forming personal services in the United States           Income that residents of Indonesia receive
the residents meet three requirements.                  during the tax year as independent contractors       for personal services performed in the United
                                                        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.                 the residents:                                       sidents meet three requirements.
  • Their income is paid by or on behalf of an            • Are present in the United States for no            • They are present in the United States 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              • Do not have a fixed base regularly avail-          • The income is paid by, or on behalf of, an
     establishment or a fixed base that the em-                                                                   employer who is not a resident of the
                                                            able to them in the United States for per-
     ployer has in the United States.                                                                             United States.
                                                            forming the services.
   Pay received by an employee who is a mem-                                                                   • The income is not borne or reimbursed by
                                                          If they have a fixed base available, they are           a permanent establishment the employer
ber 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 in
                                                        base.
international traffic is exempt from U.S. tax. If the
ship or aircraft is operated by a U.S. enterprise,          Income that residents of India receive for          Pay received by an individual for services
the pay is subject to U.S. tax.                         personal services performed in the United            performed as an employee aboard a ship or
                                                        States as employees (dependent personal serv-        aircraft operated by an Indonesian resident in
                                                        ices) is exempt from U.S. income tax if the re-      international traffic is exempt from U.S. tax if the
Iceland                                                 sidents meet three requirements.                     individual is a member of the regular comple-

Income that residents of Iceland receive for per-
                                                          • They are present in the United States for        ment of the ship or aircraft.
                                                            no more than 183 days during the tax                 These exemptions do not apply to income
forming personal services as independent con-                                                                residents of Indonesia receive as public enter-
                                                            year.
tract ors o r se lf-em ploy ed 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 if
States 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-
  • Are present in the United States for no               • The income is not borne by a permanent           secutive 12-month period. Regardless of these
     more than 182 days during the tax year,                establishment, fixed base, or trade or busi-     limits, income of Indonesian entertainers and
     and                                                    ness the employer has in the United              athletes is exempt from U.S. tax if their visit to
                                                            States.                                          the United States is substantially supported or
  • 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 that
                                                           The exemption does not apply to pay received
     more than 182 days during the tax year.                                                                 the entertainers or athletes qualify for this ex-
                                                        by a resident of India for services performed as
If they do not meet condition (2), they are taxed       an employee aboard a ship or aircraft operated       emption.
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
  This exemption does not apply to residents of         fees and similar payments received by an Indian
Iceland who are public entertainers (theater,           resident as a member of the board of directors of    Income that residents of Ireland receive for per-
motion picture, or television artists, musicians,       a company that is a U.S. resident.                   sonal services as independent contractors or
or athletes) if they are in the United States for           These exemptions do not apply to income          self-employed individuals (independent per-
more than 90 days during the tax year or their          residents of India receive as public entertainers    sonal services) in the United States is exempt

Publication 901 (April 2008)                                                                                                                              Page 7
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 is
base regularly available to them in the United       that residents of Israel receive as public enter-           not more than $5,000 during the tax year if
States for performing the services. If they have a   tainers (such as theater, motion picture, radio, or         the income is from a U.S. contractor.
fixed base available in the United States, they      television artists, musicians, or athletes), if the
                                                                                                            If they have a fixed base available in the United
are 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 is
base.                                                for each day they are in the United States per-        attributable to the fixed base. There is no dollar
    Income that residents of Ireland receive for     forming the services.                                  limit for condition (3) if the contractor is from a
services performed in the United States as em-                                                              country other than the United States.
ployees (dependent personal services) is ex-
empt from U.S. income tax if the residents meet      Italy                                                     Income that residents of Jamaica receive for
the following requirements.                                                                                 personal services performed in the United
                                                     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 more
  • Their income is paid by, or on behalf of, an     sonal services) is exempt from U.S. income tax if
                                                                                                                 than 183 days during the tax year.
    employer who is not a U.S. resident.             the residents:
                                                       • Are present in the United States for no              • Their income is paid by or for an employer
  • Their income is not borne by a permanent                                                                     who is not a resident of the United States.
    establishment or a fixed base that the em-            more than 183 days in the tax year, and
    ployer has in the United States.                   • Do not have a fixed base regularly avail-            • Their income is not borne by a permanent
                                                                                                                 establishment or a fixed base that the em-
                                                          able to them in the United States for per-
   These exemptions do not apply to directors’                                                                   ployer has in the United States.
                                                          forming the services.
fees and similar payments received by a resi-                                                                 • Their net income received for the services
dent of Ireland as a member of the board of          If they have a fixed base available, they are
                                                                                                                 is not more than $5,000 during the tax
directors of a company that is a resident of the     taxed only on the income attributable to the fixed
                                                                                                                 year.
United States. However, amounts received for         base.
attending meetings in Ireland are not subject to       Income that residents of Italy receive for per-         Pay received from employment as a member
U.S. income tax.                                     sonal services performed in the United States as       of the regular complement of a ship or an aircraft
    Income received by a resident of Ireland for     employees (dependent personal services) is ex-         operated in international traffic by a Jamaican
services performed as an employee and mem-           empt from U.S. income tax if:                          enterprise is exempt from U.S. tax. If the ship or
ber of the regular complement of a ship or air-                                                             aircraft is operated by a U.S. enterprise, the pay
craft operated in international traffic is exempt      • The residents are present in the United            is subject to U.S. tax.
from U.S. income tax.                                     States for not more than 183 days during
                                                                                                                These exemptions do not apply to income
                                                          the tax year,
    These exemptions do not apply to public                                                                 that residents of Jamaica receive for performing
entertainers (such as theater, motion picture,         • The income is paid by or for an employer           services in the United States as entertainers,
radio, or television entertainers, musicians, and         who is not a U.S. resident, and                   such as theater, motion picture, radio, or televi-
athletes) from Ireland who earn more than                                                                   sion artists, musicians, or athletes, if the gross
$20,000 in gross receipts, including reimbursed
                                                       • The income is not borne by a permanent             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 a
                                                          ployer has in the United States.
the United States during the tax year.                                                                      day or $5,000 for 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 United
Israel                                               ployment regularly exercised aboard a ship or
                                                                                                            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
Income that residents of Israel receive for per-     national traffic is exempt from U.S. tax.
                                                                                                            (excluding reimbursed expenses) are not more
forming personal services as independent con-            These exemptions do not apply to directors’        than $400 per day for each day the directors are
tractors 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 income
more 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-
labor or personal services performed in the          sion artists, musicians, or athletes) if they are      Income that residents of Japan receive for per-
United States as employees (dependent per-           present in the United States for more than 90          sonal services as independent contractors or
sonal services), including income for services       days during the tax year or their gross receipts,      self-employed individuals is subject to the provi-
performed by an officer of a corporation or com-     including reimbursed expenses, are more than           sions of Article 7 (business profits) of the treaty.
pany, is exempt from U.S. income tax if the          $12,000 during the tax year for their entertain-       Under that provision, business profits are ex-
residents meet four requirements.                    ment activities in the United States.                  empt from U.S. income tax unless they have a
                                                                                                            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-
                                                     Jamaica
  • They are employees of a resident of, or a                                                               come attributable to the permanent establish-
    permanent establishment in, Israel.              Income that residents of Jamaica receive for the       ment.
                                                     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 meet
  • Their income is subject to Israeli tax.          income tax if the residents:                           the following requirements.
                                                       • Are in the United States for no more than            • They are in the United States for no more
   The exemption does not apply to pay received
                                                          89 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, an
tional traffic by a U.S. resident.                        forming their services, and                            employer who is not a U.S. resident.

Page 8                                                                                                                        Publication 901 (April 2008)
  • 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 in
    establishment that the employer has in the             182 days during the tax year,                                 international traffic by a U.S. enterprise.
    United States.
                                                        • Earn income for those services that is not                         The exemptions do not apply to directors’
                                                           more than $3,000 during the tax year, and                     fees and similar payments received by a resi-
   The 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 a
dent 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 entertainers
                                                     If they maintain a fixed base in the United States
    The exemption does not apply to a resident       for more than 182 days, they are taxed on the                       (such as theater, motion picture, radio, or televi-
of Japan who performs services as an employee        income attributable to the fixed base.                              sion artists, or musicians) or sportsmen if their
aboard a ship or an aircraft operated in interna-                                                                        gross receipts, including reimbursed expenses,
tional traffic by a U.S. resident.                      Income that residents of Korea receive for                       are more than $20,000 for their personal activi-
    These exemptions do not apply to public          labor or personal services performed in the                         ties in the United States during the tax year.
entertainers (such as theater, motion picture,       United States as employees (dependent per-                          Regardless of these limits, income of Latvian
radio, or television artists, musicians, or ath-     sonal services), including pay for services per-                    entertainers or athletes is exempt from U.S. in-
letes) from Japan who earn more than $10,000         formed as an officer of a corporation, is exempt                    come tax if their visit to the United States is
in gross receipts, including reimbursed ex-          from U.S. tax if the residents meet four require-                   wholly or mainly supported by public funds of
penses, from their entertainment activities in the   ments.                                                              Latvia, its political subdivisions, or local authori-
United States during the tax year.                      • They are in the United States for no more                      ties.
                                                           than 182 days during the tax year.

Kazakhstan                                              • They are employees of a resident of Korea                      Lithuania
                                                           or of a permanent establishment main-
Income that residents of Kazakhstan receive for            tained in Korea.                                              Income that residents of Lithuania receive for
performing personal services as independent                                                                              performing 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 States
pendent personal services) in the United States
                                                           has 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 for             more than $3,000.
    no more than 183 days in any consecutive                                                                                  183 days in any 12-month period begin-
    12-month period, and                                                                                                      ning or ending in the tax year, and
                                                        Pay received by employees who are mem-
  • The income is not attributable to a fixed        bers of the regular complement of a ship or                           • Do not have a fixed base regularly avail-
    base in the United States which is regu-         aircraft operated by a resident of Korea in inter-                       able to them in the United States for per-
    larly available to the residents.                national traffic is exempt.                                              forming the services.

If the residents have a fixed base available, they                                                                       If they have a fixed base available, they are
are taxed only on the income attributable to the                                                                         taxed only on the income attributable to the fixed
                                                     Latvia                                                              base.
fixed base.
  Income that residents of Kazakhstan receive        Income that residents of Latvia receive for per-                      Income that residents of Lithuania receive for
for employment in the United States (dependent       forming personal services as independent con-                       services performed in the United States as em-
personal services) is exempt from U.S. income        t r ac t or s o r s e l f - e m p l o y e d i n d i v i d u a l s   ployees (dependent personal services) is ex-
tax if the following three requirements are met.     (independent personal services) in the United                       empt from U.S. income tax if the following
                                                     States is exempt from U.S. income tax if the                        requirements are met.
  • The resident is in the United States for no      residents:
    more than 183 days in any 12-month pe-                                                                                 • The resident is in the United States for no
    riod.                                               • Are in the United States for no more than                           more than 183 days in any 12-month pe-
                                                           183 days in any 12-month period begin-                             riod beginning or ending in the tax year.
  • The income is paid by, or on behalf of, an
    employer who is not a resident of the
                                                           ning or ending in the tax year, and                             • The income is paid by, or on behalf of, an
    United States.                                      • Do not have a fixed base regularly avail-                           employer who is not a U.S. resident.

  • The income is not borne by a permanent
                                                           able to them in the United States for per-                      • 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-
                                                     If they have a fixed base available, they are                            ployer has in the United States.
    ployer has in the United States.
                                                     taxed only on the income attributable to the fixed
                                                     base.                                                                  The exemption does not apply to pay received
   Income derived by a resident of Kazakhstan
                                                                                                                         for employment as a member of the regular
from employment as a member of the regular             Income that residents of Latvia receive for                       complement of a ship or an aircraft operated in
complement 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-
    These exemptions do not apply to directors’                                                                              The 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 of
dent of Kazakhstan as a member of the board of
directors or similar body of a company that is a        • The resident is in the United States for no                    directors or similar body of a company that is a
                                                           more than 183 days in any 12-month pe-                        U.S. resident.
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, an
Korea, Republic of                                                                                                       ers (such as theater, motion picture, radio, or
                                                           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 in-            establishment 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 the
uals (independent personal services) in the                                                                              tax year. Regardless of these limits, income of
United States during the tax year is exempt from       The exemption does not apply to pay received                      Lithuanian entertainers or athletes is exempt
U.S. tax if the residents:                           for employment as a member of the regular                           from U.S. income tax if their visit to the United

Publication 901 (April 2008)                                                                                                                                          Page 9
States is wholly or mainly supported by public          • The resident is present in the United              a corporation does not qualify for this exemp-
funds of Lithuania, its political subdivisions, or         States for no more than 183 days in a             tion.
local authorities.                                         12-month period.                                      Income received by an individual for per-
                                                                                                             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
Luxembourg                                                                                                   international traffic by a Moroccan resident is
                                                           United States.                                    exempt from U.S. income tax if the individual is a
Income that residents of Luxembourg receive for         • The income is not borne by a permanent             member of the regular complement of the ship or
personal services as independent contractors or            establishment or fixed base that the em-          aircraft.
self-employed individuals (independent per-                ployer has in the United States.                      These exemptions do not apply to income
sonal services) in the United States is exempt                                                               received for services performed in the United
from U.S. income tax if they do not have a fixed         These exemptions do not apply to director’s         States by professional entertainers, including
base regularly available to them in the United        fees and similar payments received by a resi-          theater, film, radio, and television performers,
States for performing the services. If they have a    dent of Mexico for services performed outside          musicians, and athletes, unless the services are
fixed base available in the United States, they       Mexico as a director or overseer of a company          performed by, or for the account of, a Moroccan
are taxed on the income attributable to the fixed     that is a U.S. resident.                               nonprofit organization.
base.                                                     These exemptions do not apply to income
   Income that residents of Luxembourg re-            residents of Mexico receive as public entertain-
                                                      ers (such as theater, motion picture, radio, or
                                                                                                             Netherlands
ceive for services performed in the United
States as employees (dependent personal serv-         television artists, or musicians) or athletes if the   Income that residents of the Netherlands re-
ices) is exempt from U.S. income tax if the re-       income, including reimbursed expenses, is              ceive for performing personal services as inde-
sidents meet the following requirements.              more than $3,000 during the tax year for their         pendent contractors or self-employed
                                                      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 fixed
    ginning or ending in the tax year.                athlete’s reputation, such as endorsements of          base in the United States that is regularly avail-
  • Their income is paid by, or on behalf of, an      commercial products. Regardless of this limit,         able for performing the services.
    employer who is not a U.S. resident.              the income of Mexican entertainers and athletes            Income that residents of the Netherlands re-
                                                      is exempt from U.S. tax if their visit to the United   ceive for employment in the United States (de-
  • Their income is not borne by a permanent          States is substantially supported by public funds      pendent personal services) is exempt from U.S.
    establishment or a fixed base that the em-        of Mexico, its political subdivisions, or local au-    income tax if the following three requirements
    ployer has in the United States.                  thorities.                                             are met.

   The exemption does not apply to pay received                                                                • The resident is in the United States for no
for employment exercised continuously or                                                                         more than 183 days during the tax year.
                                                      Morocco
predominantly aboard a ship or aircraft operated                                                               • The income is paid by, or on behalf of, an
in international traffic by a U.S. enterprise.        Income that residents of Morocco receive for               employer who is not a U.S. resident.
                                                      performing personal services as independent
    The exemptions do not apply to directors’
                                                      contractors or as self-employed persons (inde-           • The income is not borne by a permanent
fees and similar payments received by a resi-                                                                    establishment or fixed base the employer
                                                      pendent personal services) in the United States
dent of Luxembourg for services performed in                                                                     has in the United States.
                                                      during the tax year is exempt from U.S. income
the United States as a member of the board of
                                                      tax if the residents:
directors of a company that is a resident of the                                                                Income received by a Netherlands resident for
United States.                                          • Are in the United States for no more than          employment as a member of the regular com-
    The exemptions do not apply to public enter-           182 days during the tax year,                     plement of a ship or aircraft operated in interna-
                                                                                                             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
television artists, musicians, or athletes) from                                                                 These exemptions do not apply to directors’
                                                           States for more than 89 days during the
Luxembourg who earn more than $10,000 in                                                                     fees and other similar payments received by a
                                                           tax year, and
                                                                                                             resident 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 of
from 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 for
                                                                                                                 These exemptions do not apply to income
                                                      more than 89 days, they are taxed only on the
                                                                                                             residents of the Netherlands receive as public
Mexico                                                income attributable to the fixed base.
                                                                                                             entertainers (such as theater, motion picture,
Income that residents of Mexico receive for per-        Income that residents of Morocco receive for         radio, or television artists, or musicians) or ath-
forming personal services as independent con-         labor or personal services performed in the            letes if the gross income, including reimbursed
tract ors o r se lf-em ploy ed indiv iduals           United States as employees (dependent per-             expenses, is more than $10,000.
(independent personal services) in the United         sonal services) is exempt from U.S. income tax if
States is exempt from U.S. income tax if the          the residents meet three requirements.
                                                                                                             New Zealand
residents:                                              • They are in the United States for less than
  • Are in the United States for no more than              183 days during the tax year.                     Income that residents of New Zealand receive
    183 days in a 12-month period, and                  • They are employees of a resident of Mo-            for performing personal services as indepen-
                                                           rocco or of a permanent establishment of          dent contractors or self-employed individuals
  • Do not have a fixed base that they regu-                                                                 (independent personal services) in the United
    larly use for performing the services.                 a resident of a country other than Morocco
                                                           if the permanent establishment is located         States in any tax year is exempt from U.S. in-
If they have a fixed base available, they are                                                                come tax if the residents:
                                                           in Morocco.
taxed only on income attributable to the fixed
                                                        • Their income is not borne by a permanent             • Are present in the United States for no
base.                                                                                                            more than 183 days during any consecu-
                                                           establishment that the employer has in the
   Income that residents of Mexico receive for                                                                   tive 12-month period, and
                                                           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.

Page 10                                                                                                                        Publication 901 (April 2008)
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 for
States, they are taxed on the income attributable         establishment that the employer has in the          the tax year. Regardless of these limits, income
to the fixed base.                                        United States.                                      of Philippine entertainers is exempt from U.S.
  Income that residents of New Zealand receive                                                                tax if their visit to the United States is substan-
                                                        The exemption does not apply to a resident of         tially supported or sponsored by the Philippine
for labor or personal services performed in the      Norway who performs services as an employee
United States as employees (dependent per-                                                                    Government and the entertainers are certified
                                                     aboard a ship or an aircraft operated by a United
sonal services) is exempt from U.S. income tax if                                                             as qualified for this exemption by the Philippine
                                                     States resident in international traffic or in fish-
the residents meet these requirements.               ing on the high seas if the resident of Norway is a      competent authority.

  • They are present in the United States for        member of the regular complement of the ship or
    no more than 183 days in any consecutive         aircraft.
                                                                                                              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 the
                                                     Residents of Pakistan who perform personal               t r a c t o r s o r s e l f - e m p l o y e d i n d i vi d u a l s
    United States.
                                                     services (including professional services) for or        (independent personal services) in the United
  • Their income is not borne by a permanent         on behalf of a resident of Pakistan while in the         States is exempt from U.S. income tax if they are
    establishment or fixed base of the em-           United States for no more than 183 days during           in the United States for no more than 182 days
    ployer 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
   Pay received by a New Zealand resident as                                                                      Income that residents of Poland receive for
                                                     to Pakistani tax.
an employee and member of the regular com-                                                                    labor or personal services performed as employ-
plement of a ship or aircraft operated in interna-                                                            ees (dependent personal services), including
tional traffic is exempt from U.S. tax.              Philippines                                              services performed by an officer of a corporation
    The exemption from U.S. tax on income from                                                                or company, in the United States during the tax
                                                     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
                                                     (independent personal services) in the United               • They are in the United States for no more
more than $10,000 in gross receipts, including       States during the tax year is exempt from U.S.                 than 182 days during the tax year.
reimbursed expenses, from their entertainment
activities in the United States during the tax
                                                     income tax if the residents:                                • Their income is paid by or on behalf of an
year.                                                  • Are in the United States for no more than                  employer who is not a U.S. resident.
                                                          89 days during the tax year,                           • Their income is not borne by a permanent
                                                       • Earn gross income for those services that                  establishment that the employer has in the
Norway                                                    is not more than $10,000 for the tax year if              United States.
                                                          the income is from U.S. contractors, and
Income 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-
                                                          able to them in the United States for per-          bers of the regular complement of a ship or
tract ors o r se lf-em ploy ed indiv iduals
(independent personal services) in the United             forming their services.                             aircraft operated by a resident of Poland in inter-
States during the tax year is exempt from U.S.                                                                national traffic is exempt from U.S. tax.
                                                     If they have a fixed base available in the United
income tax if the residents:                         States, they are taxed only on the income attrib-
  • Are present in the United States for no          utable to the fixed base. There is no dollar limit       Portugal
    more than 182 days during the tax year,          for condition (2) if the contractor is a resident of a
    and                                              country other than the United States.                    Income that residents of Portugal receive for
                                                                                                              performing personal services as independent
  • Do not maintain a fixed base in the United         Income that residents of the Philippines re-
                                                                                                              contractors or self-employed individuals (inde-
    States for more than 182 days during the         ceive for personal services performed in the
                                                     United States as employees (dependent per-               pendent personal services) in the United States
    tax year.
                                                     sonal services) is exempt from U.S. income tax if        is exempt from U.S. income tax if the residents:
If they do not meet requirement (2), they are        the residents meet three requirements.                      • Are in the United States for no more than
taxed only on the income attributable to the fixed
base.                                                  • They are in the United States for no more                  182 days in any 12-month period, and
                                                          than 89 days during the tax year.                      • Do not have a fixed base regularly avail-
  This exemption does not apply to residents of
Norway who are public entertainers (theater,
                                                       • They are employees of a resident of the                    able to them in the United States for per-
                                                          Philippines or of a permanent establish-                  forming the activities.
motion picture, or television artists, musicians,
                                                          ment maintained in the Philippines.
or athletes) if they are in the United States for                                                             If they have a fixed base available, they are
more than 90 days during the tax year or their         • Their income is not borne by a permanent             taxed only on the income attributable to the fixed
pay for services as public entertainers is more           establishment that the employer has in the          base.
than $10,000 during the tax year.                         United States.
                                                                                                                Income that residents of Portugal receive for
   Income that residents of Norway receive for                                                                employment in the United States (dependent
labor or personal services performed in the            Pay received by an employee of a resident of
                                                     the Philippines for personal services performed          personal services) is exempt from U.S. income
United States as employees (dependent per-
                                                     as a member of the regular complement of a               tax if the following three requirements are met.
sonal services) is exempt from U.S. income tax if
the residents meet three requirements.
                                                     ship or an aircraft operated in international traffic       • The resident is in the United States for no
                                                     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
    resident of a state other than Norway if the     personal services) in the United States as enter-           • The income is not borne by a permanent
    permanent establishment is situated in           tainers, such as theater, motion picture, radio, or            establishment or fixed base that the em-
    Norway.                                          television artists, musicians, or athletes, if the             ployer has in the United States.

Publication 901 (April 2008)                                                                                                                                        Page 11
   Income received by a resident of Portugal for        Russia                                                              If they have a fixed base available, they are
employment as a member of the regular com-                                                                                  taxed only on income attributable to the fixed
plement of a ship or aircraft operated in interna-      Income that residents of Russia receive for per-                    base.
tional traffic is exempt from U.S. tax.                 forming personal services as independent con-
                                                        t r ac t or s o r s e l f - e m p l o y e d i n d i v i d u a l s     Income that residents of the Slovak Republic
     These exemptions do not apply to income
                                                        (independent personal services) in the United                       receive for employment in the United States
residents of Portugal receive as public entertain-
                                                        States is exempt from U.S. income tax if:                           (dependent personal services) is exempt from
ers (such as theater, motion picture, radio, or
                                                                                                                            U.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-
more than $10,000. The income of Portuguese
                                                              dar year, or
                                                                                                                              • The resident is present in the United
entertainers and athletes is exempt from U.S.                                                                                   States for no more than 183 days in any
tax if their visit to the United States is substan-        • The income is not attributable to a fixed                          12-month period.
tially supported by public funds of Portugal or its           base in the United States which is regu-
                                                              larly available to the residents.
                                                                                                                              • The income is paid by, or on behalf of, an
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
fees and similar payments received by a resi-
                                                        are taxed only on the income attributable to the
                                                                                                                              • The income is not borne by a permanent
dent of Portugal for services performed outside                                                                                 establishment or a fixed base that the em-
                                                        fixed base.
of Portugal as a member of the board of direc-                                                                                  ployer has in the United States.
tors of a company that is a resident of the United        Income that residents of Russia receive for
States.                                                 employment in the United States (dependent                             These exemptions do not apply to income
                                                        personal services) is exempt from U.S. income                       residents of the Slovak Republic receive as pub-
                                                        tax if the following three requirements are met.                    lic entertainers (such as theater, motion picture,
Romania                                                                                                                     radio, or television artists, or musicians) or
                                                           • The resident is in the United States for no                    sportsmen if their gross receipts, including reim-
Income that residents of Romania receive for                  more than 183 days during the calendar                        bursed expenses, are more than $20,000 during
performing personal services as independent                   year.                                                         the tax year. Regardless of these limits, income
contractors or self-employed individuals (inde-            • The income is paid by, or on behalf of, an                     of Slovak entertainers and sportsmen is exempt
pendent personal services) in the United States               employer who is not a resident of the                         from U.S. income tax if their visit to the United
during the tax year is exempt from U.S. income                                                                              States is substantially supported by public funds
                                                              United States.
tax if the residents:                                                                                                       of the Slovak Republic, its political subdivisions,
                                                           • The income is not borne by a permanent
  • Are present in the United States for no                   establishment or a fixed base that the em-
                                                                                                                            or local authorities, or the visit is made pursuant
     more than 182 days during the tax year,                                                                                to a specific arrangement between the United
                                                              ployer has in the United States.                              States and the Slovak Republic.
     and
                                                        However, income from employment directly                                 These exemptions do not apply to directors’
  • Do not maintain a permanent establish-              connected with a place of business that is not a                    fees and similar payments received by a resi-
     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 the
                                                        dent is present in the United States not longer
                                                        than 12 consecutive months. For this purpose, a                     board of directors of a company that is a resident
   Income that residents of Romania receive for                                                                             of the United States.
labor or personal services performed as employ-         place of business means a construction site,
                                                        assembly or installation project, or drilling opera-                     Income from employment as a member of
ees (dependent personal services), including                                                                                the regular complement of a ship or aircraft
services performed by an officer of a corporation       tion.
                                                                                                                            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 ship
year 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, the
sidents meet these requirements.                        plement of a ship or aircraft operated in interna-                  income is subject to U.S. income tax.
  • They are in the United States for no more           tional traffic is exempt from U.S. tax.
     than 182 days during the tax year.                     Income from technical services directly con-
                                                        nected with the application of a right or property                  Slovenia
  • They are employees of a resident of                 giving rise to a royalty is exempt if those services
     Romania or of a permanent establishment                                                                                Income that residents of Slovenia receive for
                                                        are provided as part of a contract granting the
     maintained in Romania by a resident of                                                                                 personal services as independent contractors or
                                                        use 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 fixed
     establishment that the employer has in the         dent of Russia as a member of the board of                          base regularly available to them in the United
     United 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, they
   These exemptions do not apply to entertain-
                                                                                                                            are taxed on the income attributable to the fixed
ers, such as theater, motion picture, radio, or
                                                                                                                            base.
television artists, musicians, or athletes, who are     Slovak Republic                                                         Income that residents of Slovenia receive for
present in the United States for more than 90
                                                        Income that residents of the Slovak Republic                        services performed in the United States as em-
days during the tax year (90 days or more if the
                                                        receive for performing personal services as in-                     ployees (dependent personal services) is ex-
entertainers are employees) or who earn gross
                                                        dependent contractors or self-employed individ-                     empt from U.S. income tax if the residents meet
income as entertainers in the United States of
                                                        uals (independent personal services) in the                         the following requirements.
more than $3,000 during the tax year ($3,000 or
more if they are employees). However, the ex-           United States is exempt from U.S. income tax if                       • They are in the United States for no more
emptions do apply, without regard to the 90 day,        the residents:                                                          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 no
ent in the United States by specific arrange-
ments between the United States and Romania.
                                                              more than 183 days in any 12-month pe-                          • Their income is paid by, or on behalf of, an
                                                              riod, and                                                         employer who is not a U.S. resident.
    Pay received by employees who are mem-
bers of the regular complement of a ship or                • Do not have a fixed base regularly avail-                        • Their income is not borne by a permanent
aircraft operated by a resident of Romania in                 able to them in the United States for per-                        establishment or a fixed base that the em-
international traffic is exempt from U.S. tax.                forming the activities.                                           ployer has in the United States.



Page 12                                                                                                                                       Publication 901 (April 2008)
   These exemptions do not apply to directors’           funds of South Africa, its political subdivisions,       • They are in the United States for no more
fees and similar payments received by a resi-            or local authorities.                                       than 183 days in any 12-month period.
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, an
United 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
United States.                                           operated in international traffic is exempt from         • Their income is not borne by a permanent
    Income received by a Slovenian resident for          U.S. income tax.                                            establishment or a fixed base that the em-
employment as a member of the regular com-                                                                           ployer has in the United States.
plement of a ship or aircraft operated in interna-
                                                         Spain                                                     Income received from employment as a mem-
tional traffic is exempt from U.S. tax.
                                                                                                                ber of the regular complement of a ship or an
    These exemptions do not apply to income                                                                     aircraft operated in international traffic by a Sri
                                                         Income that residents of Spain receive as inde-
residents of Slovenia receive as public enter-           pendent contractors or self-employed individu-         Lanka enterprise is exempt from U.S. tax. If the
tainers (such as theater, motion picture, radio, or      als (independent personal services) in the             ship or aircraft is operated by a U.S. enterprise,
television artists, or musicians) or athletes if         United States is exempt from U.S. income tax if        the income is subject to U.S. tax.
their gross receipts, including reimbursed ex-           the residents do not have a fixed base available           These exemptions do not apply to public
penses, 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, and
venian entertainers or athletes is exempt from           taxed only on the income attributable to the fixed     athletes) from Sri Lanka who earn more than
U.S. tax if their visit to the United States is wholly   base.                                                  $6,000 in gross receipts, including reimbursed
or mainly paid by public funds of either the                                                                    expenses, from their entertainment activities in
                                                            Income that residents of Spain receive for
United States or Slovenia or their political subdi-                                                             the United States during the tax year. Regard-
                                                         personal services performed in the United
visions, or local authorities.                           States as employees (dependent personal serv-          less of these limits, income of Sri Lanka enter-
                                                         ices) is exempt from U.S. income tax if:               tainers is exempt from U.S. income tax if their
                                                                                                                visit to the United States is directly or indirectly
South Africa                                               • The residents are present in the United            supported wholly or substantially by public funds
                                                              States no more than 183 days in any               of Sri Lanka or the United States, their political
Income that residents of South Africa receive for             12-month period,                                  subdivisions, or local authorities.
performing personal services as independent
contractors or self-employed individuals (inde-            • The income is paid by, or on behalf of, an             These exemptions do not apply to directors’
                                                              employer who is not a U.S. resident, and          fees and other compensation received by a resi-
pendent personal services) in the United States
is exempt from U.S. income tax if the residents:           • The income is not borne by a permanent             dent of Sri Lanka for services performed in the
                                                              establishment or fixed base the employer          United States as a member of the board of
  • Are in the United States for no more than                                                                   directors of a company resident in the United
                                                              has 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 received
  • Do not have a fixed base regularly avail-            by employees who are members of a regular
     able to them in the United States for per-          complement of a ship or aircraft operated in           Sweden
     forming the services.                               international traffic by a U.S. enterprise.            Income that residents of Sweden receive for
If they have a fixed base available, they are                These exemptions do not apply to public            performing personal services as independent
taxed only on income attributable to the fixed           entertainers (such as theater, motion picture,         contractors or self-employed individuals (inde-
base.                                                    radio, or television artists, or musicians) or ath-    pendent personal services) in the United States
                                                         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 regularly
for 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 base
empt from U.S. income tax if the following re-           Spanish entertainers and athletes are exempt           available in the United States, they are taxed on
quirements are met.                                      from U.S. tax if their visit to the United States is   the income attributable to the fixed base.
  • The resident is in the United States for no          substantially supported by public funds of Spain,         Income that residents of Sweden receive for
                                                         a political subdivision, or local authority.           labor or personal services performed in the
     more than 183 days in any 12-month pe-
     riod beginning or ending in the tax year.                                                                  United States as employees (dependent per-
                                                                                                                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
                                                         during the tax year is exempt from U.S. income
                                                                                                                  • Their income is paid by, or on behalf of, an
   These exemptions do not apply to directors’                                                                       employer who is not a resident of the
                                                         tax if the residents:
fees and similar payments received by a resi-                                                                        United States.
                                                           • Are in the United States for no more than
dent of South Africa for services performed in
                                                              183 days in any 12-month period, or
                                                                                                                  • Their income is not borne by a permanent
the 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
    These exemptions do not apply to income                   purpose of performing the services.                  Income received by a resident of Sweden for
residents of South Africa receive as public enter-                                                              employment as a member of the regular com-
tainers (such as theater, motion picture, radio, or         If they have a fixed base available in the          plement of a ship or aircraft operated in interna-
television artists, or musicians) or athletes if         United States, they are taxed on the income            tional traffic is exempt from U.S. tax.
their gross receipts, including reimbursed ex-           attributable to the fixed base.                            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, or
South African entertainers or athletes is exempt         employees (dependent personal services) is ex-         television artists, or musicians) or athletes if the
from 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.

Publication 901 (April 2008)                                                                                                                              Page 13
    These exemptions do not apply to directors’        by a U.S. resident or borne by a permanent            Tunisia
fees received by a resident of Sweden for serv-        establishment or fixed base in the United States.
ices performed outside of Sweden as a member                                                                 Income that residents of Tunisia receive for per-
                                                          Income that residents of Thailand receive for
of the board of directors of a company that is a                                                             forming personal services as independent con-
                                                       services performed in the United States as em-        t r a c t o r s o r s e l f - e m p l o y e d i n d i vi d u a l s
resident of the United States.
                                                       ployees (dependent personal services) is ex-          (independent personal services) in the United
                                                       empt from U.S. income tax if the following            States are exempt from U.S. income tax if:
Switzerland                                            requirements are met.
                                                                                                                • 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 for
                                                           more than 183 days in any 12-month pe-
personal services as independent contractors or
                                                           riod beginning or ending in the tax year.            • They do not have a fixed base regularly
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, and
year in the United States is exempt from U.S.              employer who is not a U.S. resident.
income tax if they do not have a fixed base                                                                     • The gross income for the tax year from
regularly available to them in the United States         • The income is not borne by a permanent                  U.S. residents for services performed in
for performing the services. If they have a fixed          establishment or a fixed base that the em-              the United States is no more than $7,500.
base available in the United States, they are              ployer has in the United States.
taxed on the income attributable to the fixed                                                                   If they do not meet condition (2), they are
base.                                                     These exemptions do not apply to directors’        taxed on the income that is attributable to the
    Income that residents of Switzerland receive       fees and similar payments received by a resi-         fixed base.
for services performed in the United States as         dent of Thailand for services performed outside            Income that residents of Tunisia receive for
employees (dependent personal services) is ex-         of Thailand as a member of the board of direc-        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.                            States.                                               ices) is exempt from U.S. income tax if:
  • They are in the United States for no more              These exemptions do not apply to income              • The residents are in the U.S. for no more
     than 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
  • Their income is paid by, or on behalf of, an       (such as theater, motion picture, radio, or televi-
                                                                                                                   employer who is not a resident of the
     employer who is not a U.S. resident.              sion artists, or musicians) and athletes, if the            United States, and
                                                       income is more than $100 a day or $3,000 for
  • Their income is not borne by a permanent           the tax year. Regardless of these limits, income         • Their income is not borne by a permanent
     establishment or a fixed base that the em-                                                                    establishment or fixed base the employer
                                                       of Thai entertainers is exempt from U.S. tax if
     ployer has in the United States.                                                                              has in the United States.
                                                       their visit to the United States is substantially
   These exemptions do not apply to directors’         supported by public funds of Thailand or its
                                                                                                                Pay received by employees who are mem-
fees and similar payments received by a resi-          political subdivisions or local authorities.
                                                                                                             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 place
United 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 the
entertainers (such as theater, motion picture,                                                               laws of the United States (or a U.S. state), the
radio, 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-
expenses, from their entertainment activities in       Income (including reimbursed travel expenses)
                                                                                                             ers (such as theater, motion picture, radio, or
the United States during the tax year.                 that residents of Trinidad and Tobago receive
                                                                                                             television artists, and musicians) or athletes if
    Income received by a resident of Switzerland       during the tax year for personal services per-
                                                                                                             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 tax
member 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
from U.S. income tax.                                                                                            These exemptions do not apply to fees re-
                                                       year and either:                                      ceived by a resident of Tunisia for services per-
                                                         • The residents are employees of a resident         formed as a director of a U.S. corporation if the
Thailand                                                   of a country other than the United States         fees are treated as a distribution of profits and
                                                           or are employees of a permanent estab-            cannot be taken as a deduction by the corpora-
Income that residents of Thailand receive for              lishment of a U.S. resident outside the           tion.
performing 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
                                                           nent establishment in the United States, or
                                                                                                             Turkey
States during the tax year is exempt from U.S.
income tax if the residents:                             • The income is not more than $3,000 (ex-           Income that residents of Turkey receive for per-
                                                           cluding reimbursed travel expenses).              forming personal services as independent con-
  • Are in the United States for no more than                                                                t r a c t o r s o r s e l f - e m p l o y e d i n d i vi d u a l s
     89 days during the tax year, and                                                                        (independent personal services) in the United
                                                          These exemptions do not apply to the profes-
  • Do not have a fixed base regularly avail-          sional earnings of public entertainers such as        States is exempt from U.S. income tax if the
     able to them in the United States for per-        actors, musicians, and professional athletes or       residents:
     forming their services.                           to any person providing their services if the pay        • Are in the United States for purposes of
If they have a fixed base available in the United      is more than $100 per day (excluding reim-                  performing the services or activities for no
States, they are taxed only on the income attrib-      bursed travel expenses).                                    more than 183 days in any 12-month pe-
utable to the fixed base.                                  Pay received by members of the regular                  riod, and
  This exemption does not apply if a resident of       complement of a ship or aircraft operated in             • Do not have a fixed base regularly avail-
Thailand earns more than $10,000 for indepen-          international traffic by a resident of Trinidad and         able to them in the United States for per-
dent personal services and that income is paid         Tobago is exempt from U.S. tax.                             forming the services.

Page 14                                                                                                                             Publication 901 (April 2008)
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 a
taxed only on income attributable to the fixed        States.                                                fixed base available, they are taxed on the in-
base.                                                      These exemptions generally do not apply to        come attributable to the fixed base.
                                                      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 as
services 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 meet
empt 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
  • The resident is in the United States for no       of Ukraine, its political subdivisions, or local au-
                                                                                                                  than 183 days in any 12-month period be-
    more than 183 days in any 12-month pe-            thorities, or the visit is made pursuant to a spe-
                                                                                                                  ginning or ending in the tax year.
    riod.                                             cific arrangement between the United States
                                                      and Ukraine.                                             • Their income is paid by, or on behalf of, an
  • The income is paid by, or on behalf of, an             Income derived by a resident of Ukraine from           employer who is not a U.S. resident.
    employer who is not a U.S. resident.              employment as a member of the regular com-
                                                                                                               • The income is not borne by a permanent
  • The income is not borne by a permanent            plement of a ship or aircraft operated in interna-
                                                                                                                  establishment or a fixed base that the em-
    establishment or a fixed base that the em-        tional traffic is exempt from U.S. tax.
                                                                                                                  ployer has in the United States.
    ployer has in the United States.
                                                                                                                These exemptions do not apply to directors’
   This exemption does not apply to a resident of     United Kingdom                                         fees and similar payments received by a resi-
Turkey who performs services as a member of                                                                  dent of Venezuela for services performed in the
                                                      Income that residents of the United Kingdom
the regular complement of a ship or an aircraft       receive for personal services as independent           United States as a member of the board of
operated by a U.S. resident in international traf-    contractors or self-employed individuals are           directors of a company resident in the United
fic.                                                  subject to the provisions of Article 7 (Business       States.
     These exemptions do not apply to directors’      Profits) of the treaty. Under that provision, busi-        Pay received by a resident of Venezuela for
fees and similar payments received by a resi-         ness profits are exempt from U.S. income tax           services performed as an employee of a ship or
dent of Turkey for services provided in the           unless they have a permanent establishment in          an aircraft operated in international traffic is ex-
United States as a member of the board of             the United States. If they have a permanent            empt from U.S. income tax.
directors of a company that is a resident of the      establishment available in the United States,              These exemptions do not apply to income
United States.                                        they are taxed on the income attributable to the       residents of Venezuela receive as public enter-
     These exemptions do not apply to income          permanent establishment.                               tainers (such as theater, motion picture, radio, or
residents of Turkey receive as public entertain-         Income that residents of the United Kingdom         television artists, or musicians) or sportsmen if
ers (such as theater, motion picture, radio, or       receive for services performed in the United           their gross income, including reimbursed ex-
television artists, or musicians) or athletes if      States as employees (dependent personal serv-          penses, is more than $6,000 for their personal
their gross receipts are more than $3,000 during      ices) is exempt from U.S. income tax if the re-        activities in the United States during the tax
                                                      sidents meet the following requirements.               year. Regardless of these limits, income of Ven-
the tax year for their entertainment activities in
                                                                                                             ezuelan entertainers or athletes is exempt from
the 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 of
non-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 au-
thorities, the income is taxed as independent
                                                        • Their income is paid by, or on behalf of, an       thorities.
                                                           employer who is not a U.S. resident.
personal services or dependent personal serv-
ices.                                                   • Their income is not borne by a permanent           Professors, Teachers,
                                                           establishment that the employer has in the        and Researchers
                                                           United States.
Ukraine                                                                                                      Pay of professors and teachers who are re-
                                                         These exemptions do not apply to directors’         sidents of the following countries is generally
Income that residents of Ukraine receive for          fees and similar payments received by a resi-          exempt from U.S. income tax for 2 or 3 years if
performing personal services as independent           dent of the United Kingdom for services per-           they temporarily visit the United States to teach
contractors or self-employed individuals (inde-       formed in the United States as a member of the         or do research. The exemption applies to pay
pendent personal services) in the United States       board of directors of a company resident in the        earned by the visiting professor or teacher dur-
is exempt from U.S. income tax if the income is       United States.                                         ing the applicable period. For most of the follow-
not attributable to a fixed base in the United             These exemptions do not apply to public           ing countries, the applicable period begins on
States that is regularly available for performing     entertainers (such as theater, motion picture,         the date of arrival in the United States for the
the services.                                         radio, or television artists, musicians, or ath-       purpose of teaching or engaging in research.
    Income that residents of Ukraine receive for      letes) from the United Kingdom who earn more           Furthermore, for most of the following countries,
employment in the United States (dependent            than $20,000 in gross receipts, including reim-        the exemption applies even if the stay in the
personal services) is exempt from U.S. income         bursed expenses, from their entertainment ac-          United States extends beyond the applicable
                                                      tivities in the United States during the tax year.     period.
tax if the following three requirements are met.
                                                            Income received by a resident of the United          The exemption generally applies to pay re-
  • The resident is in the United States for no       Kingdom for services performed as an em-               ceived during a second teaching assignment if
    more than 183 days during the tax year.                                                                  both are completed within the specified time,
                                                      ployee and member of the regular complement
  • The income is paid by, or on behalf of, an        of a ship or aircraft operated in international        even if the second assignment was not arranged
    employer who is not a resident of the             traffic is exempt from U.S. income tax.                until after arrival in the United States on the first
                                                                                                             assignment. For each of the countries listed, the
    United States.
                                                                                                             conditions are stated under which the pay of a
  • The income is not borne by a permanent            Venezuela                                              professor or teacher from that country is exempt
    establishment 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 a
   These 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 discussed
of Ukraine as a member of the board of directors      base regularly available to them in the United         earlier.

Publication 901 (April 2008)                                                                                                                            Page 15
Bangladesh                                            Commonwealth of                                           This exemption does not apply to income
                                                      Independent States (C.I.S.)                           from research carried on mainly for the private
An individual is exempt from U.S. income tax on                                                             benefit of any person rather than in the public
income from teaching or research for not more         An individual who is a resident of a C.I.S. mem-      interest.
than 2 years from the date of arrival for such        ber on the date of arrival in the United States
purposes if he or she:                                and who is temporarily in the United States at
                                                      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            United States primarily to teach, engage in re-       An individual who is a resident of France on the
  • Is in the United States to teach or engage        search, or participate in scientific, technical, or   date of arrival in the United States and who is
    in research at a university, college, or          professional conferences is exempt from U.S.          temporarily in the United States at the invitation
    other recognized educational institution.         income tax on income for teaching, research, or       of the U.S. Government, a university, or other
                                                      participation in these conferences for a maxi-        recognized educational or research institution in
   This exemption does not apply to income from       mum period of 2 years.                                the United States primarily to teach or engage in
research carried on mainly for the private benefit        This exemption does not apply to income           research, or both, at a university or other educa-
of any person rather than in the public interest.     from research carried on mainly for the benefit of    tional or research institution is exempt from U.S.
                                                      a private person, including a commercial enter-       income tax on income from teaching or research
                                                      prise of the United States or a foreign trade         for a maximum of 2 years from the date of arrival
Belgium                                               organization of a C.I.S. member.                      in the United States.
                                                          The exemption does, however, apply if the             An individual may claim this benefit only
                                                      research 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.
publication.                                          and correspondents who are temporarily in the
                                                      United States for periods not longer than 2 years         This exemption does not apply to income
                                                      and who receive their compensation from               from research carried on mainly for the private
New treaty. An individual who is a resident of                                                              benefit of any person rather than in the public
                                                      abroad. It is not necessary that the journalists or
Belgium at the beginning of the visit to the          correspondents be invited by the U.S. Govern-         interest.
United States and who is temporarily in the           ment or other appropriate institution, nor does it
United States to teach or carry on research at a      matter that they are employed by a private per-
school, college, university or other educational      son, including commercial enterprises and for-        Germany
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 protocol
from the date of arrival in the United States on
                                                                                                            under What’s New at the beginning of this publi-
income received for teaching or carrying on re-       Czech Republic
                                                                                                            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
from research carried on mainly for the private                                                             Treaty as modified. A professor or teacher
                                                      if he or she:                                         who is a resident of Germany and who is tempo-
benefit of any person rather than in the public
interest.                                               • Is a resident of the Czech Republic imme-         rarily in the United States to engage in advanced
                                                          diately before visiting the United States,        study or research or teaching at an accredited
                                                          and                                               educational institution or institution engaged in
Former treaty. An individual who is a resident                                                              research for the public benefit is exempt from
                                                        • Is in the United States primarily to teach or
of Belgium on the date of arrival in the United                                                             U.S. tax on income received for such study,
                                                          conduct research at a university, college,
States and who is temporarily in the United                                                                 research, or teaching for a maximum of 2 years
                                                          school, or other accredited educational or
States at the invitation of the U.S. Government,                                                            from the date of arrival in the United States.
                                                          research institution.
a university, or other recognized educational                                                                   The exemption does not apply to income
institution in the United States primarily to teach     A Czech resident is entitled to these benefits      from research carried on mainly for the private
or engage in research, or both, at a university or    only once. However, the exemption does not            benefit of any person rather than in the public
other accredited educational institution is ex-       apply if:                                             interest. The exemption does not apply if, during
empt from U.S. income tax on income for the                                                                 the preceding period, the benefit described in
                                                        • The resident claimed during the immediate
teaching or research for a maximum of 2 years                                                               paragraph (2), (3), or (4) of Article 20 of the
                                                          preceding period the benefits described
from the date of arrival in the United States.                                                              treaty, pertaining to students, was claimed.
                                                          later under Students and Apprentices, or
    This exemption does not apply to income
from research carried on mainly for the private
                                                        • The income is from research undertaken
                                                                                                            Unmodified treaty. A professor or teacher
                                                          primarily 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 the
                                                          cific person or persons.
interest.                                                                                                   United States for not more than 2 years to en-
                                                                                                            gage in advanced study or research or teaching
                                                      Egypt                                                 at an accredited educational institution or institu-
China, People’s Republic of                                                                                 tion engaged in research for the public benefit is
                                                      An individual who is a resident of Egypt on the       exempt from U.S. tax on income received for
An individual who is a resident of the People’s       date of arrival in the United States and who is       such study, research, or teaching. If the individ-
Republic of China and who is temporarily in the       temporarily in the United States primarily to
                                                                                                            ual’s visit to the United States exceeds 2 years,
United States primarily to teach, lecture, or con-    teach or engage in research, or both, at a univer-
                                                                                                            the exemption is lost for the entire visit unless
duct research at a university or other accredited     sity or other recognized educational institution is
                                                                                                            the competent authorities of Germany and the
educational institution or scientific research in-    exempt from U.S. income tax on income from
                                                                                                            United States agree otherwise.
stitution is exempt from U.S. income tax on in-       the teaching or research for a maximum of 2
                                                      years from the date of arrival in the United              The exemption does not apply to income
come for the teaching, lecturing, or research for
                                                      States. The individual must have been invited to      from research carried on mainly for the private
a total of not more than 3 years.                                                                           benefit of any person rather than in the public
                                                      the United States for a period not expected to be
    This exemption does not apply to income           longer than 2 years by the U.S. Government or a       interest. The exemption does not apply if, during
from research carried on mainly for the private       state or local government, or by a university or      the preceding period, the benefit described in
benefit of any person rather than in the public       other recognized educational institution in the       paragraph (2), (3), or (4) of Article 20 of the
interest.                                             United States.                                        treaty, pertaining to students, was claimed.

Page 16                                                                                                                       Publication 901 (April 2008)
Greece                                                 Indonesia                                                 This exemption does not apply to income
                                                                                                             from 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 public
Greece and who is temporarily in the United            for teaching or research for a maximum of 2           interest.
States to teach at a university, college, or other     years from the date of arrival in the United
educational institution for a maximum of 3 years       States if he or she:
is exempt from U.S. income tax on the income             • Is a resident of Indonesia immediately            Japan
received for teaching during that period.                  before visiting the United States, and            An individual who is a resident of Japan and who
                                                         • Is in the United States at the invitation of a    is temporarily in the United States primarily to
                                                           university, school, or other recognized ed-       teach or engage in research at a university,
Hungary                                                                                                      college, or other recognized educational institu-
                                                           ucational institution to teach or engage in
An individual who is a resident of Hungary on the          research, or both, at that educational insti-     tion is exempt from U.S. income tax on income
date of arrival in the United States and who is            tution.                                           for the teaching or research for a maximum of 2
                                                                                                             years from the date of arrival in the United
temporarily in the United States primarily to
                                                         A resident of Indonesia is entitled to this ex-     States.
teach or engage in research, or both, at a univer-
                                                       emption only once. But this exemption does not            The exemption does not apply to income
sity or other recognized educational institution is                                                          from research carried on mainly for the private
                                                       apply to income from research carried on mainly
exempt from U.S. income tax on income for the                                                                benefit of any person rather than in the public
                                                       for 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. The
individual must have been invited to the United        Israel                                                Former treaty. An individual entitled to the
States for a period not expected to be longer                                                                teacher and researcher benefits under the for-
than 2 years by the U.S. Government or a state         An individual who is a resident of Israel on the      mer treaty may continue to claim those benefits
or local government, or by a university or other       date of arrival in the United States and who is       for as long as the individual would have been
recognized educational institution in the United       temporarily in the United States primarily to         entitled to them under the treaty.
                                                       teach 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 of
from research carried on mainly for the private        the teaching or research for a maximum of 2
benefit of any person rather than in the public        years from the date of arrival in the United          An individual who is a resident of the Republic of
interest.                                              States. The individual must have been invited to      Korea on the date of arrival in the United States
                                                       the United States for a period not expected to be     and who is temporarily in the United States pri-
                                                       longer than 2 years by the U.S. Government or a       marily to teach or engage in research, or both, at
Iceland                                                state or local government, or by a university or      a university or other recognized educational in-
                                                       other recognized educational institution in the       stitution is exempt from U.S. income tax on in-
An individual who is a resident of Iceland on the                                                            come for the teaching or research for a
                                                       United 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
temporarily in the United States at the invitation                                                           the United States. The individual must have
                                                       from research carried on mainly for the private
of the U.S. Government, a university, or other                                                               been invited to the United States for a period not
                                                       benefit of any person rather than in the public
recognized educational institution in the United                                                             expected to be longer than 2 years by the U.S.
                                                       interest. The exemption does not apply if, during
States primarily to teach or engage in research,                                                             Government or a state or local government, or
                                                       the immediately preceding period, the benefits        by a university or other recognized educational
or 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 income
for the teaching or research for a maximum of 2                                                              from research carried on mainly for the private
years from the date of arrival in the United                                                                 benefit of any person rather than in the public
States.                                                Italy                                                 interest.
    This exemption does not apply to income            A professor or teacher who is a resident of Italy
from research carried on mainly for the private        on the date of arrival in the United States and
benefit of any person rather than in the public        who temporarily visits the United States to teach     Luxembourg
interest.                                              or conduct research at a university, college,         A resident of Luxembourg who is temporarily in
                                                       school, 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 in
                                                       for up to 2 years on pay from this teaching or        research, or both, at that educational institution
An 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 2
  • Is a resident of India immediately before          from research carried on mainly for the private       years from the date of arrival in the United
     visiting the United States, and                   benefit of any person rather than in the public       States.
                                                       interest.                                                 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 of
     other recognized educational institution in       Jamaica                                               Luxembourg and the United States agree other-
     the United States for a period not longer                                                               wise.
     than 2 years.                                     An individual who is a resident of Jamaica on the         This exemption does not apply to pay for
                                                       date of arrival in the United States and who          research carried on for the benefit of any person
  If the individual’s visit to the United States       temporarily visits the United States to teach or      other than the educational institution that ex-
exceeds 2 years, the exemption is lost for the         engage in research at a university, college, or       tended the invitation.
                                                       other 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      Netherlands
from research carried on mainly for the private        than 2 years from the date of arrival in the United
benefit 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 on
interest.                                              exemption only once.                                  income received for teaching or research for a

Publication 901 (April 2008)                                                                                                                            Page 17
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 or
or she:                                                ing to students, were claimed.                             conduct research at a university, college,
                                                                                                                  school, or other accredited educational or
  • Is a resident of the Netherlands immedi-                                                                      research institution.
     ately before visiting the United States, and      Poland
  • Is in the United States to teach or engage                                                                 A Slovak resident is entitled to these benefits
     in research at a university, college, or          An individual who is a resident of Poland on the      only once. However, the exemption does not
     other recognized educational institution for      date of arrival in the United States and who is       apply if:
                                                       temporarily in the United States at the invitation
     not more than 2 years.
                                                       of the U.S. Government, a university, or other          • The resident claimed during the immediate
                                                       recognized educational institution in the United           preceding period the benefits described
   If the individual’s visit to the United States is                                                              later under Students and Apprentices, or
longer than 2 years, the exemption is lost for the     States primarily to teach or engage in research,
entire visit unless the competent authorities of       or both, at a university or other recognized edu-       • The income is from research undertaken
the Netherlands and the United States agree            cational institution is exempt from U.S. income            primarily for the private benefit of a spe-
otherwise.                                             tax on income for the teaching or research for a           cific person or persons.
     The exemption does not apply to income            maximum of 2 years from the date of arrival in
                                                       the United States.
from research carried on primarily for the private                                                           Slovenia
benefit of any person rather than in the public            This exemption does not apply to income
interest. Nor does the exemption apply if the          from research carried on mainly for the private       An individual who is a resident of Slovenia on
resident claimed during the immediate preced-          benefit of any person rather than in the public       the date of arrival in the United States and who
ing period the benefits described later under          interest.                                             temporarily visits the United States to teach or
Students and Apprentices.                                                                                    engage in research at a recognized educational
                                                                                                             or research institution is exempt from U.S. in-
                                                       Portugal                                              come tax on the income received for the teach-
Norway                                                                                                       ing or research for not more than 2 years from
                                                       An individual who is a resident of Portugal on the    the date of arrival in the United States. This
An individual who is a resident of Norway on the       date of arrival in the United States and who is       benefit can be claimed for no more than 5 years.
date of arrival in the United States and who is        temporarily in the United States at the invitation        The exemption does not apply to income
temporarily in the United States at the invitation     of the U.S. Government, a university, other ac-       from research carried on mainly for the private
of the U.S. Government, a university, or other         credited educational institution, or recognized       benefit of any person rather than in the public
recognized educational institution in the United       research institution in the United States, or         interest.
States primarily to teach or engage in research,       under an official cultural exchange program,
or both, at a university or other recognized edu-      only to teach or engage in research, or both, at a
cational institution is exempt from U.S. income        university or educational institution is exempt       Thailand
tax on income for the teaching or research for a       from U.S. income tax on income from teaching
                                                       or research for a maximum of 2 years from the         An individual who is a resident of Thailand on
maximum period of 2 years from the date of
                                                       date of arrival in the United States. An individual   the date of arrival in the United States and who
arrival in the United States.
                                                       is entitled to these benefits only once. However,     is in the United States for not longer than 2 years
    This exemption does not apply to income                                                                  primarily to teach or engage in research at a
                                                       these benefits, and the benefits described later
from research carried on mainly for the private                                                              university, college, school, or other recognized
                                                       under 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 if
                                                       from research carried on mainly for the private
                                                                                                             the visit does not exceed 2 years from the date
Pakistan                                               benefit of any person rather than in the public
                                                                                                             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
Pakistan and who temporarily visits the United                                                                    This exemption does not apply to income
States to teach at a university, college, school,      Romania                                               from research carried on mainly for the private
                                                                                                             benefit of any person rather than in the public
or other educational institution for not longer
                                                       An individual who is a resident of Romania on         interest. This exemption does not apply if, during
than 2 years is exempt from U.S. income tax on
                                                       the date of arrival in the United States and who      the immediately preceding period, the benefits
the income received for teaching for that period.
                                                       is temporarily in the United States at the invita-    described in treaty Article 22(1), pertaining to
                                                       tion of the U.S. Government, a university, or         students, were claimed.
Philippines                                            other recognized educational institution in the
                                                       United States primarily to teach or engage in
An individual who is a resident of the Philippines     research, or both, at a university or other recog-    Trinidad and Tobago
on the date of arrival in the United States and        nized educational institution is exempt from U.S.
                                                                                                             An individual who is a resident of Trinidad and
who is temporarily in the United States primarily      income tax on income for the teaching or re-
                                                                                                             Tobago on the date of arrival in the United
to teach or engage in research, or both, at a          search for a maximum of 2 years from the date
                                                                                                             States and who is temporarily in the United
university or other recognized educational insti-      of arrival in the United States.                      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 or
2 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 or
States. 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
state or local government, or by a university or       Slovak Republic                                       maximum of 2 years from the date of arrival in
other recognized educational institution in the                                                              the United States.
United States.                                         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
    This exemption does not apply to income                                                                  from research carried on mainly for the private
                                                       if he or she:
from research carried on mainly for the private                                                              benefit of any person rather than in the public
benefit 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

Page 18                                                                                                                        Publication 901 (April 2008)
United States for providing the services of these     Associate Program and Visiting Scientist Pro-             Nevertheless, an individual who qualifies for
individuals.                                          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 all
                                                                                                            U.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 the
mediately 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 for
tific research is exempt from U.S. income tax on      full-time education is exempt from U.S. income        Belgium
payments received from outside the United             tax on payments received from outside the
States for teaching or research.                      United States for the individual’s maintenance or
                                                      education.                                               Note. See the effective dates of the new
                                                                                                            treaty under What’s New at the beginning of this
United Kingdom                                                                                              publication.
                                                      Austria
A professor or teacher who is a resident of the
United Kingdom on the date of arrival in the          A student, apprentice, or business trainee who        New treaty. A student or business trainee who
United States and who is in the United States for     is a resident of Austria immediately before visit-    is a resident of Belgium immediately before visit-
not longer than 2 years primarily to teach or         ing the United States and is in the United States     ing the United States and is in the United States
engage in research at a university, college, or       for the purpose of full-time education at a recog-    for the purpose of full-time education or training
other recognized educational institution is ex-       nized educational institution or full-time training   is exempt from U.S. income tax on the following
empt from U.S. income tax on income for the           is exempt from U.S. income tax on amounts             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 to
    The exemption does not apply to income                Apprentices and business trainees are enti-           $9,000 for each tax year.
from research carried on mainly for the private       tled to the benefit of this exemption for a maxi-
benefit of any person rather than in the public       mum period of 3 years.                                   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 United
Venezuela                                                                                                   States:
                                                      An individual who is a resident of Bangladesh
An individual who is a resident of Venezuela on       immediately before visiting the United States           • To secure training to practice a profession
the date of arrival in the United States and who      and who is temporarily present in the United              or professional specialty, or
temporarily visits the United States to teach or      States for the primary purpose of:
                                                                                                              • As an employee of, or under contract with,
engage in research at a recognized educational
                                                       1. Studying at a university, college, school, or         a resident of Belgium, for the primary pur-
or research institution is exempt from U.S. in-
                                                          other recognized educational institution in           pose of acquiring technical, professional,
come tax on the income received for the teach-
                                                          the United States,                                    or business experience from a person
ing or research for not more than 2 years from
                                                                                                                other than that resident of Belgium or
the 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 recipient
from research carried on mainly for the private           of a grant, allowance, or award from a gov-       Former treaty. An individual who is a resident
benefit of any person rather than in the public           ernmental, religious, charitable, or educa-       of Belgium on the date of arrival in the United
interest.                                                 tional organization                               States and who is temporarily in the United
                                                      is exempt from U.S. tax on the following              States primarily to study at a university or other
Students and Apprentices                              amounts.                                              recognized educational institution in the United
                                                                                                            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
from abroad for their maintenance and studies.
                                                        • The grant, allowance, or award.                   zation is exempt from U.S. income tax on the
                                                                                                            following amounts.
                                                        • The income from personal services per-
    This exemption does not apply to the salary
                                                          formed in the United States of up to                • Gifts from abroad for maintenance, educa-
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
who is temporarily in the United States to study a                                                            • The grant, allowance, or award.
                                                         For an individual described in (2), the exemp-
particular industry for an employer. That amount
                                                      tion from tax applies for not more than 2 years         • Income from personal services performed
is a continuation of salary and is not received to                                                              in the United States of up to $2,000 for
                                                      from the date the individual first arrived in the
study or acquire experience.                                                                                    each tax year.
                                                      United States.
    For each country listed there is a statement
                                                                                                               An individual is entitled to the benefit of this
of the conditions under which the exemption
                                                      Barbados                                              exemption for a maximum of 5 years.
applies to students and apprentices from that
                                                                                                                An individual who is a resident of Belgium on
country.
                                                      A student or business apprentice who is a resi-       the date of arrival in the United States and who
    Amounts 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 is
Visiting 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 12
as a grant, allowance, or award for purposes of       payments received from outside the United             consecutive months on up to $5,000 received
whether an exemption is provided by treaty.           States for the individual’s maintenance, educa-       for personal services if the individual is in the
Amounts received from NIH under the Visiting          tion, or training.                                    United States primarily to:

Publication 901 (April 2008)                                                                                                                          Page 19
  • Acquire technical, professional, or busi-           under contract with, a resident of a C.I.S. mem-      Czech Republic
     ness experience from a person other than           ber is exempt from U.S. income tax on the
     that resident of Belgium or other than a           amounts received from that resident. Also ex-         An individual who is a resident of the Czech
     person related to that resident, or                empt is an amount received from U.S. sources,         Republic at the beginning of his or her visit to the
                                                                                                              United States and who is temporarily present in
  • Study at an educational institution.                of not more than $10,000, that is necessary to
                                                                                                              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
   An individual who is a resident of Belgium on        emption contained in this paragraph is limited to
                                                                                                              years. To be entitled to the exemption, the indi-
the date of arrival in the United States and who        1 year.                                               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
program sponsored by the U.S. Government                                                                        • Studying at a university or other accred-
                                                        United States under an exchange program pro-
primarily to train, research, or study is exempt                                                                   ited educational institution in the United
                                                        vided for by an agreement between govern-                  States,
from U.S. income tax on income received for
                                                        ments on cooperation in various fields of
personal services for the training, research, or
                                                        science and technology is exempt from U.S.              • Obtaining training required to qualify him
study in the amount of $10,000.                                                                                    or her to practice a profession or profes-
                                                        income tax on all income received in connection
                                                        with the exchange program for a period not                 sional specialty, or

Canada                                                  longer than 1 year.                                     • Studying or doing research as a recipient
                                                                                                                   of a grant, allowance, or award from a
A full-time student, trainee, or business appren-                                                                  governmental, religious, charitable, scien-
tice who is or was a Canadian resident immedi-          Cyprus                                                     tific, literary, or educational organization.
ately before visiting the United States is exempt
                                                        An individual who is a resident of Cyprus on the      If the individual meets any of these require-
from U.S. income tax on amounts received from
                                                        date of arrival in the United States and who is       ments, the following amounts are exempt from
sources outside the United States for mainte-
                                                        temporarily here primarily to study at a university   U.S. tax.
nance, education, or training.
    Also see Publication 597, Information on the        or other recognized educational institution in the      • The payments from abroad, other than
United States – Canada Income Tax Treaty.               United States, obtain professional training, or            compensation for personal services, for
                                                        study or do research as a recipient of a grant,            the purpose of maintenance, education,
                                                        allowance, or award from a governmental, relig-            study, research, or training.
China, People’s Republic of                             ious, charitable, scientific, literary, or educa-       • The grant, allowance, or award.
                                                        tional organization is exempt from U.S. income
A student, business apprentice, or trainee who          tax on the following amounts.                           • The income from personal services per-
is a resident of the People’s Republic of China                                                                    formed in the United States of up to
on the date of arrival in the United States and           • Gifts from abroad for maintenance, educa-              $5,000 for the tax year.
who is present in the United States solely to               tion, or training.
obtain training, education, or special technical          • The grant, allowance, or award.                     An individual who is a Czech resident at the
experience is exempt from U.S. income tax on                                                                  beginning of the visit to the United States and
the following amounts.                                    • Income from personal services performed           who is temporarily present in the United States
                                                            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 to
     training.                                             An individual is entitled to this exemption for    $8,000 received for personal services if the indi-
  • Grants or awards from a government, sci-            up to 5 tax years and for an additional period as     vidual is in the United States primarily to:
     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
  • Income from personal services performed             professional degree from a recognized educa-               the Czech resident, or
     in the United States of up to $5,000 for           tional institution.
                                                                                                                • Study at a university or other accredited
     each tax year.                                         An individual who is a resident of Cyprus on           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 the
for the time reasonably necessary to complete           contract with, a resident of Cyprus is exempt         time he or she becomes temporarily present in
the 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 longer
                                                        of $7,500 if the individual is in the United States   than 1 year as a participant in a program spon-
Commonwealth of                                         primarily to either:                                  sored by the U.S. Government for the primary
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
ber and who is temporarily in the United States                                                               come from personal services for that training,
                                                            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 income
research institution or to obtain training for quali-
fication in a profession or specialty is exempt           • Study at a university or other recognized         from research undertaken primarily for the pri-
                                                            educational institution.                          vate benefit of a specific person or persons.
from U.S. income tax on amounts received as
stipends, scholarships, or other substitute al-
lowances necessary to provide ordinary living              An individual who is a resident of Cyprus on
                                                        the date of arrival in the United States and who      Denmark
expenses. An individual is entitled to the benefit
of this exemption for a maximum of 5 years and          is temporarily here for a period of not more than     A student, apprentice, or business trainee who
for less than $10,000 in each tax year.                 1 year as a participant in a program sponsored        is a resident of Denmark immediately before
    An individual who is a resident of a C.I.S.         by the U.S. Government primarily to train, re-        visiting the United States and is in the United
member and who is temporarily in the United             search, or study is exempt from U.S. income tax       States for the purpose of full-time education at
States primarily to acquire technical, profes-          on income for personal services for the training,     an accredited educational institution, or full-time
sional, or commercial experience or perform             research, or study. This exemption is limited to      training, is exempt from U.S. income tax on
technical services and who is an employee of, or        $10,000.                                              amounts received from sources outside the


Page 20                                                                                                                         Publication 901 (April 2008)
United States for the individual’s maintenance,         governmental, religious, charitable, scientific, lit-       An individual is entitled to this benefit and the
education, or training.                                 erary, or educational organization is exempt             benefit described earlier under Professors,
    Apprentices and business trainees are enti-         from U.S. income tax on the following amounts.           Teachers, and Researchers for a maximum of 5
                                                                                                                 tax years.
tled to the benefit of this exemption for a maxi-         • Payments from abroad, other than com-
mum period of 3 years.                                       pensation for personal services, for main-              This exemption does not apply to income
    The exemption does not apply to income                   tenance, education, study, research, or             from research carried on mainly for the private
from research undertaken primarily for the pri-              training.                                           benefit of any person rather than in the public
vate benefit of a specific person or persons.                                                                    interest.
                                                          • The grant, allowance, or award.                          An individual who is a resident of France on
                                                          • Income from personal services performed              the date of arrival in the United States and who
Egypt                                                        in the United States of up to $5,000 for            is in the United States as an employee of, or
                                                             each tax year.                                      under contract with, a resident of France is ex-
An individual who is a resident of Egypt on the                                                                  empt from U.S. income tax for a period of 12
date of arrival in the United States and who is           An individual is entitled to the benefit of this       consecutive months on up to $8,000 received
temporarily in the United States primarily to           exemption for a maximum of 5 years.                      for personal services if the individual is in the
study at a university or other recognized educa-                                                                 United States primarily to:
                                                            An individual who is a resident of Estonia on
tional institution in the United States, obtain pro-
fessional training, or study or do research as a
                                                        the date of arrival in the United States and who           • Acquire technical, professional, or busi-
                                                        is in the United States as an employee of, or                 ness experience from a person other than
recipient of a grant, allowance, or award from a        under contract with, a resident of Estonia is                 that resident of France, or
governmental, religious, charitable, scientific, lit-   exempt from U.S. income tax for a period of 12
erary, or educational organization is exempt            consecutive months on up to $8,000 received                • Study at an educational institution.
from U.S. income tax on the following amounts.          for personal services if the individual is in the
  • Gifts from abroad for maintenance, educa-           United States primarily to:                              Germany
     tion, study, research, or training.                  • Acquire technical, professional, or busi-
  • The grant, allowance, or award.                          ness experience from a person other than               Note. See the effective dates of the protocol
                                                             that resident of Estonia, or                        under What’s New at the beginning of this publi-
  • Income from personal services performed
     in the United States of up to $3,000 each            • Study at an educational institution.                 cation. The only change under the protocol that
                                                                                                                 applies to students and business apprentices
     tax year.
                                                           An individual who is a resident of Estonia on         increases the compensation for dependent per-
                                                        the date of arrival in the United States and who         sonal services that is exempt from U.S. tax from
   An individual is entitled to the benefit of this
                                                        is temporarily present in the United States for          $5,000 to $9,000.
exemption for a maximum of 5 tax years and for
                                                        not longer than 1 year as a participant in a                 A student or business apprentice (including
any 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 a
ments as a candidate for a postgraduate or
                                                        from U.S. income tax on income received for              resident of Germany and who is present in the
professional degree from a recognized educa-
                                                        personal services for the training, research, or         United States for full-time education or training
tional 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 income
the date of arrival in the United States and who                                                                 tenance, education, or training.
                                                        from research carried on mainly for the private
is temporarily in the United States as an em-
                                                        benefit of any person rather than in the public              An individual who is or was immediately
ployee of, or under contract with, a resident of
                                                        interest.                                                before visiting the United States a resident of
Egypt is exempt from U.S. income tax for a
                                                                                                                 Germany is exempt from U.S. tax on amounts
period of 12 consecutive months on up to $7,500                                                                  received as a grant, allowance, or award from a
received for personal services if the individual is     Finland                                                  nonprofit religious, charitable, scientific, literary,
in the United States primarily to:                                                                               or educational organization.
  • Acquire technical, professional, or busi-           A full-time student, trainee, or business appren-
                                                                                                                     Individuals described in the previous two
                                                        tice who is a resident of Finland immediately
     ness experience from a person other than                                                                    paragraphs are also exempt from U.S. tax on
                                                        before visiting the United States is exempt from
     that resident of Egypt or other than a per-                                                                 compensation for dependent personal services
                                                        U.S. income tax on amounts received from
     son related to that resident, or                                                                            of up to $9,000 per year if:
                                                        sources outside the United States for mainte-
  • Study at a university or other educational          nance, education, or training.                             • They are present in the United States for
     institution.                                                                                                     not more than 4 years, and

                                                        France                                                     • The services are performed for the pur-
   An individual who is a resident of Egypt on the
                                                                                                                      pose of supplementing funds available
date of arrival in the United States and who is
                                                        An individual who is a resident of France on the              otherwise for maintenance, education, or
temporarily in the United States for no more than                                                                     training.
1 year as a participant in a program sponsored          date of arrival in the United States and who is
                                                        temporarily in the United States primarily to
by the U.S. Government primarily to train, re-                                                                       If the individual’s visit exceeds 4 years, the
                                                        study 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 the
                                                        tional institution in the United States, obtain pro-
on income received for personal services for the                                                                 competent authorities of Germany and the
                                                        fessional training, or study, or do research as a
training, research, or study for a maximum of                                                                    United States agree otherwise.
                                                        recipient of a grant, allowance, or award from a
$10,000.
                                                        not-for-profit governmental, religious, charitable,            An individual who is a resident of Germany
                                                        scientific, artistic, cultural, or educational organi-   and who is employed by a German enterprise or
                                                        zation is exempt from U.S. income tax on the             by a nonprofit religious, charitable, scientific,
Estonia                                                 following amounts.                                       literary, or educational organization is exempt
                                                                                                                 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 grant, allowance, or award.                        • The individual is temporarily in the United
study at a university or other accredited educa-                                                                      States for not more than 1 year to acquire
tional 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 her
recipient of a grant, allowance, or award from a             tax year.                                                employer, and

Publication 901 (April 2008)                                                                                                                                 Page 21
  • The compensation is not more than                   program sponsored by the U.S. Government               Ireland
     $10,000.                                           primarily to train, research, or study is exempt
                                                        from U.S. income tax on income received for            A student, apprentice, or business trainee who
If the compensation is more than $10,000, none                                                                 is a resident of Ireland immediately before visit-
of the income is exempt.                                personal services for the training, research, or
                                                                                                               ing the United States and is in the United States
                                                        study for a maximum of $10,000.
                                                                                                               for the purpose of full-time education at a recog-
Greece                                                                                                         nized educational institution or full-time training
                                                                                                               is exempt from U.S. income tax on amounts
A student or business apprentice who is a resi-         India
                                                                                                               received from sources outside the United States
dent of Greece and is temporarily in the United
                                                        An individual who is a resident of India immedi-       for the individual’s maintenance, education, or
States only to study or acquire business experi-
                                                        ately before visiting the United States and who is     training.
ence is exempt from U.S. income tax on
amounts received from sources outside the               temporarily in the United States primarily for             Apprentices and business trainees are enti-
United States for maintenance or studies.               studying or training is exempt from U.S. income        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-
                                                        ment in the United States or paid by a U.S.            Israel
An individual who is a resident of Hungary im-
                                                        citizen or resident, the U.S. Government, or any
mediately before arrival in the United States and                                                              An individual who is a resident of Israel on the
is here for full-time education or training is ex-      of its agencies, instrumentalities, political subdi-
                                                                                                               date of arrival in the United States and who is
empt from U.S. income tax on payments re-               visions, or local authorities.
                                                                                                               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-
    The full-time student or trainee may instead        vidual described in the previous paragraph may         fessional training, or study or do research as a
choose to be treated as a resident alien of the         be eligible to deduct exemptions for his or her        recipient of a grant, allowance, or award from a
United States for U.S. income tax purposes.             spouse and dependents and the standard de-             governmental, religious, charitable, scientific, lit-
Once made, the choice applies for the entire            duction. The individual must file Form 1040NR          erary, or educational organization is exempt
period that the individual remains qualified for        or Form 1040NR-EZ to claim these amounts.              from U.S. income tax on the following 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
                                                        or customarily required to complete studying or          • Income from personal services performed
Iceland                                                                                                             in the United States of up to $3,000 each
                                                        training.
                                                                                                                    tax year.
An individual who is a resident of Iceland on the
date of arrival in the United States and who is
                                                                                                                 An individual is entitled to the benefit of this
temporarily in the United States primarily to           Indonesia
                                                                                                               exemption for a maximum of 5 tax years.
study at a university or other recognized educa-
tional institution in the United States, obtain pro-    An individual who is a resident of Indonesia
                                                                                                                   An individual who is a resident of Israel on
fessional training, or study or do research as a        immediately before visiting the United States
                                                                                                               the date of arrival in the United States and who
recipient of a grant, allowance, or award from a        and who is temporarily in the United States is         is temporarily in the United States as an em-
governmental, religious, charitable, scientific, lit-   exempt from U.S. income tax on certain                 ployee of, or under contract with, a resident of
erary, or educational organization is exempt            amounts for a period of up to 5 years. To be           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 $7,500
  • Gifts from abroad for maintenance, educa-           temporarily in the United States for full-time         received for personal services if the individual is
     tion, study, research, or training.                study at a U.S. university, school, or other recog-    in the United States primarily to:
                                                        nized educational institution, or for full-time
  • The grant, allowance, or award.                                                                              • Acquire technical, professional, or busi-
                                                        study, research, or training as a recipient of a
                                                                                                                    ness experience from a person other than
  • Income from personal services performed             grant, allowance, or award from either the U.S.             that resident of Israel or other than a per-
     in the United States of up to $2,000 each          or Indonesian Government, a scientific, educa-              son related to that resident, or
     tax year.                                          tional, religious, or charitable organization, or
                                                        under a technical assistance program entered             • Study at a university or other educational
  An individual is entitled to the benefit of this      into by either the U.S. or Indonesian Govern-               institution.
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
    An individual who is a resident of Iceland on       quirements, the following amounts are exempt
                                                                                                               date of arrival in the United States and who is
the date of arrival in the United States and who        from tax.                                              temporarily in the United States for no more than
is temporarily in the United States as an em-             • All payments from abroad for mainte-               1 year as a participant in a program sponsored
ployee of, or under contract with, a resident of                                                               by the U.S. Government primarily to train, re-
                                                             nance, education, study, research, or
Iceland is exempt from U.S. income tax for a                                                                   search, or study is exempt from U.S. income tax
                                                             training.
period of 12 consecutive months on up to $5,000                                                                on income received for personal services for the
received for personal services if the individual is       • The grant, allowance, or award.                    training, research, or study for a maximum of
in the United States primarily to:
                                                          • Income from personal services performed            $10,000.
  • Acquire technical, professional, or busi-                in the United States of up to $2,000 each
     ness experience from a person other than                tax year.
     that resident of Iceland or other than a                                                                  Italy
     person related to that person, or                    An individual who is a resident of Indonesia         A student or business apprentice (trainee) who
  • Study at an educational institution.                immediately before visiting the United States          is a resident of Italy on the date of arrival in the
                                                        and is temporarily in the United States only as a      United States and who is temporarily in the
   An individual who is a resident of Iceland on        business or technical apprentice is exempt from        United States only for education or training is
the date of arrival in the United States and who        U.S. income tax for a period of 12 consecutive         exempt from U.S. income tax on amounts re-
is temporarily present in the United States for         months on up to $7,500 received for personal           ceived from outside the United States for main-
not longer than 1 year as a participant in a            services.                                              tenance, education, and training.

Page 22                                                                                                                            Publication 901 (April 2008)
Jamaica                                                   The individual is entitled to this exemption           • The grant, allowance, or award.
                                                       only for a period of time necessary to complete
A student who is a resident of Jamaica on the          the study, training, or research, but the exemp-
                                                                                                                 • Income from personal services performed
date of arrival in the United States and is here for                                                                in the United States of up to $5,000 for
                                                       tion for training or research may not extend for a
full-time education or training is exempt from                                                                      each tax year.
                                                       period exceeding 5 years.
U.S. income tax on payments received from
                                                           These exemptions do not apply to income                An individual is entitled to the benefit of this
outside 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 on
     An individual who is a resident of Jamaica on
the date of arrival in the United States and who                                                               the date of arrival in the United States and who
is temporarily in the United States as an em-                                                                  is in the United States as an employee of, or
                                                       Korea, Republic of                                      under contract with, a resident of Latvia is ex-
ployee of, or under contract with, a resident of
Jamaica is exempt from U.S. income tax for a           An individual who is a resident of the Republic of      empt from U.S. income tax for a period of 12
period of 12 consecutive months on up to $7,500        Korea on the date of arrival in the United States       consecutive months on up to $8,000 received
of net income from personal services if the indi-      and who is temporarily in the United States pri-        for personal services if the individual is in the
vidual is in the United States primarily to:           marily to study at a university or other recog-         United States primarily to:
  • Acquire technical, professional, or busi-          nized educational institution in the United               • Acquire technical, professional, or busi-
     ness experience from a person other than          States, obtain professional training, or study or            ness experience from a person other than
     that resident of Jamaica or other than a          do research as a recipient of a grant, allowance,            that resident of Latvia, or
     person related to that resident, or               or award from a governmental, religious, chari-
                                                       table, scientific, literary, or educational organi-       • Study at an educational institution.
  • Study at a university or other recognized          zation is exempt from U.S. income tax on the
     educational institution.                          following amounts.                                         An individual who is a resident of Latvia on the
                                                                                                               date of arrival in the United States and who is
   An individual who qualifies for one of the ex-        • Amounts from abroad for maintenance,                temporarily present in the United States for not
emptions discussed above may instead choose                 education, study, research, or training.           longer than 1 year as a participant in a program
to be treated as a resident alien of the United          • The grant, allowance, or award.                     sponsored by the U.S. Government primarily to
States for all U.S. income tax purposes. Once                                                                  train, research, or study is exempt from U.S.
made, the choice applies for the entire period           • Income from personal services performed             income tax on income received for personal
that the individual remains qualified for exemp-            in the United States of up to $2,000 each
                                                                                                               services for the training, research, or study in the
tion and may not be revoked unless permission               tax year.
                                                                                                               amount of $10,000.
is obtained from the U.S. competent authority.                                                                     These provisions do not apply to income
                                                         An individual is entitled to the benefit of this
                                                       exemption for a maximum of 5 years.                     from research carried on mainly for the private
                                                                                                               benefit of any person rather than in the public
Japan                                                      An individual who is a resident of Korea on         interest.
                                                       the date of arrival in the United States and who
A 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
United States and is in the United States for the                                                              Lithuania
                                                       Korea is exempt from U.S. income tax for 1 year
purpose 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 on
U.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 who
abroad for the individual’s maintenance, educa-
                                                         • Acquire technical, professional, or busi-           is temporarily in the United States primarily to
tion, or training.
                                                            ness experience from a person other than           study at a university or other accredited educa-
     Business apprentices are entitled to the ben-                                                             tional institution in the United States, obtain pro-
efit of this exemption for a maximum period of 1            that resident of Korea or other than a per-
                                                            son related to that resident, or                   fessional training, or study or do research as a
year.
                                                                                                               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
student and trainee benefits under the former             An individual who is a resident of Korea on the      from U.S. income tax on the following amounts.
treaty may continue to claim those benefits for        date of arrival in the United States and who is
as long as the individual would have been enti-        temporarily present in the United States for not          • Payments from abroad, other than com-
tled to those benefits under that treaty.              longer than 1 year as a participant in a program             pensation for personal services, for main-
                                                       sponsored by the U.S. Government primarily to                tenance, education, study, research, or
                                                       train, research, or study is exempt from U.S.                training.
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       maximum of $10,000.                                       • Income from personal services performed
the beginning of his or her visit to the United                                                                     in the United States of up to $5,000 for
States is exempt from U.S. tax on payments                                                                          each tax year.
from abroad for maintenance, education, study,         Latvia
research, or training and on any grant, allow-                                                                   An individual is entitled to the benefit of this
ance, or other similar payments. To be entitled        An individual who is a resident of Latvia on the        exemption for a maximum of 5 years.
to the exemption, the individual must be tempo-        date of arrival in the United States and who is             An individual who is a resident of Lithuania
rarily present in the United States primarily to:      temporarily in the United States primarily to           on the date of arrival in the United States and
                                                       study at a university or other accredited educa-
  • Study at a university or other accredited          tional institution in the United States, obtain pro-
                                                                                                               who is in the United States as an employee of, or
     educational institution,                                                                                  under contract with, a resident of Lithuania is
                                                       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 the
     specialty, 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 than
     ments from a governmental, religious,                  pensation for personal services, for main-
                                                                                                                    that resident of Lithuania, or
     charitable, scientific, literary, or educa-            tenance, education, study, research, or
     tional organization.                                   training.                                            • Study at an educational institution.

Publication 901 (April 2008)                                                                                                                              Page 23
   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 on
the date of arrival in the United States and who        versity, college, or school or securing training as     the date of arrival in the United States and who
is temporarily present in the United States for         a business apprentice is exempt from U.S. in-           is in the United States as an employee of, or
not longer than 1 year as a participant in a            come tax on the following amounts.                      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 received
                                                             education, or training.
from U.S. income tax on income received for                                                                     for personal services if the individual is in the
personal services for the training, research, or          • Income from personal services performed             United States primarily to:
study in the amount of $10,000.                              in the United States of up to $2,000 each
                                                             tax year.                                            • Acquire technical, professional, or busi-
    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 a
benefit of any person rather than in the public            The individual is entitled to this exemption
                                                        only for a period of time considered reasonable              person related to that resident of Norway,
interest.                                                                                                            or
                                                        or customarily required to complete studying or
                                                        training.                                                 • Study at an educational institution.
Luxembourg                                                  An individual who immediately before visiting
                                                        the United States is a resident of the Nether-             Also exempt is a resident of Norway who is
A student, apprentice, or business trainee who          lands and is temporarily present in the United          present in the United States for not longer than 1
is a resident of Luxembourg immediately before          States for a period not exceeding 3 years for the       year as a participant in a program sponsored by
visiting the United States and is in the United         purpose of study, research, or training solely as       the Government of the United States primarily to
States for the purpose of full-time education at a      a recipient of a grant, allowance, or award from a      train, research, or study. The individual is ex-
recognized educational institution or full-time         scientific, educational, religious, or charitable or-   empt from tax on income from personal services
training is exempt from U.S. income tax on              ganization or under a technical assistance pro-         performed in the United States and received for
amounts received for the individual’s mainte-           gram entered into by either the Netherlands or          the training, research, or study, for a maximum
nance, education, or training.                          the United States, or its political subdivisions or     of $10,000.
    Apprentices and business trainees are enti-         local authorities is exempt from U.S. income tax
tled 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 United
longer than 2 years, the exemption is lost for the
entire visit unless the competent authorities of          • Income of up to $2,000 for personal serv-           States are exempt from U.S. income tax on
Luxembourg and the United States agree other-                ices performed in the United States for            certain income they may receive. To be entitled
wise.                                                        any tax year if the services are connected         to this exemption, they must be in the United
                                                             with, or incidental to, the study, research,       States only as students at a recognized univer-
                                                             or training.                                       sity, college, or school, or as recipients of grants,
Mexico                                                                                                          allowances, or awards from religious, charitable,
                                                           An individual is not entitled to these exemp-        scientific, or educational organizations of Paki-
A student or business apprentice who is a resi-         tions if, during the immediately preceding pe-          stan primarily to study or research. The income
dent of Mexico immediately before visiting the          riod, the individual claimed the exemption              exempt in these cases is any payment from
United States and is in the United States solely        discussed earlier under Professors, Teachers,           abroad for maintenance, education, or training,
for the purpose of education or training is ex-         and Researchers.                                        and any pay for personal services of not more
empt from U.S. tax on amounts received from                                                                     than $5,000 for any tax year.
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 of
                                                        A resident of New Zealand or an individual who          not more than $6,000 received for that period,
Morocco                                                 was a resident of New Zealand immediately               including pay from the enterprise or organization
                                                        before 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 contract
is 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 and
tional 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.
governmental, religious, charitable, scientific, lit-   An individual who is a resident of Norway on the
                                                        date of arrival in the United States and who is             Also exempt from U.S. income tax on certain
erary, or educational organization is exempt
                                                        temporarily in the United States primarily to           income are residents of Pakistan temporarily in
from U.S. income tax on the following amounts.
                                                        study at a university or other recognized educa-        the United States under an arrangement with
  • Gifts from abroad for maintenance, educa-           tional institution in the United States, obtain pro-    the U.S. Government, or any of its agencies or
     tion, study, research, or training.                fessional training, or study or do research as a        instrumentalities, only for study, training, or ori-
                                                                                                                entation. They are exempt from tax on income of
  • The grant, allowance, or award.                     recipient of a grant, allowance, or award from a
                                                        governmental, religious, charitable, scientific, lit-   not more than $10,000 for services directly re-
  • Income from personal services performed             erary, or educational organization is exempt            lated to their training, study, or orientation, in-
     in the United States of up to $2,000 each          from U.S. income tax on the following amounts.          cluding income from their employer abroad.
     tax year.
                                                          • Gifts from abroad for maintenance, educa-
  An individual is entitled to the benefit of this           tion, study, research, or training.                Philippines
exemption for a maximum of 5 years.                       • The grant, allowance, or award.                     An individual who is a resident of the Philippines
                                                          • Income from personal services performed             on the date of arrival in the United States and
Netherlands                                                  in the United States up to $2,000 each tax         who is temporarily in the United States primarily
                                                             year.                                              to study at a university or other recognized edu-
An individual who immediately before visiting                                                                   cational institution in the United States, obtain
the United States is a resident of the Nether-            An individual is entitled to the benefit of this      professional training, or study or do research as
lands and who is present in the United States           exemption for a maximum of 5 tax years.                 a recipient of a grant, allowance, or award from a

Page 24                                                                                                                           Publication 901 (April 2008)
governmental, religious, charitable, scientific, lit-     • Acquire technical, professional, or busi-             • Income from personal services performed
erary, or educational organization is exempt                 ness experience from a person other than                in the United States of up to $2,000 each
from U.S. income tax on the following amounts.               that resident of Poland or other than a                 tax year.
                                                             person related to that resident, or
  • Gifts from abroad for maintenance, educa-                                                                      An individual is entitled to the benefit of this
     tion, study, research, or training.                  • Study at an educational institution.
                                                                                                                exemption for a maximum of 5 years.
  • The grant, allowance, or award.                        An individual who is a resident of Poland on             An individual who is a resident of Romania
  • Income from personal services performed             the date of arrival in the United States and who        on the date of arrival in the United States and
     in the United States of up to $3,000 each          is temporarily in the United States for not longer      who is temporarily in the United States as an
                                                        than 1 year as a participant in a program spon-         employee of, or under contract with, a resident
     tax year.
                                                        sored by the U.S. Government primarily to train,        of Romania is exempt from U.S. income tax for 1
  An individual is entitled to the benefit of this      research, or study is exempt from U.S. income           year on up to $5,000 received for personal serv-
exemption for a maximum of 5 years.                     tax on up to $10,000 of income received for             ices if the individual is in the United States pri-
                                                        personal services for the training, research, or        marily to:
   An individual who is a resident of the Philip-
                                                        study.                                                    • Acquire technical, professional, or busi-
pines on the date of arrival in the United States
and who is temporarily in the United States as                                                                       ness experience from a person other than
an employee of, or under contract with, a resi-                                                                      that resident of Romania or other than a
                                                        Portugal                                                     person related to that resident, or
dent 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 is
the 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-
  • Acquire technical, professional, or busi-                                                                   the date of arrival in the United States and who
                                                        tional institution in the United States, obtain pro-    is temporarily in the United States for not longer
     ness 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. income
  • Study at an educational institution.                erary, or educational organization is exempt            tax on up to $10,000 of income received for
                                                        from U.S. income tax on the following amounts.          personal services for the training, research, or
  An individual who is a resident of the Philip-
                                                          • Payments from abroad for maintenance,               study.
pines on the date of arrival in the United States,           education, study, research, or training.
and who is temporarily in the United States (for
no more than 1 year as a participant in a pro-            • The grant, allowance, or award.                     Russia
gram sponsored by the U.S. Government) pri-               • Income from personal services performed
marily to train, research, or study is exempt from           in the United States of up to $5,000 each          An individual who is a resident of Russia at the
U.S. income tax on income received for per-                  tax year.                                          beginning of his or her visit to the United States
sonal services for the training, research, or                                                                   is exempt from U.S. tax on payments from
study, up to a maximum of $10,000.                         An individual is entitled to the benefit of this     abroad for maintenance, education, study, re-
                                                        exemption for a maximum of 5 tax years from             search, or training and on any grant, allowance,
                                                        the date of arrival in the United States. The           or other similar payments. To be entitled to the
Poland                                                  benefits provided here and the benefits de-             exemption, the individual must be temporarily
                                                        scribed earlier under Professors, Teachers, and         present in the United States primarily to:
An individual who is a resident of Poland on the
date of arrival in the United States and who is
                                                        Researchers cannot be claimed simultaneously              • Study at a university or other accredited
                                                        or consecutively.                                            educational institution,
temporarily in the United States primarily to
                                                            An individual who is a resident of Portugal on
study at a university or other recognized educa-
                                                        the date of arrival in the United States and who          • Obtain training required to qualify him or
tional institution in the United States, obtain pro-                                                                 her to practice a profession or professional
                                                        is in the United States as an employee of, or
fessional training, or study or do research as a        under contract with, a resident of Portugal is               specialty, or
recipient of a grant, allowance, or award from a
governmental, religious, charitable, scientific, lit-
                                                        exempt from U.S. income tax for a period of 12            • Study or do research as a recipient of a
                                                        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, educa-             • Acquire technical, professional, or busi-                tional organization.
     tion, study, research, or training.                     ness experience from a person other than
                                                                                                                   The individual is entitled to this exemption
  • The grant, allowance, or award.                          that resident of Portugal, or
                                                                                                                only for a period of time necessary to complete
  • Any other payments received from Poland,              • Study at an educational institution.                the study, training, or research, but the exemp-
     except income from performing personal                                                                     tion for training or research may not extend for a
     services.                                          Romania                                                 period exceeding 5 years.
  • Income from personal services performed             An individual who is a resident of Romania on
                                                                                                                    These exemptions do not apply to income
     in the United States of up to $2,000 each                                                                  from research if it is undertaken primarily for the
                                                        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 to
                                                        study at a university or other recognized educa-
   An individual is entitled to the benefit of this
exemption for a maximum of 5 years.
                                                        tional institution in the United States, obtain pro-    Slovak Republic
                                                        fessional training, or study or do research as a
    An individual who is a resident of Poland on        recipient of a grant, allowance, or award from a        An individual who is a resident of the Slovak
the date of arrival in the United States and who        governmental, religious, charitable, scientific, lit-   Republic at the beginning of his or her visit to the
is temporarily in the United States as an em-           erary, or educational organization is exempt            United States and who is temporarily present in
ployee of, or under contract with, a resident of        from U.S. income tax on the following amounts.          the United States is exempt from U.S. income
Poland is exempt from U.S. income tax for 1                                                                     tax on certain amounts for a period of up to 5
year on up to $5,000 received for personal serv-          • Gifts from abroad for maintenance, educa-           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:                                                • The grant, allowance, or award.                     mary purpose of:

Publication 901 (April 2008)                                                                                                                               Page 25
  • Studying at a university or other accred-             • Income from personal services performed             temporarily in the United States as an employee
     ited educational institution in the United              in the United States of up to $5,000 for           of, or under contract with, a resident of Spain is
     States,                                                 each tax year.                                     exempt from U.S. income tax for a period of 12
  • Obtaining training required to qualify him          An individual is entitled to the benefit of this        consecutive months on up to $8,000 received
     or her to practice a profession or profes-         exemption for a maximum of 5 tax years and for          for personal services if the individual is in the
     sional specialty, or                               any additional period of time needed to com-            United States primarily to:

  • Studying or doing research as a recipient           plete, as a full-time student, educational require-       • Acquire technical, professional, or busi-
     of a grant, allowance, or award from a             ments as a candidate for a postgraduate or                  ness experience from a person other than
     governmental, religious, charitable, scien-        professional degree from a recognized educa-                that Spanish resident, or
                                                        tional institution.
     tific, literary, or educational organization.                                                                • Study at a university or other accredited
If the individual meets any of these require-              An individual who is a resident of Slovenia on           educational institution in the United States.
ments, the following amounts are exempt from            the date of arrival in the United States and who
U.S. tax.                                               is temporarily in the United States as an em-              Both the $5,000 and $8,000 exemptions in-
                                                        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 income
     the purpose of maintenance, education,             received for personal services if the individual is
     study, research, or training.                                                                              from research carried on mainly for the private
                                                        in the United States primarily to:                      benefit of any person rather than in the public
  • The grant, allowance, or award.                       • Acquire technical, professional, or busi-           interest.
  • The income from personal services per-                   ness experience from a person other than
     formed in the United States of up to                    that resident of Slovenia, or
                                                                                                                Sri Lanka
     $5,000 for the tax year.                             • Study at a university or other recognized
                                                             educational institution.                           A student, apprentice, or business trainee, who
  An individual who is a Slovak resident at the
                                                                                                                is a resident of Sri Lanka resident immediately
beginning of the visit to the United States and            These provisions do not apply to income from         before visiting the United States and is in the
who 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 tax
Slovak resident is exempt from U.S. income tax
                                                                                                                on amounts received from sources outside the
for a period of 12 consecutive months on up to
$8,000 received from personal services if the                                                                   United States for the individual’s maintenance,
                                                        South Africa                                            education, or training.
individual is in the United States primarily to:
                                                        A student, apprentice, or business trainee who              An individual who is a resident of Sri Lanka
  • Acquire technical, professional, or busi-                                                                   on the date of arrival in the United States and
                                                        is a resident of South Africa immediately before
     ness experience from a person other than                                                                   who is temporarily in the United States as an
                                                        visiting the United States and is in the United
     the Slovak resident, or                                                                                    employee of, or under contract with, a resident
                                                        States for the purpose of full-time education or
  • Study at a university or other accredited           training is exempt from U.S. income tax on              of Sri Lanka, or as a participant in a program
     educational institution in the United States.      amounts received from sources outside the               sponsored by the United States or by any inter-
                                                        United States for the individual’s maintenance,         national organization, is exempt from U.S. in-
   An individual who is a Slovak resident at the        education, or training.                                 come tax for a period not exceeding 1 year on up
time he or she becomes temporarily present in               Apprentices and business trainees are enti-         to $6,000 received for personal services if the
the United States and who is temporarily pres-          tled to the benefit of this exemption for a maxi-       individual is in the United States primarily to:
ent in the United States for a period not longer
than 1 year as a participant in a program spon-
                                                        mum period of 1 year.                                     • Acquire technical, professional, or busi-
sored by the U.S. government for the primary                                                                        ness experience from a person other than
purpose of training, research, or study is exempt                                                                   that resident of Sri Lanka or other than a
                                                        Spain                                                       person related to that resident, or
from 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 recognized
research, 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 primarily
from research undertaken primarily for the pri-         to study at a U.S. university or other accredited
vate benefit of a specific person or persons.           educational institution, to obtain training to be-      Sweden
                                                        come qualified to practice a profession or pro-
                                                                                                                A student, apprentice, or business trainee who
                                                        fessional specialty, or to study or do research as
Slovenia                                                                                                        is a resident of Sweden immediately before visit-
                                                        a recipient of a grant, allowance, or award from a
                                                                                                                ing the United States and is in the United States
                                                        governmental, religious, charitable, scientific, lit-
An individual who is a resident of Slovenia at the                                                              for the purpose of full-time education or training
                                                        erary, or educational organization is exempt
beginning of the visit to the United States and                                                                 is exempt from U.S. tax on amounts received
                                                        from U.S. income tax on the following amounts.
who is temporarily in the United States primarily                                                               from sources outside the United States for the
to study at a U.S. university or other recognized         • Payments from abroad (other than com-               individual’s maintenance, education, and train-
educational institution, to obtain training to be-           pensation for personal services) for main-         ing.
come qualified to practice a profession or pro-              tenance, education, study, research, or
fessional specialty, or to study or do research as           training.
a recipient of a grant, allowance, or award from a
                                                          • The grant, allowance, or award.                     Switzerland
governmental, religious, charitable, scientific, lit-
erary, or educational organization is exempt              • Income from personal services performed             A student, apprentice, or business trainee who
from U.S. income tax on the following amounts.               in the United States of up to $5,000 for           is a resident of Switzerland immediately before
                                                             each tax year.                                     visiting the United States and is in the United
  • Payments from abroad (other than com-                                                                       States for the purpose of full-time education or
     pensation for personal services) for main-         An individual is entitled to the benefit of this        training is exempt from U.S. income tax on
     tenance, education, study, research, or            exemption for a maximum of 5 years.
                                                                                                                amounts received from sources outside the
     training.
                                                          An individual who is a resident of Spain at the       United States for the individual’s maintenance,
  • The grant, allowance, or award.                     beginning of the visit to the United States and is      education, or training.



Page 26                                                                                                                          Publication 901 (April 2008)
Thailand                                                • Gifts from abroad for maintenance, educa-          Ukraine
                                                           tion, study, research, or training.
An individual who is a resident of Thailand at the                                                           An individual who is a resident of Ukraine at the
beginning of his or her visit to the United States      • The grant, allowance, or award.                    beginning of his or her visit to the United States
and who is temporarily present in the United            • Income from personal services performed            is exempt from U.S. tax on payments from
States is exempt from U.S. income tax on cer-              in the United States of up to $2,000 each         abroad for maintenance, education, study, re-
tain amounts for a period of up to 5 years. To be          tax year, or, if the individual is obtaining      search, or training and on any grant, allowance,
entitled to the exemption, the individual must be                                                            or other similar payments. To be entitled to the
                                                           training required to qualify to practice a
in 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 accredited
    States,                                             An individual is entitled to the benefit of this          educational institution,
  • Obtaining training required to qualify him        exemption for a maximum period of 5 tax years.           • Obtain training required to qualify him or
    or her to practice a profession or profes-            An individual who is a resident of Trinidad             her to practice a profession or professional
    sional specialty, or                              and Tobago on the date of arrival in the United             specialty, or
  • Studying or doing research as a recipient         States and who is in the United States as an             • Study or do research as a recipient of a
    of a grant, allowance, or award from a            employee of, or under contract with, a resident             grant, allowance, or other similar pay-
    governmental, religious, charitable, scien-       or corporation of Trinidad and Tobago is exempt             ments from a governmental, religious,
    tific, literary, or educational organization.     from U.S. income tax for 1 tax year on up to                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
U.S. tax.                                               • Study at an educational institution, or
                                                                                                             only for a period of time necessary to complete
  • Gifts from abroad for the purpose of main-          • Acquire technical, professional, or busi-          the study, training, or research, but the exemp-
    tenance, education, study, research, or                ness experience from a person other than          tion for training or research may not extend for a
    training.                                              that resident or corporation of Trinidad and      period exceeding 5 years.
                                                                                                                 These exemptions do not apply to income
  • The grant, allowance, or award.                        Tobago.
                                                                                                             from research if it is undertaken primarily for the
  • Income from personal services performed              Also exempt is a resident of Trinidad and           private benefit of a specific person or persons.
    in the United States of up to $3,000 for the      Tobago who is present in the United States for
    tax year.                                         not longer than 1 year as a participant in a
                                                      program sponsored by the U.S. Government               United Kingdom
   An individual who is a resident of Thailand at     primarily to train, research, or study. The individ-
the beginning of the visit to the United States                                                              A student or business apprentice who is a resi-
                                                      ual is exempt from tax on income from personal         dent of the United Kingdom immediately before
and who is temporarily present in the United
                                                      services performed in the United States and            visiting the United States and is in the United
States as an employee of, or under contract
with, a resident of Thailand is exempt from U.S.      received for the training, research, or study for      States for the purpose of full-time education at a
income tax for a period of 12 consecutive             up to a maximum of $10,000.                            recognized educational institution or full-time
months on up to $7,500 received from personal                                                                training is exempt from U.S. income tax on
services if the individual is in the United States                                                           amounts received from abroad for the individ-
primarily to:                                         Tunisia                                                ual’s maintenance, education, or training.
                                                                                                                  Business apprentices are entitled to the ben-
  • Acquire technical, professional, or busi-         An individual who is a resident of Tunisia imme-       efit of this exemption for a maximum period of 1
    ness experience from a person other than          diately before visiting the United States and who      year.
    the Thai resident, or                             is in the United States for full-time study or
                                                      training is exempt from U.S. income tax on the         Former treaty. An individual entitled to treaty
  • Study at a university or other recognized
                                                      following amounts.                                     benefits under Article 21 (students and trainees)
    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 have
   An 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
in the United States and who is temporarily pres-       • A grant, allowance, or award from a gov-
ent in the United States for a period not longer           ernmental, religious, charitable, scientific,
                                                           literary, or educational organization to          Venezuela
than 1 year as a participant in a program spon-
sored by the U.S. government for the primary               study or engage in research.                      An individual who is a resident of Venezuela on
purpose of training, research, or study is exempt       • Income from personal services performed            the date of arrival in the United States and who
from U.S. income tax on up to $10,000 of in-                                                                 is temporarily in the United States primarily to
                                                           in the United States of up to $4,000 in any
come 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-
                                                        The individual is entitled to this exemption for     fessional training, or study or do research as a
                                                      a maximum of 5 years.                                  recipient of a grant, allowance, or award from a
Trinidad and Tobago                                                                                          governmental, religious, charitable, scientific, lit-
                                                                                                             erary, or educational organization is exempt
An individual who is a resident of Trinidad and
                                                      Turkey                                                 from U.S. income tax on the following amounts.
Tobago 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 who
States primarily to study at a university or other                                                                pensation for personal services, for main-
accredited educational institution in the United      is a resident of Turkey immediately before visit-           tenance, education, study, research, or
States, obtain professional training, or study or     ing the United States and is in the United States           training.
do research as a recipient of a grant, allowance,     for the purpose of full-time education or training
or award from a governmental, religious, chari-       is exempt from U.S. income tax on amounts                • The grant, allowance, or award.
table, scientific, literary, or educational organi-   received from sources outside the United States          • Income from personal services performed
zation is exempt from U.S. income tax on the          for the individual’s maintenance, education, or             in the United States of up to $5,000 for
following amounts.                                    training.                                                   each tax year.


Publication 901 (April 2008)                                                                                                                            Page 27
    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. This
exemption will also apply to any additional pe-                                                                  Former treaty. Wages, salaries, similar in-
riod of time that a full-time student needs to          Bangladesh                                               come, and pensions and annuities paid by, or
complete the educational requirements as a                                                                       from public funds of, Belgium, its political subdi-
candidate for a postgraduate or professional de-        Income, other than a pension, paid by Ban-
                                                                                                                 visions, or its local authorities, to citizens of
gree from a recognized educational institution.         gladesh, its political subdivisions, or local au-
                                                                                                                 Belgium (or to citizens of countries other than
     An individual who is a resident of Venezuela       thorities to an individual for services performed
                                                                                                                 the United States or Belgium who come to the
on the date of arrival in the United States and         for the paying governmental body is exempt
                                                                                                                 United States and are employed by Belgium or
who is in the United States as an employee of, or       from U.S. income tax. However, the exemption
                                                                                                                 its political subdivisions or local authorities) for
under contract with, a resident of Venezuela is         does not apply if the services are performed in
                                                                                                                 performing governmental functions are exempt
exempt from U.S. income tax for a period of 12          the United States by a resident of the United
                                                                                                                 from U.S. tax.
months on up to $8,000 received for personal            States who either:
                                                                                                                     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 connection
primarily to:
                                                          • Did not become a U.S. resident only to               with a trade or business carried on by Belgium or
  • Acquire technical, professional, or busi-                perform the services.                               its political subdivisions or local authorities.
     ness experience from a person other than
     that resident of Venezuela, or                        Pensions paid from the public funds of Ban-
                                                        gladesh, its political subdivisions, or local au-        Canada
  • Study at an educational institution.
                                                        thorities for services performed for Bangladesh,         Wages, salaries, and similar income (other than
   These provisions do not apply to income from         its political subdivisions, or local authorities to an
                                                                                                                 pensions) paid by Canada or by a Canadian
research carried on mainly for the private benefit      individual for services performed for the paying
                                                                                                                 political subdivision or local authority to a citizen
of any person rather than in the public interest.       governmental body are exempt from U.S. in-
                                                                                                                 of Canada for performing governmental func-
                                                        come tax unless the recipient is both a resident
                                                                                                                 tions are exempt from U.S. income tax. This
                                                        and citizen of the United States.
Wages and Pensions                                           This exemption does not apply to income or
                                                                                                                 exemption does not apply, however, to pay-
Paid by a Foreign                                                                                                ments for services performed in connection with
                                                        pensions for services performed in connection
                                                                                                                 a trade or business carried on by Canada or its
Government                                              with a business carried on by Bangladesh, its
                                                                                                                 political subdivisions or local authorities.
                                                        political subdivisions, or local authorities.
Wages, salaries, pensions, and annuities paid                                                                        Also see Publication 597, Information on the
by the governments of the following countries to                                                                 United States – Canada Income Tax Treaty.
their residents who are present in the United           Barbados
States as nonresident aliens generally are ex-
empt from U.S. income tax. The conditions               Income, including a pension, paid from the pub-          China, People’s Republic of
under which the income is exempt are stated for         lic funds of Barbados, or its political subdivisions
                                                        or local authorities, to a citizen of Barbados for       Income, other than a pension, paid by the Peo-
each of the countries listed.
                                                        performing governmental functions is exempt              ple’s Republic of China or its political subdivi-
                                                        from U.S. income tax.                                    sions or local authorities to an individual for
Exemption under U.S. tax law. Employees of
                                                             However, this exemption does not apply to           services performed for the paying governmental
foreign countries who do not qualify under a tax
                                                        payments for services in connection with a busi-         body is exempt from U.S. income tax. However,
treaty provision and employees of international
                                                        ness carried on by Barbados or its political sub-        the exemption does not apply to payments for
organizations should see if they can qualify for
                                                        divisions or local authorities.                          services performed in the United States by a
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, or
exempt from U.S. tax if you perform services            Belgium
similar to those performed by U.S. government
                                                                                                                   • Did not become a U.S. resident only to
                                                                                                                      perform the services.
employees in that foreign country and that for-
                                                           Note. See the effective dates of the new
eign government grants an equivalent exemp-
                                                        treaty under What’s New at the beginning of this            Pensions paid by the People’s Republic of
tion. If you work for an international organization
                                                        publication.                                             China for services performed for China are ex-
in the United States, your salary from that
                                                                                                                 empt from U.S. income tax unless the recipient
source is exempt from U.S. tax. See chapter 10
                                                        New treaty. Wages, salaries, and similar in-             is both a citizen and a resident of the United
of 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 or
                                                        individual for services performed for the paying         pensions for services performed in connection
Australia                                               governmental body is exempt from U.S. income             with a business carried on by the People’s Re-
Salaries, wages, and similar income, including          tax. However, the exemption does not apply if            public of China or its subdivisions or local au-
pensions, paid by Australia, its political subdivi-     the services are performed in the United States          thorities.
sions, agencies, or authorities to its citizens         by a resident of the United States who either:
(other than U.S. citizens) for performing govern-         • Is a U.S. national, or
mental functions as an employee of any of the                                                                    Commonwealth of
above entities are exempt from U.S. income tax.           • Did not become a U.S. resident only to               Independent States (C.I.S.)
                                                             perform the services.
                                                                                                                 Wages, salaries, and similar income paid by the
Austria                                                   Pensions paid by, or out of funds created by,          C.I.S. or a member of the C.I.S. to its citizens for
                                                        Belgium, its political subdivisions, or local au-        personal services performed as an employee of
Wages, salaries, similar income, and pensions           thorities for services performed for Belgium, its        a governmental agency or institution of the
and 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 local
its 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 in
U.S. tax.                                               and national of the United States.                       commercial activities are not considered en-
    However, this exemption does not apply to               However, these exemptions do not apply to            gaged in the discharge of governmental func-
payments for services performed in connection           payments for services performed in connection            tions.

Page 28                                                                                                                            Publication 901 (April 2008)
Cyprus                                                 Estonia                                                 Treaty as modified. Wages, salaries, and
                                                                                                               similar 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-
pensions, annuities, and similar benefits, paid        public funds of Estonia, its political subdivisions,    ties, or instrumentalities to an individual for serv-
from public funds of Cyprus to a citizen of Cy-        or local authorities to an individual for services      ices performed for the paying governmental
prus for labor or personal services performed as       performed as an employee for the paying gov-            body is exempt from U.S. income tax. However,
an employee of Cyprus in the discharge of gov-         ernmental body in the discharge of governmen-           the exemption does not apply if the services are
ernmental functions are exempt from U.S. in-           tal functions is exempt from U.S. income tax.           performed in the United States by a resident of
                                                       However, the exemption does not apply if the            the United States who either:
come tax.
                                                       services are performed in the United States by a          • Is a U.S. national, or
                                                       resident of the United States who either:
Czech Republic                                                                                                   • Did not become a U.S. resident only to
                                                         • 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
lic funds of the Czech Republic, its political sub-         perform the services.                                 Pensions paid by, or out of funds created by,
divisions, or local authorities to a Czech citizen                                                             Germany, its political subdivisions, local authori-
                                                          Pensions paid by or from the public funds of         ties, or instrumentalities for services performed
for services performed in the discharge of gov-
                                                       Estonia, its political subdivisions, or local author-   for the paying governmental body are exempt
ernmental functions is exempt from U.S. income                                                                 from U.S. income tax unless the recipient is both
tax. This exemption does not apply to income           ities for services performed for Estonia are ex-
                                                       empt from U.S. income tax unless the recipient          a resident and a national of the United States.
paid for services performed in connection with a                                                                    This exemption does not apply to income or
                                                       is both a resident and citizen of the United
business carried on by the Czech Republic, its                                                                 pensions for services performed in connection
                                                       States.
political subdivisions, or local authorities.                                                                  with a business carried on by Germany, its politi-
                                                                                                               cal subdivisions, local authorities, or instrumen-
                                                       Finland                                                 talities.
Denmark
                                                       Income, other than a pension, paid by Finland,          Unmodified treaty. Wages, salaries, and sim-
Income, other than a pension, paid from public                                                                 ilar income and pensions paid by Germany, its
                                                       its 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 if
                                                       formed for the paying governmental body is
formed for the paying governmental body in the                                                                 paid to individuals other than U.S. citizens and
                                                       exempt from U.S. income tax. However, the
discharge of governmental functions is exempt                                                                  other than individuals admitted to the United
                                                       exemption does not apply to payments for serv-
from U.S. income tax. However, the exemption                                                                   States for permanent residence.
                                                       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
States who either:
                                                         • Is a U.S. citizen, or                               Greece
  • Is a U.S. national, or                               • Did not become a U.S. resident only to              Wages, salaries, and similar income and pen-
                                                            perform 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 services
     perform the services.                                Pensions paid by Finland for services per-           rendered to Greece or its subdivisions are ex-
                                                       formed for Finland are exempt from U.S. income          empt from U.S. income tax. This exemption
   Pensions 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 or
exempt from U.S. income tax unless the recipi-         pensions for services performed in connection
ent is a resident and a national of the United         with a trade or business carried on by Finland or       Hungary
States.                                                its political subdivisions, statutory bodies, or lo-    Income (other than a pension) paid by the Re-
    These exemptions do not apply to income or         cal authorities.                                        public of Hungary or its political subdivisions for
pensions for services performed in connection                                                                  labor or personal services performed for the
with a trade or business carried on by Denmark,                                                                paying governmental body is exempt from U.S.
                                                       France                                                  tax. However, the exemption does not apply to
its political subdivisions, or local authorities.
                                                       Income, including pensions, paid by the French          payments for services performed in the United
                                                       Government or a local authority thereof to an           States by a resident of the United States who
Egypt                                                                                                          either:
                                                       individual in the United States for services per-
Wages, salaries, and similar income, including
                                                       formed for France (or for a local authority of            • Is a U.S. citizen, or
                                                       France) in the discharge of governmental func-
pensions, annuities, and similar benefits, paid                                                                  • Did not become a resident of the United
                                                       tions is exempt from U.S. tax. This exemption
from public funds of the Arab Republic of Egypt                                                                     States only to perform the services.
                                                       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
country who comes to the United States specifi-                                                                  Pensions paid by Hungary for services per-
                                                       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 in-            come tax unless the recipient is both a citizen
labor 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 or
any of its agencies, in the discharge of govern-       business carried on by the French Government            pensions for services performed in connection
mental functions are exempt from U.S. income           (or a local authority thereof).                         with a trade or business carried on by Hungary
tax.                                                                                                           or its subdivisions.
    This exemption does not apply to U.S. citi-
zens or to alien residents of the United States.       Germany
The exemption also does not apply to payments
                                                                                                               Iceland
for services performed in connection with a              Note. See the effective dates of the protocol         Wages, salaries, and similar income, including
trade 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 from
its agencies.                                          cation.                                                 public funds of the Republic of Iceland, a political

Publication 901 (April 2008)                                                                                                                              Page 29
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. income
Iceland (other than a U.S. citizen or one admit-        visions or local authorities.                         tax. However, the exemption does not apply if
ted to the United States for permanent resi-                                                                  the services are performed in the United States
dence) for labor or personal services performed                                                               by a resident of the United States who either:
for Iceland or its political subdivisions or local      Israel
authorities in the discharge of governmental
                                                                                                                • Is a U.S. citizen, or
functions are exempt from U.S. tax.                     Wages, salaries, and similar income, including          • Did not become a U.S. resident only to
                                                        pensions and similar benefits, paid from public            perform the services.
                                                        funds by the national government of Israel or its
India                                                   agencies, for services performed in the dis-              Pensions paid by, or out of funds to which
                                                        charge 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 services
political 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 and
governmental body is exempt from U.S. income
                                                                                                              citizen of the United States.
tax. However, the exemption does not apply if
the services are performed in the United States         Italy                                                      These exemptions do not apply to income or
by a U.S. resident who either:                                                                                pensions for services performed in connection
                                                        Income, other than a pension, paid by Italy or by     with a business carried on by Japan, its political
  • Is a U.S. citizen, or                               an Italian political or administrative subdivision    subdivisions, or local authorities.
  • Did not become a U.S. resident only to              or local authority to an individual for services
     perform the services.                              performed for the paying governmental body is
                                                        exempt from U.S. income tax. However, the             Kazakhstan
   Pensions paid by India for services performed        exemption does not apply to payments for serv-
                                                        ices performed in the United States by a resident     Income, other than a pension, paid by Kazakh-
for India are exempt from U.S. tax unless the
                                                        of the United States who either:                      stan, or its subdivisions or local authorities to an
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 not
    These exemptions do not apply to income or
pensions for services performed in connection             • Did not become a U.S. resident only to            apply if the services are performed in the United
                                                            perform the services.                             States by a U.S. resident who either:
with a business carried on by India, its subdivi-
sions, or local authorities.                            The spouse and dependent children of an indi-           • Is a U.S. citizen, or
                                                        vidual, however, are not subject to the second          • Did not become a U.S. resident solely for
                                                        restriction if that individual is receiving exempt         the purpose of performing the services.
Indonesia                                               income for governmental services performed for
                                                        Italy and that individual does not come under         These exemptions do not apply to income for
Income, 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
paying governmental body is exempt from U.S.            for Italy are exempt from U.S. income tax unless         Pensions paid by Kazakhstan, or its subdivi-
income tax. However, the exemption does not             the recipient is both a citizen and a resident of     sions or local authorities for services performed
apply if the services are performed in the United       the United States.                                    for Kazakhstan is exempt from U.S. tax unless
States by a U.S. resident who either:                       These exemptions do not apply to income or        the individual is both a resident and citizen of the
                                                        pensions for services performed in connection         United States.
  • 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.
     perform the services.                                                                                    Korea, Republic of
   Pensions paid by Indonesia for services per-         Jamaica                                               Wages, salaries, and similar income, including
formed for Indonesia are exempt from U.S. tax.                                                                pensions and similar benefits, paid from public
    These exemptions do not apply to income or          Income, other than a pension, paid by the Gov-        funds of the Republic of Korea to a citizen of
pensions for services performed in connection           ernment of Jamaica or its political subdivisions      Korea (other than a U.S. citizen or an individual
with a trade or business carried on by Indonesia,       or local authorities for personal services per-       admitted to the United States for permanent
its subdivisions, or local authorities.                 formed for the paying governmental body is ex-        residence) for services performed as an em-
                                                        empt from U.S. income tax.                            ployee of Korea discharging government func-
                                                            This exemption does not apply to payments         tions are exempt from U.S. income tax.
Ireland                                                 for services performed in the United States by
                                                        an individual who is a citizen and resident of the
Income, other than a pension, paid by Ireland or        United States.                                        Latvia
its political subdivisions or local authorities to an       Pensions paid by Jamaica for services per-
individual for services performed for the paying        formed for Jamaica generally are exempt from          Income, other than a pension, paid by or from
governmental body is exempt from U.S. income            U.S. income tax. However, if the recipient of the     public funds of Latvia, its political subdivisions,
tax. However, the exemption does not apply to           pension is a citizen and resident of the United       or local authorities to an individual for services
payments for services performed in the United           States and was a U.S. citizen at the time the         performed as an employee for the paying gov-
States by a resident of the United States who           services were performed, the pension is taxable       ernmental body in the discharge of governmen-
either:                                                 in the United States.                                 tal functions is exempt from U.S. income tax.
                                                                                                              However, the exemption does not apply if the
  • Is a U.S. citizen, or                                   These exemptions do not apply to income or
                                                                                                              services are performed in the United States by a
                                                        pensions for services performed in connection
  • Did not become a U.S. resident only to              with a trade or business carried on by Jamaica        resident of the United States who either:
     perform the services.                              or its subdivisions or local authorities.               • Is a U.S. citizen, or
   Pensions paid by Ireland for services per-                                                                   • Did not become a U.S. resident only to
formed for Ireland are exempt from U.S. income          Japan                                                      perform the services.
tax unless the recipient is both a resident and
citizen of the United States.                           Income, other than a pension, paid by Japan, its         Pensions paid by or from the public funds of
     These exemptions do not apply to income or         political subdivisions, or local authorities to an    Latvia, its political subdivisions, or local authori-
pensions for services performed in connection           individual for services performed for the paying      ties for services performed for Latvia are exempt

Page 30                                                                                                                         Publication 901 (April 2008)
from U.S. income tax unless the recipient is both             These exemptions do not apply to income or        authorities in the discharge of governmental
a 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 political
                                                         subdivisions, or local authorities.
Lithuania                                                                                                       Pakistan
Income, other than a pension, paid by or from            Morocco                                                Income, including pensions and annuities, paid
public 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 a
services 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 of
ernmental functions is exempt from U.S. income           Morocco (other than a U.S. citizen or an individ-      functions of that Government or local authority is
tax. However, the exemption does not apply if            ual admitted to the United States for permanent        exempt from U.S. income tax. To be exempt
the 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                                of governmental functions are exempt from U.S.
                                                                                                                status in the United States. This exemption does
                                                                                                                not apply to payments for services performed in
  • Did not become a U.S. resident only to               income tax.
     perform the services.                                                                                      connection with any trade or business carried on
                                                                                                                for profit.
   Pensions paid by or from the public funds of          Netherlands
Lithuania, its political subdivisions, or local au-
thorities for services performed for Lithuania are       Income, other than a pension, paid by the              Philippines
exempt from U.S. income tax unless the recipi-           Netherlands, its political subdivisions, or local
                                                         authorities to an individual for services per-         Wages, salaries, and similar income, including
ent is both a resident and citizen of the United
                                                         formed for the paying governmental body is ex-         pensions, annuities, and similar benefits, paid
States.
                                                         empt from U.S. income tax. However, the                from public funds of the Republic of the Philip-
                                                         exemption does not apply if the services are           pines to a citizen of the Philippines (or to a
Luxembourg                                               rendered in the United States and the individual       citizen of another country other than the United
                                                         is a U.S. resident who either:                         States who comes to the United States specifi-
Income, other than a pension, paid by Luxem-                                                                    cally to work for the Government of the Philip-
bourg, its political subdivisions, or local authori-
                                                           • Is a U.S. national, or                             pines) for labor or personal services performed
ties to an individual for services performed for           • Did not become a U.S. resident solely for          as an employee of the national Government of
the paying governmental body is exempt from                   the purpose of performing the services.           the Philippines or any of its agencies in the
U.S. income tax. However, the exemption does                                                                    discharge of governmental functions are exempt
not 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 from
who either:                                              U.S. income tax unless the individual is both a
  • Is a U.S. citizen, or                                resident and national of the United States.            Poland
                                                             These exemptions do not apply to income or
  • Did not become a U.S. resident only to               pensions for services performed in connection          Wages, salaries, and similar income, including
     perform the services.                               with a business carried on by the Netherlands,         pensions, annuities, and similar benefits, paid
                                                         its political subdivisions, or local authorities.      from public funds of Poland to a citizen of Poland
   Pensions paid by Luxembourg, its political                                                                   (other than a U.S. citizen or one admitted to the
subdivisions, or local authorities for services                                                                 United States for permanent residence) for labor
performed for Luxembourg are exempt from                 New Zealand                                            or personal services performed as an employee
U.S. income tax unless the recipient is both a                                                                  of the national Government of Poland in the
resident and citizen of the United States.               Income (other than pensions) paid by the Gov-          discharge of governmental functions are exempt
    These exemptions do not apply to income or           ernment of New Zealand, its political subdivi-         from U.S. income tax.
pensions for services performed in connection            sions, or local authorities for services performed
with a trade or business carried on by Luxem-            in the discharge of governmental functions is
bourg, its political subdivisions, or local authori-     exempt from U.S. income tax. However, the              Portugal
ties.                                                    income is not exempt if the services are per-
                                                         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-
Mexico                                                   the United States who did not become a resident        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, the
its 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
the services are performed in the United States          for services performed in connection with any            • Is a U.S. national, or
by a U.S. resident who either:                           trade or business carried on for profit by the           • Did not become a U.S. resident only to
  • Is a U.S. national, or                               Government of New Zealand (or its subdivisions              perform the services.
                                                         or local authorities).
  • Did not become a resident of the United
                                                                                                                  Pensions 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 and
   Pensions paid by Mexico, its political subdivi-       Wages, salaries, and similar income, including         national of the United States.
sions, or local authorities for services performed       pensions and similar benefits paid by or from              These exemptions do not apply to income or
for the paying governmental body are exempt              public funds of Norway or its political subdivi-       pensions for services performed in connection
from U.S. income tax unless the individual is            sions or local authorities to a citizen of Norway      with a business carried on by Portugal or its
both a resident and national of the United               for labor or personal services performed for Nor-      political or administrative subdivisions, or local
States.                                                  way or any of its political subdivisions or local      authorities.

Publication 901 (April 2008)                                                                                                                              Page 31
Romania                                                 South Africa                                               • Did not become a U.S. resident solely for
                                                                                                                      the purpose of performing the services.
Wages, salaries, and similar income, including          Income, other than a pension, paid by South
pensions, 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 performed
Romania (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 the
ted to the United States for permanent resi-            U.S. income tax. However, the exemption does             individual is both a resident and citizen of the
dence) 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
Romania in the discharge of governmental func-          States who either:                                           These exemptions do not apply to income or
tions are exempt from U.S. income tax.                                                                           pensions for services performed in connection
                                                          • Is a U.S. citizen, or                                with a business carried on by Sweden, its politi-
                                                          • Did not become a U.S. resident only to               cal subdivisions, or local authorities.
Russia                                                       perform the services.

Income, other than a pension, paid by Russia, its         Pensions paid by South Africa for services             Switzerland
republics, or local authorities to an individual for    performed for South Africa are exempt from U.S.
government services is exempt from U.S. tax.            income tax unless the recipient is both a resident       Income, other than a pension, paid by Switzer-
However, the exemption does not apply if the            and citizen of the United States.                        land or its political subdivisions or local authori-
services are performed in the United States by a                                                                 ties to an individual for services performed for
U.S. resident who either:                                   These exemptions do not apply to income or
                                                                                                                 the paying governmental body is exempt from
                                                        pensions for services performed in connection
  • Is a U.S. citizen, or                                                                                        U.S. income tax. However, the exemption does
                                                        with a business carried on by South Africa or its
                                                                                                                 not apply to payments for services performed in
  • Did not become a U.S. resident solely for           subdivisions or local authorities.
                                                                                                                 the United States by a resident of the United
     the purpose of performing the services.                                                                     States who either:

  Pensions paid by Russia, its republics, or lo-        Spain                                                      • Is a U.S. citizen, or
cal authorities for services performed for Russia       Income, other than a pension, paid by Spain, its           • Did not become a U.S. resident only to
are 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 services
pensions 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:
Slovak Republic                                                                                                      These exemptions do not apply to income or
                                                          • Is a U.S. citizen, or                                pensions for services performed in connection
Income, including a pension, paid from the pub-                                                                  with a business carried on by Switzerland or its
lic funds of the Slovak Republic, its political           • Did not become a U.S. resident only to
                                                             perform the services.                               subdivisions or local authorities.
subdivisions, or local authorities to a Slovak
citizen for services performed in the discharge of
governmental functions is exempt from U.S. in-             Pensions paid by Spain, its political subdivi-
                                                        sions, or local authorities for services performed       Thailand
come tax. This exemption does not apply to
income paid for services performed in connec-           for Spain are exempt from U.S. tax unless the            Income, other than a pension, paid by Thailand
tion with a business carried on by the Slovak           individual is both a citizen and resident of the         or its political subdivisions or local authorities to
Republic, its political subdivisions, or local au-      United States.
                                                                                                                 an individual for services performed for the pay-
thorities.                                                  These exemptions do not apply to income or           ing governmental body is exempt from U.S. in-
                                                        pensions for services performed in connection            come tax. However, the exemption does not
                                                        with 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 States
                                                                                                                 who either:
Income, other than a pension, paid from public
funds of Slovenia, its political subdivisions, or       Sri Lanka                                                  • Is a U.S. citizen, or
local authorities to an individual for services per-
formed for the paying governmental body in the          Income, including a pension, paid from the pub-            • Did not become a U.S. resident only to
discharge of governmental functions is exempt           lic funds of Sri Lanka, its political subdivisions, or        perform the services.
from U.S. income tax. However, the exemption            local authorities to a citizen or national of Sri
does not apply if the services are performed in         Lanka for services performed for Sri Lanka in the          Pensions paid by Thailand for services per-
the United States by a resident of the United           discharge of functions of a governmental nature          formed for Thailand are exempt from U.S. in-
States who either:                                      is exempt from U.S. income tax. This exemption           come tax unless the recipient is both a resident
                                                        does not apply to income paid for services per-          and citizen of the United States.
  • Is a U.S. citizen, or                               formed in connection with a business carried on              These exemptions do not apply to income or
  • Did not become a U.S. resident only to              by Sri Lanka, its political subdivisions, or local       pensions for services performed in connection
     perform the services.                              authorities.                                             with a business carried on by Thailand or its
                                                                                                                 subdivisions or local authorities.
   Pensions paid from the public funds of Slove-
nia, its political subdivisions, or local authorities   Sweden
for services performed for Slovenia in the dis-                                                                  Trinidad and Tobago
charge of governmental functions are exempt             Income, other than a pension, paid by Sweden,
from U.S. income tax unless the recipient is both       its political subdivisions, or local authorities to an   Wages, salaries, and similar income and pen-
a resident and citizen of the United States.            individual for services performed for the paying         sions, annuities, and similar benefits paid by or
                                                        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 for
                                                        the services are performed in the United States          services performed for Trinidad and Tobago in
                                                        by a U.S. resident who either:
                                                                                                                 the discharge of governmental functions are ex-
                                                          • Is a U.S. citizen, or                                empt from U.S. tax.

Page 32                                                                                                                            Publication 901 (April 2008)
Tunisia                                                 subdivisions, or local authorities to an individual    rents, and royalties. The income code numbers
                                                        for services performed for the paying govern-          shown in this table are the same as the income
Income, other than a pension, paid by Tunisia,          mental body is exempt from U.S. income tax.            codes on Form 1042-S, Foreign Person’s U.S.
its political subdivisions, or local authorities to a   However, the exemption does not apply if the           Source Income Subject to Withholding.
Tunisian citizen for personal services performed
                                                        services are performed in the United States by a
in the discharge of governmental functions is                                                                  Interest. If you are a nonresident alien who
                                                        resident of the United States who either:
exempt from U.S. income tax.                                                                                   receives interest that is not effectively con-
    Pensions paid by Tunisia, its political subdi-        • Is a U.S. citizen, or                              nected with the conduct of a U.S. trade or busi-
visions, or local authorities for services per-
                                                          • Did not become a U.S. resident only to             ness, you do not include the interest in income if
formed for Tunisia are exempt from U.S. income                                                                 it is paid on deposits with banks, on accounts or
                                                             perform 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, the
pensions for services performed in connection                                                                  These amounts are exempt from U.S. tax even
                                                        United Kingdom, its political subdivisions, or lo-
with a trade or business carried on by Tunisia, its                                                            though they are considered to be income from a
political subdivisions, or local authorities.           cal authorities for services performed for the
                                                        United Kingdom are exempt from U.S. income             U.S. source. Also exempt from U.S. tax (al-
                                                        tax unless the recipient is both a resident and        though considered from U.S. sources) is certain
                                                        citizen of the United States.                          portfolio interest on obligations issued after July
Turkey                                                                                                         18, 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 connection
its political subdivisions or local authorities to an
                                                        with a business carried on by the United King-
individual for services performed for the paying
                                                        dom, its political subdivisions, or local authori-
                                                                                                               Table 2
governmental body is exempt from U.S. income
tax. However, the exemption does not apply to           ties.                                                  This table lists the different kinds of personal
payments for services performed in the United                                                                  service income that may be fully or partly ex-
States by a resident of the United States who                                                                  empt from U.S. income tax. You must meet all of
either:
                                                        Venezuela                                              the treaty requirements before the item of in-
                                                                                                               come can be exempt from U.S. income tax. The
  • Is a U.S. citizen, or                               Income, other than a pension, paid by Vene-
                                                                                                               income code numbers shown in this table are
                                                        zuela, its political subdivisions, or local authori-
  • Did not become a U.S. resident only to              ties to an individual for services performed for
                                                                                                               the same as the income codes on Form 1042-S,
     perform the services.                                                                                     Foreign Person’s U.S. Source Income Subject
                                                        the paying governmental body is exempt from
                                                                                                               to Withholding.
                                                        U.S. income tax. However, the exemption does
   Pensions paid by Turkey for services per-
formed for Turkey are exempt from U.S. income           not apply to payments for services performed in
                                                                                                               Independent personal services. The term
tax unless the recipient is both a resident and         the United States by a resident of the United          “independent personal services” generally
citizen of the United States.                           States who either:                                     means services you perform for your own ac-
     These exemptions do not apply to income or           • Is a U.S. citizen, or                              count if you receive the income and bear the
pensions for services performed in connection                                                                  losses arising from those services. Examples of
with a business carried on by Turkey or its subdi-        • Did not become a U.S. resident only to             these services are those provided by physi-
visions or local authorities.                                perform the services.                             cians, lawyers, engineers, dentists, and ac-
                                                                                                               countants who perform personal services as
                                                          Pensions paid by Venezuela, its political sub-       sole proprietors or partners.
Ukraine                                                 divisions, or local authorities for services per-
                                                        formed for Venezuela are exempt from U.S.              Dependent personal services. Dependent
Income, other than a pension, paid from public          income tax unless the recipient is both a resident     personal services usually are those you perform
funds 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 payments
formed in the discharge of governmental func-
tions is exempt from U.S. income tax. However,          or pensions for services performed in connec-          Table 3
the exemption does not apply if the services are        tion with a business carried on by Venezuela, its
performed in the United States by a resident of         political subdivisions, or local authorities.          This table lists the countries that have tax trea-
the United States who either:                                                                                  ties with the United States. Some treaties are
                                                                                                               published in the Cumulative Bulletins (C.B.),
  • Is a U.S. citizen, or                                                                                      which contain official matters of the Internal
  • Did not become a U.S. resident only to              Explanation                                            Revenue Service. The column headed Citation
     perform the services.                                                                                     shows the number of the C.B. and the page on
                                                        of Tables                                              which a particular treaty may be found.
                                                                                                                   Regulations implementing some treaties
   Pensions paid by, or by funds created by,
Ukraine, its political subdivisions, or local au-       The paragraphs below describe the tables that          were issued as Treasury Decisions (T.D.). Other
thorities for services performed for Ukraine are        follow and provide additional information that         treaties are explained by Treasury explanation.
exempt from U.S. income tax unless the recipi-          may make the tables more useful to you. Be-            The fifth column lists the T.D. numbers and the
ent is both a resident and citizen of the United        cause there is an effective date election avail-       C.B. in which each T.D. or Treasury explanation
States.                                                                                                        is printed.
                                                        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 the
                                                        protocol with Germany, two entries are shown
pensions for services performed in connection                                                                  Government Printing Office or you are welcome
                                                        for those countries. The effective date of these
with a trade or business carried on by Ukraine,                                                                to read them in most Internal Revenue Service
                                                        items 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 service
                                                                                                               that publishes the treaties and regulations or
United Kingdom                                          Table 1                                                explanations.
Income, other than a pension, paid from the             This table lists the income tax rates on such
public funds of the United Kingdom, its political       income as interest, dividends, capital gains,




Publication 901 (April 2008)                                                                                                                            Page 33
Page 34
                               Table 1. Tax Rates on Income Other Than Personal Service Income Under Chapter 3, Internal Revenue Code, and Income Tax Treaties
                                       Income Code Number                       1                    2                    3               6                  7               9              10         11         12          13           14               21
                                    Country of Residence of Payee                                                                             Dividends                                              Copyright Royalties
                                                                                                                                                                                                                              Real
                                                                                                        Interest                                                                                                            Property
                                                                          Interest                      Paid to a   Paid by                                                                                                 Income
                                                                          Paid by             Interest Controlling    U.S.                             Qualifying                                 Motion                      and
                                                                            U.S.              on Real    Foreign   Corpora-                            for Direct                                 Pictures                  Natural    Pensions            Social
                                                                          Obligors            Property  Corpora-    tions—                              Dividend          Capital      Industrial   and                    Resources     and              Security
                                                                                                                                                                                                                                     v
                                              Name              Code      General            Mortgages     tion    Generala                              Ratea,b          Gainsv       Royalties Television      Other     Royalties   Annuities         Payment u
                                                                             g,tt,uu           g,ff,tt,uu             g,tt,uu             g,pp              g,pp,xx                             g          g          g                          d
                                Australia                           AS            10
                                                                                  g,m
                                                                                                        10
                                                                                                     g,m,ff
                                                                                                                           10
                                                                                                                           g,m
                                                                                                                                              15
                                                                                                                                            g,x
                                                                                                                                                                 5
                                                                                                                                                                 g,x
                                                                                                                                                                             30
                                                                                                                                                                             g,l
                                                                                                                                                                                             0  g      g
                                                                                                                                                                                                         5          5 g
                                                                                                                                                                                                                              30                     0      30
                                Austria                             AU             0                     0                  0                 15                 5             0             0          10          0         30                     0      30
                                                                            g,m,yy             g,m,ff,yy             g,m,yy               g,pp              g,pp           g,hh            g           g          g                        d,f,q
                                Bangladesh                          BG            10                    10                 10                 15                10             0            10          10         10         30                     0      30
                                                                                   g                     g                  g               g,x                  g,x         g,l                g          g          g                      d,f
                                Barbados                            BB              5                     5                  5                  15                  5          0             5            5          5        30                0           30
                                                                                    g                    g                 g                  g                      g       g,l                g          h          g                      d,f
                                Belgium (old treaty)                BE            15                     15                15                   15                  5          0             0            0          0        30                0           30
                                                                               g,m                g,m,ff                g,m             g,zz,ab          g,xx,zz,ab         g,l             g            g          g                        d,f
                                Belgium (new treaty)                BE           g
                                                                                   15
                                                                                                    g,ff
                                                                                                         15
                                                                                                                          g
                                                                                                                            15
                                                                                                                                           g, x
                                                                                                                                                15                  5          0             0            0          0        30                0           30
                                                                                                                                                                g,x         r               g          g            g
                                Canada                              CA           g
                                                                                  10
                                                                                                      g
                                                                                                        10
                                                                                                                          g
                                                                                                                            10
                                                                                                                                              g
                                                                                                                                                15                  5        30              0          10           0        30              15             0
                                                                                                                                                                g                       g,w            g          g                       d, mm
                                China, People’s Rep. of             CH            10                    10                 10                   10               10          30             10          10         10         30                0           30
                                Commonwealth of
                                                                                    n                                                                                         o
                                    Independent States                                0                  30                  30                  30              30              0            0            0         0        30             30             30
                                                                                    g                    g                 g                  g                   g          g,l                g          g          g                      d,f
                                Cyprus                              CY              10                   10                  10                  15                 5            0            0            0         0        30                 0          30
                                                                                    g                   g,ff                 g              g,x                 g,x          g,l           g               g          g                      d,f
                                Czech Republic                      EZ                0                     0                  0                 15                 5            0         10              0         0        30                 0          30
                                                                                 g,oo               g,ff,oo               g,oo          g,zz,ab          g,xx,zz,ab           g             g            g          g                 d,mm,ss
                                Denmark                             DA                0                      0                 0                 15                 5            0            0            0         0        30             30             30
                                                                                  h                                        h                   h                  h          h,l            h            h        g                          d,f
                                Egypt                               EG              15                   30                  15                  15                 5            0            0            0       15         30                 0           0
                                                                               g,oo               g,ff,oo               g,oo                 g,x                g,x          g,l         g,bb          g          g                          d,f
                                Estonia                             EN              10                   10                  10                  15                5            0             5         10         10         30             d,f
                                                                                                                                                                                                                                                 0          30
                                                                                 g,oo               g,ff,oo               g,oo          g,zz,ab          g,xx,zz,ab          g,l            g            g          g
                                Finland                             FI                0                      0                 0                 15                 5            0            0            0         0        30                 0          30
                                                                                    g                   g,ff                 g           b,g,pp                 g,x          g,l            g            g          g                       d 30
                                France                              FR                0                     0                  0                 15                 5            0            5            0         0        30                            30
                                                                                        g                    g                  g           g,x                  g,x         g,l                g     g,dd            g                          d
                                Germany                             GM                0                    0                  0                 15                  5            0             0           0          0       30                0             0
                                                                                 g,m                 g,m,ff               g,m           g,zz,ab          g,xx,zz,ab          g,l                g     g,dd            g                      d,f
                                Germany (as modified)               GM                0                    0                   0                15                  5            0             0           0          0       30                 0            0
                                                                                    h                    h                                                                                   h                      h                            d
                                Greece                              GR                0                    0                 30                 30               30          30                0        30            0       30                0           30
                                                                                    g                    g                   g                g                   g          g,l             g           g          g                        d,f
                                Hungary                             HU               0                     0                  0                 15                 5             0            0           0          0        30                 0          30
                                                                                    g                    g                   g                g                   g          g,l             g                      g                        d,f
                                Iceland                             IC                0                    0                  0                 15                  5            0             0        30            0       30                 0           30
                                                                               g,aa                 g,aa                g,aa                g,x               g,x                       g,bb           g          g                          d,f          ee
                                India                               IN              15                   15                  15                 25               15          30              10         15         15         30                 0           30
                                                                                    g                    g                 g                  g                  g         g,l,z        g,bb           g          g                      d,f,q
                                Indonesia                           ID               10                   10                  10          g,pp
                                                                                                                                               15                 10             0          10          10         10         30              15            30
                                                                                      g                  g,ff                 g                               g,pp           g,l             g           g          g                        d,f
                                Ireland                             EI                 0                   0                   0               15                   5           0             0           0          0        30                 0           0
                                                                             g,aa,ii            g,aa,ff,ii            g,aa,ii               g,x              g,x           g,cc            g           g          g                            f
                                Israel                              IS               171⁄2                171⁄2              171⁄2             25                 121⁄2          0          15          10         10         30                 0           0
                                                                                    g                    g                 g                  g                  e,g         g,l         g,s             g          g                        d,f
                                Italy                               IT               15                   15                  15               15                   5            0          10            8          5        30                 0           0
                                                                                    g                    g                 g                  g                  g           g,l           g           g          g                        d,f,p
                                Jamaica                             JM               121⁄2                121⁄2               121⁄2            15                 10             0          10          10         10         30                 0          30
                                                                         g,ww,zz,ac          g,ff,ww,zz,ac        g,ww,zz,ac          g,w,zz,ab        e,g,ww,zz,ab          g,l         g,ww         g,ww       g,ww                            d
                                Japan                               JA              10                    10                 10                 10                   5           0            0           0         0         30                0            0
                                                                                    g                 g,ff                 g              g,gg                g,gg           g,l         g,jj          g          g                          d,f
                                Kazakhstan                          KZ             10                    10                 10                 15                    5          0          10           10         10         30                0           30
                                                                                  g                     g                  g                  g                  g           g,l          g            g          g                          d,f
                                Korea, Rep. of                      KS             12                    12                 12                 15                 10             0         15           10         10         30                0           30
                                                                               g,oo               g,ff,oo               g,oo                g,x                  g,x         g,l         g,bb          g          g                          d,f
                                Latvia                              LG             10                    10                 10                 15                   5           0            5           10        10         30                0           30
                                                                               g,oo               g,ff,oo               g,oo                g,x                  g,x         g,l         g,bb          g          g                          d,f
                                Lithuania                           LH             10
                                                                                    g,h
                                                                                                          10
                                                                                                      g,ff,h
                                                                                                                            10
                                                                                                                           g,h              g,x
                                                                                                                                                15                 5            0             5          10         10        30                  0         30
                                                                                                                                                                 g,x          g                 g        g          g                            d
                                Luxembourg                          LU               0                     0                  0                 15                 5             0            0           0          0        30                  0         30
                                                                               g,qq               g,ff,qq                  g            g,pp,vv          g,pp,vv,xx          g,l           g           g          g                              d
                                Mexico                              MX              15                    15                15                  10                 5             0           10         10         10         30                  0         30
                                                                                  g                     g                  g                  g                 g            g,l           h           g          g                          d,f
                                Morocco                             MO              15                    15                15                  15               10              0           10         10         10         30                  0         30
                                                                                    g                     g                  g                g                   g        g,hh              g        g,dd          g                       d,f,t
                                Netherlands                         NL               0                     0                  0                 15                 5             0            0            0         0        30                  0         30
                                                                                    g                    g                 g                  g                  g           g,l           g           g          g                              d
                                New Zealand                         NZ               10                      10                 10                15               15              0            10      10         10         30                     0      30
                                                                                     g                       g                  g             g                  g           g,l                g       h          g                         d,f
                                Norway                              NO                0                       0                  0                15               15              0             0        0         0         30                     0      30




Publication 901 (April 2008)
Publication 901 (April 2008)
                               Table 1. Tax Rates on Income Other Than Personal Service Income Under Chapter 3, Internal Revenue Code, and Income Tax Treaties
                                       Income Code Number                           1            2               3              6               7          9            10        11         12           13              14      21
                                    Country of Residence of Payee                                                                   Dividends                                   Copyright Royalties
                                                                                                                                                                                                          Real
                                                                                                   Interest                                                                                             Property
                                                                          Interest                 Paid to a   Paid by                                                                                  Income
                                                                          Paid by        Interest Controlling    U.S.                    Qualifying                            Motion                     and
                                                                            U.S.         on Real    Foreign   Corpora-                   for Direct                            Pictures                 Natural    Pensions      Social
                                                                          Obligors       Property  Corpora-    tions—                     Dividend      Capital     Industrial   and                   Resources     and        Security
                                                                                                                                                                                                                 v
                                             Name               Code      General       Mortgages     tion    Generala                     Ratea,b      Gainsv      Royalties Television    Other      Royalties   Annuities   Payment u
                                                                                                                                              h                            h                     h                     d,j
                                Pakistan                            PK           30                30              30              30            15         30             0       30              0      30               0      30
                                                                               g                g                g               g             g           g,l          g         g          g                        q
                                Philippines                         RP           15                15              15              25            20            0         15        15           15        30           30         30
                                                                                 g                 g               g             g               g         g,l          g         g          g
                                Poland                              PL             0                 0               0             15              5           0         10        10           10        30           30         30
                                                                               g              g,ff               g            g,x              g,x         g,l          g         g          g                         d,f
                                Portugal                            PO           10                10              10              15              5           0         10        10           10        30               0      30
                                                                               g                g                g               g             g           g,l          g         g          g                         d,f
                                Romania                             RO           10                10              10              10            10             0         15        10           10       30               0       0
                                                                                 g              g,ff               g         g,gg             g,gg         g,l            g         g            g                      d
                                Russia                              RS           g
                                                                                   0
                                                                                                g,ff
                                                                                                     0
                                                                                                                   g
                                                                                                                     0
                                                                                                                              g,x
                                                                                                                                   10              5            0           0         0            0      30               0      30
                                                                                                                                               g,x         g,l          g           g            g                     d,f
                                Slovak Republic                     LO             0                 0               0             15              5            0         10          0            0      30               0      30
                                                                                 g              g,ff               g         g,pp            g,pp            g            g         g            g                     d,f
                                Slovenia                            SI             5                 5               5             15              5            0           5         5            5      30               0      30
                                                                               g,m            g,m,ff             g,m          g,x              g,x            l           g         g            g                 d,kk
                                South Africa                        SF         g
                                                                                  0
                                                                                                g
                                                                                                     0
                                                                                                                 g
                                                                                                                    0
                                                                                                                              g,x
                                                                                                                                   15              5           0            0        0             0      30            15        30
                                                                                                                                             g,x           g,l          g,y       g,y         g,y                      d,f
                                Spain                               SP           10                10              10              15            10             0           8        8             5      30               0      30
                                                                             g,m10          g,m,ff10           g,m10           g,rr15        g,rr15       g,hh0           g       g
                                Sri Lanka                           CE                                                                                                      0       10      g,s10         30        d,mm0         30
                                                                                 g              g,ff               g      g,zz,ab                          g,l            g         g            g                      d
                                Sweden                              SW            0                  0               0             15     g,xx,zz,ab5           0           0        0             0      30               0      30
                                                                               g,m            g,m,ff             g,m          g,x              g,x            l           g         g            g                      d
                                Switzerland                         SZ            0                  0               0             15              5            0           0        0             0      30               0      15
                                                                            g,aa           g,aa,ff            g,aa            g,x            g,x                         bb                   ll                       d,f
                                Thailand                            TH           15                15              15              15            10         30              8        5           15       30               0      30
                                                                                                                                                                        g                        g                     d,f
                                Trinidad & Tobago                   TD           30               30               30              30            30         30            15       30              0      30               0      30
                                                                               g                g                g            g,x            g,x           g,l       g,bb         g          g                           f
                                Tunisia                             TS           15               15               15              20            14            0          10       15           15        30               0      30
                                                                           g,i,aa         g,i,aa,ff          g,i,aa           g,x            g,x           g,l          bb                                                d
                                Turkey                              TU          15                15               15             20             15            0           5        10         10         30           0          30
                                                                                 g               g,ff               g       g,gg             g,gg           g          g          g          g                            d
                                Ukraine                             UP            0                 0                0            15               5           0         10         10         10         30           0          30
                                                                          g,oo,ww        g,ff,oo,ww         g,oo,ww       g,pp,ww        g,pp,ww,xx         g         g,ww       g,ww       g,ww                      d,f
                                United Kingdom                      UK             0                0                 0           15               5          0            0         0          0         30           0           0
                                                                         g,nn,oo        g,ff,nn,oo       g,ff,nn,oo          g,pp                          g,l         g,bb        g          g                    d,mm
                                Venezuela                           VE          10                10               10            15           g,pp5           0            5        10         10         30           0          30
                                Other Countries                                  30                30              30             30             30        30            30         30         30         30          30          30




Page 35
                               a                                                                           l                                                                          bb




Page 36
                                   No U.S. tax is imposed on a dividend paid by a U.S. corporation that        Exemption does not apply to gains from the sale of real property.            This is the rate for royalties for the use of, or the right to use,
                                   received at least 80% of its gross income from an active foreign            However, for U.S. real property that was owned continuously                  industrial, commercial, and scientific equipment. The rate for
                                   business for the 3-year period before the dividend is declared.             since June 18, 1980, by a Netherlands resident, the taxable gain             royalties for information concerning industrial, commercial and
                               b                                                                               may be limited to the appreciation after 1984. For details, see
                                   The reduced rate applies to dividends paid by a subsidiary to                                                                                            scientific know-how is subject to the rate in column 12.
                                                                                                               Article 14(2) of the treaty.                                           cc
                                   a foreign parent corporation that has the required percentage                                                                                            The exemption does not apply to gain from the sale or other
                                                                                                           m
                                   of stock ownership. In some cases, the income of the subsidiary             The rate is 15% (30% for Germany and Switzerland) for                        disposition of property described in Article 14(2)(c) (copyrights
                                   must meet certain requirements (e.g., a certain percentage of               contingent interest that does not qualify as portfolio interest.             of literary, artistic, or scientific works).
                                   its total income must consist of income other than dividends            n                                                                          dd
                                                                                                               The exemption applies only to interest on credits, loans, and                The exemption does not apply to cinematographic items, or
                                   and interest).                                                                                                                                           works on film, tape, or other means of reproduction for use in
                               c                                                                               other indebtedness connected with the financing of trade
                                   The exemption or reduction in rate applies only if the recipient            between the United States and the C.I.S. member. It does not                 radio or television broadcasting.
                                   is subject to tax on this income in the country of residence.                                                                                      ee
                                                                                                               include interest from the conduct of a general banking business.             U.S. social security benefits paid to individuals who are both
                                   Otherwise, a 30% rate applies.                                          o
                               d                                                                               The exemption applies only to gains from the sale or other                   residents and nationals of India are exempt from tax if they are
                                   Exemption does not apply to U.S. Government (federal, state,                disposition of property acquired by gift or inheritance.                     for services performed for the United States, its subdivisions,
                                   or local) pensions and annuities; a 30% rate applies to these           p                                                                                or local authorities.
                                                                                                               The exemption does not apply if the recipient was a resident of         ff
                                   pensions and annuities. For this purpose, railroad retirement tier                                                                                       Exemption or reduced rate does not apply to an excess inclusion
                                                                                                               the United States when the pension was earned or when the
                                   2, dual, and supplemental benefits are not considered U.S.                                                                                               for a residual interest in a real estate mortgage investment
                                                                                                               annuity was purchased.
                                   Government pensions or annuities. U.S. Government pensions              q                                                                                conduit (REMIC).
                                   paid to an individual who is both a resident and national of                Annuities paid in return for other than the recipient’s services       gg
                                                                                                               are exempt. For Bangladesh, exemption does not apply to                      The rate in column 6 applies to dividends paid by a regulated
                                   Bangladesh, Belgium, China, Denmark, Estonia, Finland,                                                                                                   investment company (RIC). Dividends paid by a real estate
                                   Germany, Hungary, India, Ireland, Italy, Latvia, Lithuania,                 annuity received for services rendered.
                                                                                                           r                                                                                investment trust (REIT) are subject to a 30% rate.
                                   Luxembourg, Mexico, the Netherlands, Portugal, Russia,                      Generally, if the property was owned by the Canadian resident          hh
                                   Slovenia, South Africa, Spain, Switzerland, Thailand, Turkey, the           on September 26, 1980, not as part of the business property                  The exemption does not apply to a sale of a U.S. company’s
                                   United Kingdom, or Venezuela are exempt from U.S. tax. U.S.                 of a permanent establishment or fixed base in the U.S., the                  stock representing ownership of 50% or more.
                                   Government pensions paid to an individual who is both a                     taxable gain is limited to the appreciation after 1984. Capital         ii
                                                                                                                                                                                            An election can be made to treat this interest income as if it
                                   resident and citizen of Kazakstan, New Zealand, or Sweden are               gains on personal property not belonging to a permanent                      were industrial and commercial profits taxable under article 8
                                   exempt from U.S. tax.                                                       establishment or fixed base of the taxpayer in the U.S. are                  of the treaty.
                               e                                                                               exempt.                                                                 jj
                                   For Italy, the reduced rate is 10% if the foreign corporation owns      s                                                                                If the payments were for the use of, or the right to use, industrial,
                                   10% to 50% of the voting stock (for a 12-month period) of the               The rate for royalties with respect to tangible personal property            commercial, or scientific equipment, an election may be made
                                   company paying the dividends. For Japan, dividends received                 is 7% (5% in the case of Sri Lanka).                                         to compute the tax on a net basis as if such income were
                                                                                                           t
                                   from a more than 50% owned corporate subsidiary are exempt                  The exemption does not apply if (1) the recipient was a U.S.                 attributable to a permanent establishment or fixed base in the
                                   if certain conditions are met.                                              resident during the 5-year period before the date of payment,                U.S.
                               f
                                   Includes alimony.                                                           (2) the amount was paid for employment performed in the United         kk
                               g
                                                                                                                                                                                            The reduced rate does not apply if the distribution is subject to
                                   The exemption or reduction in rate does not apply if the recipient          States, and (3) the amount is not a periodic payment, or is a                a penalty for early withdrawal. Annuities that were purchased
                                   has a permanent establishment in the United States and the                  lump-sum payment in lieu of a right to receive an annuity.                   while the annuitant was not a resident of the United States are
                                                                                                           u
                                   property giving rise to the income is effectively connected with            Applies to 85% of the social security payments received from                 not taxable in the United States.
                                                                                                                                                                                       ll
                                   this permanent establishment. Under certain treaties, exemption             the U.S. Government. The effective rate on the total social                  The rate is 5% for royalties on the use of any copyright of literary,
                                   or reduction in rate also does not apply if the property producing          security payments received is 85% of the rate shown in the                   artistic, or scientific work, including software.
                                   the income is effectively connected with a fixed base in the                table. These rates also apply to the social security equivalent        mm
                                                                                                                                                                                            Does not apply to annuities. For Denmark, annuities are exempt.
                                   United States from which the recipient performs independent                 portion of tier 1 railroad retirement benefits (income code 22)        nn
                                   personal services. Even with the treaty, if the income is not               received from the U.S. The remainder of tier 1, all of tier 2, dual,         The rate is 4.95% if the interest is beneficially owned by a
                                   effectively connected with a trade or business in the United                and supplemental railroad retirement benefits (income code 23)               financial institution (including an insurance company).
                                                                                                                                                                                      oo
                                   States by the recipient, the recipient will be considered as not            are taxed as shown in column 14, “Pensions and Annuities.”                   The rate is 15% for interest determined with reference to (a) receipts,
                                   having a permanent establishment in the United States under             v                                                                                sales, income, profits or other cash flow of the debtor or a related
                                                                                                               Gains on the disposition of U.S. real property interests are
                                   Internal Revenue Code section 894(b).                                       considered effectively connected with a U.S. trade or business               person, (b) any change in the value of any property of the debtor
                               h                                                                                                                                                            or a related person, or (c) any dividend, partnership distribution, or
                                   The exemption or reduction in rate does not apply if the recipient          and thus are subject to graduated rates of tax rather than the
                                   is engaged in a trade or business in the United States through              flat percentage shown in this column.                                        similar payment made by the debtor or related person.
                                                                                                                                                                                      pp
                                                                                                          w                                                                                 The rate in column 6 applies to dividends paid by a regulated
                                   a permanent establishment that is in the United States.                     Tax imposed on 70% of gross royalties for rentals of industrial,
                                   However, if the income is not effectively connected with a trade            commercial, or scientific equipment.                                         investment company (RIC) or real estate investment trust (REIT).
                                   or business in the United States by the recipient, the recipient        x                                                                                However, that rate applies to dividends paid by a REIT only if
                                                                                                               The rate in column 6 applies to dividends paid by a regulated                the beneficial owner of the dividends is (a) an individual holding
                                   will be considered as not having a permanent establishment in
                                                                                                               investment company (RIC) or a real estate investment trust                   not more than a 10% interest in the REIT, (b) a person holding
                                   the United States to apply the reduced treaty rate to that item
                                                                                                               (REIT). However, that rate applies to dividends paid by a REIT               not more than 5% of any class of the REIT’s stock and the
                                   of income.
                               i
                                                                                                               only if the beneficial owner of the dividends is an individual               dividends are paid on stock that is publicly traded, or (c) a
                                   Contingent interest that does not qualify as portfolio interest is          holding less than a 10% interest (25% in the case of Portugal,
                                   treated as a dividend and is subject to the rate under column                                                                                            person holding not more than a 10% interest in the REIT and
                                                                                                               Spain, and Tunisia) in the REIT.                                             the REIT is diversified.
                                   6 or 7.                                                                 y
                                                                                                               Royalties not taxed at the 5% or 8% rate are taxed at a 10%            qq
                               j                                                                                                                                                            The rate is 4.9% for interest derived from (1) loans granted by
                                   Exemption is not available when paid from a fund under an                   rate, unless footnote (g) applies.
                                   employees’ pension or annuity plan, if contributions to it are          z
                                                                                                                                                                                            banks and insurance companies and (2) bonds or securities that
                                                                                                               The exemption does not apply if the recipient of the gain is an              are regularly and substantially traded on a recognized securities
                                   deductible under U.S. tax laws in determining taxable income
                                                                                                               individual who is present in the United States for more than 119             market. The rate is 10% for interest not described in the
                                   of the employer.
                               k                                                                               days during the year.                                                        preceding sentence and paid (i) by banks or (ii) by the buyer of
                                   Applies to 100% of the social security and other public pensions       aa
                                                                                                               The rate is 10% if the interest is paid on a loan granted by a               machinery and equipment to the seller due to a sale on credit.
                                   received from the U.S. government.
                                                                                                               bank or similar financial institution. For Thailand, the 10% rate
                                                                                                               also applies to interest from an arm’s length sale on credit of
                                                                                                               equipment, merchandise, or services.




Publication 901 (April 2008)
Publication 901 (April 2008)
                               rr                                                                          xx                                                                        ab
                                    The rate applies to dividends paid by a real estate investment              Dividends received from an 80%-owned corporate subsidiary                 The rate in column 6 applies to dividends paid by a regulated
                                    trust (REIT) only if the beneficial owner of the dividends is (a) an        are exempt if certain conditions are met.                                 investment company (RIC) or real estate investment trust (REIT).
                                    individual holding less than a 10% interest in the REIT, (b) a                                                                                        However, that rate applies to dividends paid by a REIT only if
                                                                                                           yy
                                    person holding not more than 5% of any class of the REIT’s                  The rate is 5% for interest (a) beneficially owned by a bank or           the beneficial owner of the dividends is (a) an individual or
                                    stock and the dividends are paid on stock that is publicly traded,          other financial institution (including an insurance company) or           pension fund holding not more than a 10% interest in the
                                    or (c) a person holding not more than a 10% interest in the REIT            (b) paid due to a sale on credit of any industrial, commercial,           REIT,(b) a person holding not more than 5% of any class of the
                                    and the REIT is diversified.                                                or scientific equipment, or of any merchandise to an enterprise.          REIT’s stock and the dividends are paid on stock that is publicly
                               ss                                                                          zz
                                                                                                                                                                                          traded, or (c) a person holding not more than a 10% interest in
                                    Generally, if the person was receiving pension distributions                Amounts paid to a pension fund that are not derived from the              the REIT and the REIT is diversified. Dividends paid to a pension
                                    before March 31, 2000, the distributions continue to be exempt              carrying on of a business, directly or indirectly, by the fund are        fund from a RIC, or a REIT that meets the above conditions, are
                                    from U.S. tax.                                                              exempt. This includes amounts paid by a REIT only if the                  exempt. For Sweden, the pension fund must also satisfy the
                                                                                                                conditions in footnote ab are met. For Sweden, to be entitled             requirements in footnote (zz).
                               tt
                                    Interest determined with reference to the profits of the issuer or          to the exemption, the pension fund must not sell or make a
                                    one of its associated enterprises is taxed at 15%.                                                                                               ac
                                                                                                                contract to sell the holding from which the dividend is derived           Interest is exempt if (a) paid to certain financial institutions, or
                               uu
                                                                                                                within 2 months of the date the pension fund acquired the                 (b) paid on indebtedness from the sale on credit of equipment
                                    Interest received by a financial institution is exempt.                     holding.                                                                  or merchandise.
                               vv
                                    Dividends received by a trust, company, or other organization
                                    operated exclusively to administer or provide pension,
                                    retirement, or other employee benefits generally are exempt if
                                    certain conditions are met.
                               ww
                                    Exemption does not apply to amount paid under, or as part of,
                                    a conduit arrangement.




Page 37
                               Table 2. Compensation for Personal Services Performed in United States Exempt from U.S. Income Tax Under Income Tax Treaties




Page 38
                                                                   Category of Personal Services              Maximum                                             Maximum
                                                                                                              Presence                                           Amount of         Treaty Article
                                            Country    Code1               Purpose                             in U.S.             Required Employer or Payer   Compensation          Citation
                                              (1)       (2)                  (3)                                 (4)                          (5)                    (6)                 (7)
                                Australia               16     Independent personal services22             183   days       Any   contractor                    No limit          14
                                                        20        Public entertainment                     183   days       Any   contractor                    $10,00025         17
                                                        17     Dependent personal services15               183   days       Any   foreign resident              No limit          15
                                                        20        Public entertainment15                   183   days       Any   foreign resident              $10,00025         17
                                                        19     Studying and training:
                                                                  Remittances or allowances10              No limit         Any   foreign resident              No limit          20
                                Austria                 16     Independent personal services22             No limit         Any   contractor                    No limit          14
                                                        20        Public entertainment                     No limit         Any   contractor                    $20,000 p.a.25    17
                                                        17     Dependent personal services15               183 days         Any   foreign resident              No limit          15
                                                        20        Public entertainment                     No limit         Any   U.S. or foreign resident      $20,000 p.a.25    17
                                                        19     Studying and training:
                                                                  Remittances or allowances10              3 years11        Any   foreign resident              No limit          20
                                Bangladesh              15     Scholarship or fellowship grant4            2 years11        Any   U.S. or foreign resident5     No limit          21(2)
                                                        16     Independent personal services22             183 days         Any   contractor                    No limit          15
                                                        20        Public entertainment                     No limit         Any   contractor                    $10,00030         18
                                                        17     Dependent personal services15               183 days         Any   foreign resident              No limit          16
                                                        20        Public entertainment                     No limit         Any   contractor                    $10,00030         18
                                                        18     Teaching or research4                       2 years          Any   U.S. or foreign resident      No limit          21(1)
                                                        19     Studying and training:4
                                                                  Remittances or allowances                2 years11        Any   foreign resident              No limit          21(2)
                                                                  Compensation during study or training    2 years11        Any   U.S. or foreign resident      $8,000 p.a.       21(2)
                                Barbados                16     Independent personal services7,22           89 days          Any   foreign contractor            No limit          14
                                                                                                           89 days          Any   U.S. contractor               $5,000            14
                                                        20        Public entertainment                     No limit         Any   contractor                    $250 per day
                                                                                                                                                                or $4,000 p.a.6   17
                                                        17     Dependent personal services7,15             183 days         Any foreign resident                $5,000            15
                                                        20        Public entertainment                     No limit         Any U.S. or foreign resident        $250 per day 6
                                                        19     Studying and training:20                                                                         or $4,000 p.a.    17
                                                                  Remittances or allowances10              No limit         Any foreign resident                No limit          20
                                Belgium (old treaty)    15     Scholarship or fellowship grant             5 years          Any U.S. or foreign resident5       No limit          21(1)
                                                        16     Independent personal services22             182 days         Any contractor                      No limit          14(2)(a)(b)
                                                        20        Public entertainment                     90 days          Any contractor                      $3,000            14(2)(c)
                                                        17     Dependent personal services15               182 days         Belgian resident                    No limit          15
                                                        18     Teaching4                                   2 years          U.S. educational institution        No limit          20
                                                        19     Studying and training:
                                                                  Remittances or allowances                5 years          Any foreign resident                No limit          21(1)
                                                                  Compensation during training             12 consec. mo.   Belgian resident                    $5,000            21(2)(b)
                                                                                                           5 years          Other foreign or U.S. resident      $2,000 p.a.       21(1)
                                                                  Compensation while gaining experience2   12 consec. mo.   Belgian resident                    $5,000            21(2)(a)
                                                                  Compensation under U.S.
                                                                     Government program                    1 year           U.S. Government or its contractor   $10,000           21(3)
                                Belgium (new treaty)    16     Independent personal services54
                                                        17     Dependent personal services15,24            183 days         Any foreign resident                No limit          14
                                                        20        Public entertainment                     No limit         Any U.S. or foreign resident        $20,000 p.a.25    16
                                                        18     Teaching4                                   2 years          Any U.S. educational or research
                                                        19     Studying and training:10                                     institution                         No limit          19(2)
                                                                  Remittances or allowances                No limit57       Any foreign resident                No limit          19(1)(a)
                                                                  Compensation during study or training    No limit57       Any U.S. or foreign resident        $9,000 p.a.       19(1)(b)
                                Canada                  16     Independent personal services22             No limit         Any contractor                      No limit12        XIV
                                                        20        Public entertainment                     No limit         Any contractor                      $15,000 p.a.25    XVI
                                                        17     Dependent personal services                 No limit         Any U.S. or foreign resident        $10,000           XV
                                                                                                           183 days         Any foreign resident15              No limit12        XV
                                                        20        Public entertainment3                    No limit         Any U.S. or foreign resident        $15,000 p.a.25    XVI
                                                        19     Studying and training:
                                                                  Remittances or allowances10              No limit         Any foreign resident                No limit          XX




Publication 901 (April 2008)
                               Table 2. ( Continued)
                                                                      Category of Personal Services              Maximum                                                             Maximum
                                                                                                                 Presence                                                            Amount of        Treaty Article
                                         Country          Code1                Purpose                             in U.S.              Required Employer or Payer                 Compensation          Citation
                                           (1)             (2)                   (3)                                 (4)                              (5)                                 (6)               (7)
                                China, People’s Rep. of    15     Scholarship or fellowship grant             No specific limit   Any U.S. or foreign resident5                    No limit          20(b)
                                                           16     Independent personal services22             183 days            Any contractor                                   No limit          13
                                                           20        Public entertainment29                   No limit            Any contractor                                   No limit          16
                                                           17     Dependent personal services7,15             183 days            Any foreign resident                             No limit          14
                                                           20        Public entertainment29                   No limit            Any U.S. or foreign resident                     No limit          16




Publication 901 (April 2008)
                                                           18     Teaching4                                   3 years             U.S. educational or research institute           No limit          19
                                                           19     Studying and training:
                                                                     Remittances or allowances                No specific limit   Any foreign resident                             No limit          20(a)
                                                                     Compensation during training or while
                                                                        gaining experience                    No specific limit   Any U.S. or foreign resident                     $5,000 p.a.       20(c)
                                Commonwealth of            15     Scholarship or fellowship grant             5 years             Any U.S. or foreign resident                     Limited19         VI(1)
                                  Independent States       16     Independent personal services               183 days            Any U.S. or foreign contractor                   No limit          VI(2)
                                                           17     Dependent personal services                 183 days            Any U.S. or foreign resident                     No limit          VI(2)
                                                           18     Teaching4,18                                2 years             Any U.S. educational or scientific institution   No limit          VI(1)
                                                           19     Studying and training:
                                                                     Remittances or allowances                5 years             Any U.S. or foreign resident                     Limited19         VI(1)
                                                                     Compensation while gaining experience    1 year              C.I.S. resident                                  No limit19        VI(1)
                                                                     Compensation under U.S.
                                                                        Government program                    1 year              Any U.S. or foreign resident                     No limit          VI(1)
                                Cyprus                     15     Scholarship or fellowship grant             Generally, 5
                                                                                                              years               Any U.S. or foreign resident5                    No limit          21(1)
                                                           16     Independent personal services22             182 days            Any contractor                                   No limit          17
                                                           20        Public entertainment                     No limit            Any contractor                                   $500 per day or
                                                                                                                                                                                   $5,000 p.a.6      19(1)
                                                           17     Dependent personal services15               182 days            Any foreign resident                             No limit          18
                                                                    Directors’ fees                           No limit            U.S. corporation                                 No limit21        20
                                                           20       Public entertainment                      No limit            Any U.S. or foreign resident                     $500 per day or
                                                                                                                                                                                   $5,000 p.a.6      19(1)
                                                           19     Studying and training:
                                                                     Remittances or allowances                Generally, 5
                                                                                                              years               Any foreign resident                             No limit          21(1)
                                                                     Compensation during training             Generally, 5
                                                                                                              years               Any U.S. or foreign resident                     $2,000 p.a.       21(1)
                                                                     Compensation while gaining experience2   1 year              Cyprus resident                                  $7,500            21(2)
                                                                     Compensation under U.S.
                                                                        Government program                    1 year              U.S. Government or its contractor                $10,000           21(3)
                                Czech Republic             15     Scholarship or fellowship grant             5 years             Any U.S. or foreign resident5                    No limit          21(1)
                                                           16     Independent personal services22             183 days            Any contractor                                   No limit          14
                                                           20        Public entertainment                     183 days            Any contractor                                   $20,000 p.a.30    18
                                                           17     Dependent personal services7,15             183 days            Any foreign resident                             No limit          15
                                                           20        Public entertainment                     183 days            Any foreign resident                             $20,000 p.a.30    18
                                                           18     Teaching4,35                                2 years             Any U.S. educational or research
                                                                                                                                     institution                                   No limit          21(5)
                                                           19     Studying and training:4
                                                                     Remittances and allowances               5 years             Any foreign resident                             No limit          21(1)
                                                                     Compensation during training             5 years             Any U.S. or foreign resident                     $5,000 p.a.       21(1)
                                                                     Compensation while gaining experience2   12 consec. mos.     Czech resident                                   $8,000            21(2)
                                                                     Compensation under U.S.
                                                                        Government program                    1 year              U.S. Government                                  $10,000           21(3)
                                Denmark                    16     Independent personal services22             No limit            Any contractor                                   No limit          14
                                                           20        Public entertainment                     No limit            Any contractor                                   $20,000 p.a.25    17
                                                           17     Dependent personal services15               183 days            Any foreign resident                             No limit          15
                                                           20        Public entertainment                     183 days            Any foreign resident                             $20,000 p.a.25    17
                                                           19     Studying and training:4
                                                                     Remittances or allowances10              3 years11           Any foreign resident                             No limit          20




Page 39
                               Table 2. ( Continued)




Page 40
                                                                     Category of Personal Services              Maximum                                                         Maximum
                                                                                                                Presence                                                       Amount of       Treaty Article
                                                             1
                                          Country      Code                  Purpose                              in U.S.               Required Employer or Payer            Compensation        Citation
                                            (1)         (2)                     (3)                                  (4)                              (5)                           (6)              (7)
                                Egypt                   15       Scholarship or fellowship grant             Generally, 5 years   Any U.S. or foreign resident5              No limit         23(1)
                                                        16       Independent personal services               89 days              Any contractor                             No limit         15
                                                        20          Public entertainment                     No limit             Any contractor                             $400 per day     17
                                                        17       Dependent personal services14,15            89 days              Egyptian resident                          No limit         16
                                                        20          Public entertainment                     No limit             Any U.S. or foreign resident               $400 per day     17
                                                        18       Teaching4                                   2 years              U.S. educational institution               No limit         22
                                                        19       Studying and training:
                                                                    Remittances or allowances                Generally, 5 years   Any foreign resident                       No limit         23(1)
                                                                    Compensation during training             Generally, 5 years   U.S. or any foreign resident               $3,000 p.a.      23(1)
                                                                    Compensation while gaining experience2   12 consec. mos.      Egyptian resident                          $7,500           23(2)
                                                                    Compensation under U.S.
                                                                       Government program                    1 year               U.S. Government or its contractor          $10,000          23(3)
                                Estonia                 15       Scholarship or fellowship grants4           5 years              Any U.S. or foreign resident5              No limit         20(1)
                                                        16       Independent personal services22             183 days             Any contractor                             No limit         14
                                                        20          Public entertainment                     No limit             Any contractor                             $20,00030        17
                                                        17       Dependent personal services7,15             183 days             Any foreign resident                       No limit         15
                                                        20          Public entertainment                     No limit             Any U.S. or foreign resident               $20,00030        17
                                                        19       Studying and training:4
                                                                    Remittances or allowances                5 years              Any foreign resident                       No limit         20(1)
                                                                    Compensation during training             12 consec. mos.      Estonian resident                          $8,000           20(2)
                                                                                                             5 years              Other foreign or U.S. resident             $5,000 p.a.      20(1)
                                                                     Compensation2 while gaining
                                                                        experience                           12 consec. mos.      Estonian resident                          $8,000           20(2)
                                                                     Compensation under U.S.
                                                                        Government program                   1 year               U.S. Government or its contractor          $10,000          20(3)
                                Finland                 16       Independent personal services22             No limit             Any contractor                             No limit         14
                                                        20           Public entertainment                    No limit             Any contractor                             $20,000 p.a.25   17
                                                        17       Dependent personal services15               183 days             Any foreign resident                       No limit         15
                                                        20           Public entertainment                    No limit             Any U.S. or foreign resident               $20,000 p.a.25   17
                                                        19       Studying and training:
                                                                     Remittances or allowances10             No limit             Any foreign resident                       No limit         20
                                France                  15        Scholarship or fellowship grant            5 years40            Any U.S. or foreign resident5              No limit         21(1)
                                                        16        Independent personal services22            No limit             Any contractor                             No limit         14
                                                        20           Public entertainment                    No limit             Any contractor                             $10,00030        17
                                                        17        Dependent personal services7,15            183 days             Any foreign resident                       No limit         15
                                                        20           Public entertainment                    No limit             Any U.S. or foreign resident               $10,00030        17
                                                        18        Teaching4,39                               2 years40            U.S. educational or research institution   No limit         20
                                                        19        Studying and training:4
                                                                     Remittances or allowances               5 years40            Any foreign resident                       No limit         21(1)
                                                                     Compensation during study or
                                                                        training                             12 consec. mos.      French resident                            $8,000           21(2)
                                                                                                             5 years              Other foreign or U.S. resident             $5,000 p.a.      21(1)
                                                                                                         2
                                                                    Compensation while gaining experience    12 consec. mos.      French resident                            $8,000           21(2)
                                Germany                 15       Scholarship or fellowship grant             No limit             Any U.S. or foreign resident5              No limit         20(3)
                                                        16       Independent personal services22             No limit             Any contractor                             No limit         14
                                                        20          Public entertainment22                   No limit             Any contractor                             $20,000 p.a.30   17
                                                        17       Dependent personal services15,24            183 days             Any foreign resident                       No limit         15
                                                        20          Public entertainment15                   183 days             Any foreign resident                       $20,000 p.a.30   17
                                                        18       Teaching4                                   2 years              U.S. educational or research institution   No limit         20(1)
                                                        19       Studying and training:
                                                                    Remittances or allowances10              No limit             Any foreign resident                       No limit         20(2)
                                                                    Compensation during study or training    4 years              Any U.S. or foreign resident               $5,000 p.a.      20(4)
                                                                    Compensation while gaining experience2   1 year               Any German enterprise or foreign
                                                                                                                                     organization or institution             $10,00028        20(5)




Publication 901 (April 2008)
                               Table 2. ( Continued)
                                                                      Category of Personal Services             Maximum                                                      Maximum
                                                                                                                 Presence                                                    Amount of       Treaty Article
                                                              1
                                        Country         Code                  Purpose                              in U.S.          Required Employer or Payer             Compensation         Citation
                                           (1)           (2)                    (3)                                  (4)                           (5)                            (6)              (7)
                                Germany (as modified)    15       Scholarship or fellowship grant             No limit         Any U.S. or foreign resident5               No limit         20(3)
                                                         16       Independent personal services54
                                                         17       Dependent personal services15,24            183 days         Any foreign resident                        No limit         15
                                                         20          Public entertainment                     No limit         Any U.S. or foreign resident                $20,000 p.a.30   17
                                                         18       Teaching4,56                                2 years          U.S. educational or research institution    No limit         20(1)
                                                         19       Studying and training:10




Publication 901 (April 2008)
                                                                     Remittances or allowances                No limit         Any foreign resident                        No limit         20(2)
                                                                     Compensation during study or training    4 years          Any U.S. or foreign resident                $9,000 p.a.      20(4)
                                                                     Compensation while gaining experience2   1 year           Any foreign resident                        $10,00028        20(5)
                                Greece                   16       Independent personal services               183 days         Greek resident contractor                   No limit         X
                                                                                                              183 days         Other foreign or U.S. resident contractor   $10,000          X
                                                         17       Dependent personal services                 183 days         Greek resident                              No limit         X
                                                                                                              183 days         Other foreign or U.S. resident              $10,000          X
                                                         18       Teaching                                    3 years          U.S. educational institution                No limit         XII
                                                         19       Studying and training:
                                                                     Remittances or allowances                No limit         Any foreign resident                        No   limit       XIII
                                Hungary                  16       Independent personal services22             183 days         Any contractor                              No   limit       13
                                                         17       Dependent personal services15               183 days         Any foreign resident                        No   limit       14
                                                         18       Teaching4                                   2 years          U.S. educational institution                No   limit       17
                                                         19       Studying and training:20
                                                                     Remittances or allowances10              No limit         Any foreign resident                        No limit         18(1)
                                Iceland                  15       Scholarship and fellowship grant            5 years          Any U.S. or foreign resident5               No limit         22(1)
                                                         16       Independent personal services22             182 days         Any contractor                              No limit         18
                                                         20          Public entertainment                     90 days          Any contractor                              $100 per day     18
                                                         17       Dependent personal services15               182 days         Iceland resident16                          No limit         19
                                                         18       Teaching4                                   2 years          U.S. educational institution                No limit         21
                                                         19       Studying and training:
                                                                     Remittances or allowances                5 years          Any foreign resident                        No limit         22(1)
                                                                     Compensation during training             5 years          U.S. or any foreign resident                $2,000 p.a.      22(1)
                                                                     Compensation while gaining experience2   12 consec. mo.   Iceland resident                            $5,000           22(2)
                                                                     Compensation under U.S.
                                                                        Government program                    1 year           U.S. Government or its contractor           $10,000          22(3)
                                India                    16       Independent personal services7,22           89 days          Any contractor                              No limit         15
                                                         20          Public entertainment22                   89 days          Any contractor                              $1,500 p.a.26    18
                                                         17       Dependent personal services7,15             183 days         Any foreign resident                        No limit         16
                                                         20          Public entertainment15                   183 days         Any foreign resident                        $1,500 p.a.26    18
                                                         18       Teaching4                                   2 years          U.S. educational institution                No limit         22
                                                         19       Studying and training:
                                                                     Remittances or allowances                No limit         Any foreign resident27                      No limit         21(1)
                                Indonesia                15       Scholarship and fellowship grant            5 years          Any U.S. or foreign resident5               No limit         19(1)
                                                         16       Independent personal services22             119 days         Any contractor                              No limit         15
                                                         20          Public entertainment43                   No limit         Any contractor                              $2,000 p.a.25    17
                                                         17       Dependent personal services15               119 days         Any foreign resident                        No limit         16
                                                         20          Public entertainment43                   No limit         Any U.S. or foreign resident                $2,000 p.a.25    17
                                                         18       Teaching4,39                                2 years          U.S. educational institution                No limit         20
                                                         19       Studying and training:
                                                                     Remittances or allowances                5 years          Any   foreign resident                      No limit         19(1)
                                                                     Compensation during training             5 years          Any   foreign or U.S. resident              $2,000 p.a.      19(1)
                                                                     Compensation while gaining experience    12 consec. mo.   Any   U.S. or foreign resident              $7,500           19(2)
                                Ireland                  16       Independent personal services22             No limit         Any   contractor                            No limit         14
                                                         20          Public entertainment                     No limit         Any   contractor                            $20,000 p.a.25   17
                                                         17       Dependent personal services15,23            183 days         Any   foreign resident                      No limit         15
                                                         20          Public entertainment                     No limit         Any   U.S. or foreign resident              $20,000 p.a.25   17
                                                         19       Studying and training:
                                                                     Remittances or allowances10              1 year11         Any foreign resident                        No limit         20




Page 41
                               Table 2. ( Continued)




Page 42
                                                                      Category of Personal Services              Maximum                                              Maximum
                                                                                                                 Presence                                            Amount of        Treaty Article
                                                             1
                                          Country      Code                   Purpose                              in U.S.            Required Employer or Payer    Compensation         Citation
                                            (1)         (2)                     (3)                                  (4)                           (5)                    (6)               (7)
                                Israel                  15       Scholarship and fellowship grant             5 years          Any U.S. or foreign resident5       No limit          24(1)
                                                        16       Independent personal services                182 days         Any contractor                      No limit          16
                                                        20          Public entertainment                      No limit         Any contractor                      $400 per day52    18
                                                        17       Dependent personal services14,15             182 days         Israeli resident16                  No limit          17
                                                        20          Public entertainment                      No limit         Any U.S. or foreign resident        $400 per day52    18
                                                        18       Teaching4,37                                 2 years          U.S. educational institution        No limit          23
                                                        19       Studying and training:
                                                                    Remittances or allowances                 5 years          Any foreign resident                No limit          24(1)
                                                                    Compensation during study or
                                                                       training                               5 years          Any U.S. or foreign resident        $3,000 p.a.       24(1)
                                                                    Compensation while gaining experience2    12 consec. mo.   Israeli resident                    $7,500            24(2)
                                                                    Compensation under U.S.
                                                                       Government program                     1 year           U.S. Government or its contractor   $10,000           24(3)
                                                                                                  7,22
                                Italy                   16       Independent personal services                183 days         Any contractor                      No limit          14
                                                        20          Public entertainment                      90 days          Any contractor                      $12,000 p.a.25    17(1)
                                                        17       Dependent personal services7,15              183 days         Any foreign resident                No limit          15
                                                        20          Public entertainment                      90 days          Any U.S. or foreign resident        $12,000 p.a.25    17(1)
                                                        18       Teaching4                                    2 years          U.S. educational institution        No limit          20
                                                        19       Studying and training:
                                                                    Remittances or allowances                 No limit         Any   foreign resident              No limit          21
                                Jamaica                 16       Independent personal services22              89 days          Any   foreign contractor            No limit          14
                                                                                                              89 days          Any   U.S. contractor               $5,000 p.a.       14
                                                        20          Public entertainment                      No limit         Any   contractor                    $400 per day
                                                                                                                                                                   or $5,000 p.a.6   18
                                                        17       Dependent personal services15                183 days         Any foreign resident                $5,000 p.a.       15
                                                        20         Public entertainment                       No limit         Any U.S. or foreign resident        $400 per day 6
                                                                                                                                                                   or $5,000 p.a.    18
                                                                     Directors’ fees                          No limit         U.S. resident                       $400 per day6     16
                                                        18       Teaching4,39                                 2 years          U.S. educational institution        No limit          22
                                                        19       Studying and training:20
                                                                     Remittances or allowances10              No limit         Any foreign resident                No limit          21(1)
                                                                     Compensation during study                12 consec. mo.   Jamaican resident                   $7,500 p.a.       21(2)
                                                                     Compensation while gaining experience2   12 consec. mo.   Jamaican resident                   $7,500 p.a.       21(2)
                                Japan                   16       Independent personal service 7,54
                                                        20           Public entertainment                     No limit         Any contractor                      $10,000 p.a. 25   16
                                                        17       Dependent personal services7,15              183 days         Any foreign resident                No limit          14
                                                        20           Public entertainment                     No limit         Any U.S. or foreign resident        $10,000 p.a. 25   16
                                                        18       Teaching or research 4                       2 years          Any U.S. educational institution    No limit          20
                                                        19        Studying and training:
                                                                     Remittances or allowances                1 year 11        Any   foreign resident              No   limit        19
                                                                                                  44
                                Kazakhstan              15       Scholarship or fellowship grant              5 years31        Any   U.S. or foreign resident5     No   limit        19
                                                        16       Independent personal services22              183 days         Any   contractor                    No   limit        14
                                                        17       Dependent personal services7,15              183 days         Any   foreign resident              No   limit        15
                                                        19       Studying and training:4
                                                                    Remittances or allowances                 5 years          Any foreign resident                No limit          19

                                Korea, Rep. of          15       Scholarship or fellowship grant              5 years          Any U.S. or foreign resident5       No limit          21(1)
                                                        16       Independent personal services22              182 days         Any contractor                      $3,000 p.a.       18
                                                        17       Dependent personal services15                182 days         Korean resident16                   $3,000 p.a.       19
                                                        18       Teaching4                                    2 years          U.S. educational institution        No limit          20
                                                        19       Studying and training:
                                                                    Remittances or allowances                 5 years          Any foreign resident                No limit          21(1)
                                                                    Compensation during training              5 years          Any foreign or U.S. resident        $2,000 p.a.       21(1)
                                                                    Compensation while gaining experience2    1 year           Korean resident                     $5,000            21(2)
                                                                    Compensation under U.S.
                                                                       Government program                     1 year           U.S. Government or its contractor   $10,000           21(3)




Publication 901 (April 2008)
                               Table 2. ( Continued)
                                                                     Category of Personal Services             Maximum                                               Maximum
                                                                                                               Presence                                             Amount of       Treaty Article
                                                             1
                                            Country    Code                 Purpose                              in U.S.             Required Employer or Payer    Compensation        Citation
                                              (1)       (2)                     (3)                                (4)                              (5)                  (6)              (7)
                                Latvia                  15       Scholarship or fellowship grants4          5 years           Any   U.S. or foreign resident5     No limit         20(1)
                                                        16       Independent personal services22            183 days          Any   contractor                    No limit         14
                                                        20          Public entertainment                    No limit          Any   contractor                    $20,00030        17
                                                        17       Dependent personal services7,15            183 days          Any   foreign resident              No limit         15
                                                        20          Public entertainment                    No limit          Any   U.S. or foreign resident      $20,00030        17
                                                        19       Studying and training:




Publication 901 (April 2008)
                                                                    Remittances or allowances               5 years           Any foreign resident                No limit         20(1)
                                                                    Compensation during training            12 consec. mos.   Latvian resident                    $8,000           20(2)
                                                                                                            5 years           Other foreign or U.S. resident      $5,000 p.a.      20(1)
                                                                    Compensation while gaining
                                                                       experience2                          12 consec. mos.   Latvian resident                    $8,000           20(2)
                                                                    Compensation under U.S.
                                                                       Government program                   1 year            U.S. Government or its contractor   $10,000          20(3)
                                Lithuania               15       Scholarship or fellowship grants4          5 years           Any U.S. or foreign resident5       No limit         20(1)
                                                        16       Independent personal services22            183 days          Any contractor                      No limit         14
                                                        20          Public entertainment                    No limit          Any contractor                      $20,00030        17
                                                        17       Dependent personal services7,15            183 days          Any foreign resident                No limit         15
                                                        20          Public entertainment                    No limit          Any U.S. or foreign resident        $20,00030        17
                                                        19       Studying and training:
                                                                    Remittances or allowances               5 years           Any foreign resident                No limit         20(1)
                                                                    Compensation during training            12 consec. mos.   Lithuanian resident                 $8,000           20(2)
                                                                                                            5 years           Other foreign or U.S. resident      $5,000 p.a.      20(1)
                                                                    Compensation while gaining
                                                                      experience2                           12 consec. mos.   Lithuanian resident                 $8,000           20(2)
                                                                    Compensation under U.S.
                                                                      Government program                    1 year            U.S. Government or its contractor   $10,000          20(3)
                                Luxembourg              16       Independent personal services22            No limit          Any   contractor                    No limit         15
                                                        20          Public entertainment                    No limit          Any   contractor                    $10,00025        18
                                                        17       Dependent personal services15,24           183 days          Any   foreign resident              No limit         16
                                                        20          Public entertainment                    No limit          Any   foreign resident              $10,00025        18
                                                        18       Teaching or research8                      2 years           Any   U.S. or foreign resident      No limit         21(2)
                                                        19       Studying and training:
                                                                    Remittances or allowances10             2 years11         Any   U.S. or foreign resident      No limit         21(1)
                                Mexico                  16       Independent personal services22            183 days          Any   contractor                    No limit         14
                                                        20          Public entertainment                    No limit          Any   contractor                    $3,000 p.a.30    18
                                                        17       Dependent personal services15,23           183 days          Any   foreign resident              No limit         15
                                                        20          Public entertainment                    No limit          Any   U.S. or foreign resident      $3,000 p.a.30    18
                                                        19       Studying and training:
                                                                    Remittances or allowances               No limit          Any foreign resident                No limit         21
                                Morocco                 15       Scholarship or fellowship grant            5 years           Any U.S. or foreign resident5       No limit         18
                                                        16       Independent personal services12,22         182 days          Any contractor                      $5,000           14
                                                        17       Dependent personal services12,15           182 days          Moroccan resident16                 No limit         15
                                                        19       Studying and training:
                                                                    Remittances or allowances               5 years           Any foreign resident                No limit         18
                                                                    Compensation during training            5 years           U.S. or any foreign resident        $2,000 p.a.      18
                                Netherlands             15       Scholarship or fellowship grant33          3 years           Any U.S. or foreign resident5       No limit         22(2)
                                                        16       Independent personal services22            No limit          Any contractor                      No limit         15
                                                        20          Public entertainment                    No limit          Any contractor                      $10,000 p.a.25   18
                                                        17       Dependent personal services15,23           183 days          Any foreign resident                No limit         16
                                                        20          Public entertainment                    183 days          Any foreign resident                $10,000 p.a.25   18
                                                        18       Teaching4,34                               2 years           U.S. educational institution        No limit         21(1)
                                                        19       Studying and training:33
                                                                    Remittances or allowances               No limit          Any foreign resident                No limit         22(1)
                                                                    Compensation while gaining experience   No limit          Any U.S. or foreign resident        $2,000 p.a.      22(1)
                                                                    Compensation while recipient of
                                                                       scholarship or fellowship grant      3 years           Any U.S. or foreign resident        $2,000 p.a.36    22(2)




Page 43
Page 44
                               Table 2. ( Continued)
                                                                   Category of Personal Services              Maximum                                                    Maximum
                                                                                                              Presence                                                  Amount of       Treaty Article
                                        Country        Code1              Purpose                              in U.S.             Required Employer or Payer          Compensation        Citation
                                          (1)           (2)                   (3)                                (4)                             (5)                         (6)              (7)
                                New Zealand             16     Independent personal services22             183 days         Any   contractor                          No limit         14
                                                        20        Public entertainment                     183 days         Any   contractor                          $10,00025        17
                                                        17     Dependent personal services15               183 days         Any   foreign resident                    No limit         15
                                                        20        Public entertainment15                   183 days         Any   foreign resident                    $10,00025        17
                                                        19     Studying and training:
                                                                  Remittances or allowances10              No limit         Any foreign resident                      No limit         20
                                Norway                  15     Scholarship or fellowship grant             5 years          Any U.S. or foreign resident5             No limit         16(1)
                                                        16     Independent personal services22             182 days         Any contractor                            No limit         13
                                                        20        Public entertainment                     90 days          Any contractor                            $10,000 p.a.     13
                                                        17     Dependent personal services                 182 days         Norwegian resident16                      No limit         14
                                                        18     Teaching4                                   2 years          U.S. educational institution              No limit         15
                                                        19     Studying and training:
                                                                  Remittances or allowances                5 years          Any foreign resident                      No limit         16(1)
                                                                  Compensation during training             5 years          U.S. or any foreign resident              $2,000 p.a.      16(1)
                                                                  Compensation while gaining experience2   12 consec. mo.   Norwegian resident                        $5,000           16(2)
                                                                  Compensation under U.S.
                                                                     Government program                    1 year           U.S. Government or its contractor         $10,000          16(3)
                                Pakistan                15     Scholarship or fellowship grant             No limit         Pakistani nonprofit organization          No limit         XIII(1)
                                                        16     Independent personal services14             183 days         Pakistani resident contractor             No limit         XI
                                                        17     Dependent personal services14               183 days         Pakistani resident                        No limit         XI
                                                        18     Teaching                                    2 years          U.S. educational institution              No limit         XII
                                                        19     Studying and training:
                                                                  Remittances or allowances                No limit         Any foreign resident                      No limit         XIII(1)
                                                                  Compensation during training             No limit         U.S. or any foreign resident              $5,000 p.a.      XIII(1)
                                                                  Compensation while gaining experience2   1 year           Pakistani resident                        $6,000           XIII(2)
                                                                  Compensation while under U.S.
                                                                     Government program                    No limit         U.S. Government, its contractor, or any
                                                                                                                               foreign resident employer              $10,000          XIII(3)
                                Philippines             15     Scholarship or fellowship grant             5 years          Any   U.S. or foreign resident5           No limit         22(1)
                                                        16     Independent personal services22             89 days          Any   foreign contractor                  No limit         15
                                                                                                           89 days          Any   U.S. resident                       $10,000 p.a.     15
                                                        20        Public entertainment                     No limit         Any   contractor                          $100 per day
                                                                                                                                                                      or $3,000 p.a.   17
                                                        17     Dependent personal services15               89 days          Any Philippines resident16                No limit         16
                                                        20       Public entertainment                      No limit         Any U.S. or foreign resident              $100 per day
                                                                                                                                                                      or $3,000 p.a.   17
                                                        18     Teaching4,38                                2 years          U.S. educational institution              No limit         21
                                                        19     Studying and training:
                                                                  Remittances or allowances                5 years          Any foreign resident                      No limit         22(1)
                                                                  Compensation during study                5 years          Any U.S. or foreign resident              $3,000 p.a.      22(1)
                                                                  Compensation while gaining experience2   12 consec. mo.   Philippines resident                      $7,500 p.a.      22(2)
                                                                  Compensation while under U.S.
                                                                     Government program                    1 year           U.S. Government or its contractor         $10,000 p.a.     22(3)
                                Poland                  15     Scholarship or fellowship grant             5 years          Any U.S. or foreign resident5             No   limit       18(1)
                                                        16     Independent personal services               182 days         Any contractor                            No   limit       15
                                                        17     Dependent personal services15               182 days         Any foreign resident                      No   limit       16
                                                        18     Teaching4                                   2 years          U.S. educational institution              No   limit       17
                                                        19     Studying and training:
                                                                  Remittances or allowances                5 years          Any foreign resident                      No limit         18(1)
                                                                  Compensation during training             5 years          U.S. or any foreign resident              $2,000 p.a.      18(1)
                                                                  Compensation while gaining experience2   1 year           Polish resident                           $5,000           18(2)
                                                                  Compensation while under U.S.
                                                                     Government program                    1 year           U.S. Government or its contractor         $10,000          18(3)




Publication 901 (April 2008)
                               Table 2. ( Continued)
                                                                   Category of Personal Services              Maximum                                                         Maximum
                                                                                                              Presence                                                       Amount of        Treaty Article
                                           Country     Code1               Purpose                             in U.S.              Required Employer or Payer              Compensation         Citation
                                             (1)        (2)                  (3)                                 (4)                           (5)                               (6)                (7)
                                Portugal                15     Scholarship or fellowship grant             5 years           Any U.S. or foreign resident5                  No limit         23(1)
                                                        16     Independent personal services22             182 days          Any contractor                                 No limit         15
                                                        20        Public entertainment                     No limit          Any contractor                                 $10,000 p.a.30   19




Publication 901 (April 2008)
                                                        17     Dependent personal services7,15             183 days          Any foreign resident                           No limit         16
                                                        20        Public entertainment                     No limit          Any U.S. or foreign resident                   $10,000 p.a.30   19
                                                        18     Teaching4,41                                2 years           U.S. educational institution                   No limit         22
                                                        19     Studying and training:4
                                                                  Remittances or allowances                5 years           Any foreign resident                           No limit         23(1)
                                                                  Compensation during study or
                                                                     training                              12 consec. mos.   Portuguese resident                            $8,000           23(2)
                                                                                                           5 years           Other foreign or U.S. resident                 $5,000 p.a.      23(1)
                                                                                                       2
                                                                  Compensation while gaining experience    12 consec. mos.   Portuguese resident                            $8,000           23(2)
                                Romania                 15     Scholarship or fellowship grant             5 years           Any U.S. or foreign resident5                  No limit         20(1)
                                                        16     Independent personal services49             182 days          Any contractor                                 No limit         14
                                                        20        Public entertainment                     90 days           Any contractor                                 $3,000           14
                                                        17     Dependent personal services15               182 days          Romanian resident                              No limit         15
                                                        20        Public entertainment                     89 days           Romanian resident                              $2,999.99        15
                                                        18     Teaching4                                   2 years           U.S. educational institution                   No limit         19
                                                        19     Studying and training:
                                                                  Remittances or allowances                5 years           Any foreign resident                           No limit         20(1)
                                                                  Compensation during training             5 years           U.S. or any foreign resident                   $2,000 p.a.      20(1)
                                                                  Compensation while gaining experience2   1 year            Romanian resident                              $5,000           20(2)
                                                                  Compensation while under U.S.
                                                                     Government program                    1 year            U.S. Government or its contractor              $10,000          20(3)
                                Russia                  15     Scholarship or fellowship grant44           5 years31         Any U.S. or foreign resident5                  No limit         18
                                                        16     Independent personal services22             183 days          Any contractor                                 No limit         13
                                                        17     Dependent personal services7,15,32          183 days          Any foreign resident                           No limit         14
                                                        19     Studying and training:4
                                                                  Remittances                              5 years31         Any foreign resident                           No limit         18
                                Slovak Republic         15     Scholarship or fellowship grant             5 years           Any U.S. or foreign resident5                  No limit         21(1)
                                                        16     Independent personal services22             183 days          Any contractor                                 No limit         14
                                                        20        Public entertainment                     183 days          Any contractor                                 $20,000 p.a.30   18
                                                        17     Dependent personal services15,24            183 days          Any foreign resident                           No limit         15
                                                        20        Public entertainment                     183 days          Any foreign resident                           $20,000 p.a.30   18
                                                        18     Teaching4,35                                2 years           Any U.S. educational or research institution   No limit         21(5)
                                                        19     Studying and training:
                                                                  Remittances or allowances                5 years           Any foreign resident                           No limit         21(1)
                                                                  Compensation during training             5 years           Any U.S. or foreign resident                   $5,000 p.a.      21(1)
                                                                  Compensation while gaining experience2   12 consec. mos.   Slovak resident                                $8,000           21(2)
                                                                  Compensation while under U.S.
                                                                     Government program                    1 year            U.S. Government                                $10,000          21(3)
                                                                                               4                    47                                      5
                                Slovenia                15     Scholarship or fellowship grant             5 years           Any   U.S. or foreign resident                 No limit         20(1)
                                                        16     Independent personal services22             No limit          Any   contractor                               No limit         14
                                                        20        Public entertainment                     No limit          Any   contractor                               $15,000 p.a.51   17
                                                        17     Dependent personal services15, 24           183 days          Any   foreign resident                         No limit         15
                                                        20        Public entertainment                     No limit          Any   U.S. or foreign resident                 $15,000 p.a.51   17
                                                        18     Teaching or research4                       2 years48         Any   U.S. or foreign resident                 No limit         20(3)
                                                        19     Studying and training4
                                                                  Remittances or allowances                5 years47         Any foreign resident                           No limit         20(1)
                                                                  Compensation during training             12 mos.           Slovenian resident                             $8,000           20(2)
                                                                                                           5 years47         Other foreign or U.S. resident                 $5,000 p.a.      20(1)
                                                                  Compensation while gaining experience2   12 mos.           Slovenian resident                             $8,000           20(2)




Page 45
Page 46
                               Table 2. ( Continued)
                                                                     Category of Personal Services              Maximum                                              Maximum
                                                                                                                Presence                                            Amount of        Treaty Article
                                                             1
                                            Country    Code                  Purpose                             in U.S.              Required Employer or Payer   Compensation         Citation
                                              (1)       (2)                    (3)                                 (4)                           (5)                    (6)                (7)
                                South Africa            16       Independent personal services22             183 days          Any   contractor                    No limit         14
                                                        20          Public entertainment                     No limit          Any   contractor                    $7,50030         17
                                                        17       Dependent personal services15,24            183 days          Any   foreign resident              No limit         15
                                                        20          Public entertainment                     No limit          Any   U.S. or foreign resident      $7,50030         17
                                                        19       Studying and training:       10
                                                                    Remittances or allowances                1 year11          Any foreign resident                No limit         20
                                                                                                                                                             5
                                Spain                   15       Scholarship or fellowship grant             5 years           Any   U.S. or foreign resident      No limit         22(1)
                                                        16       Independent personal services22             No limit          Any   contractor                    No limit         15
                                                        20          Public entertainment                     No limit          Any   contractor                    $10,000 p.a.30   19
                                                        17       Dependent personal services15               183 days          Any   foreign resident              No limit         16
                                                        20          Public entertainment                     No limit          Any   U.S. or foreign resident      $10,000 p.a.30   19
                                                        19       Studying and training:4
                                                                    Remittances or allowances                5 years           Any foreign resident                No limit         22(1)
                                                                    Compensation during training             5 years           Any U.S. or foreign resident        $5,000 p.a.      22(1)
                                                                    Compensation while gaining experience2   12 consec. mo.    Spanish resident                    $8,000           22(2)

                                Sri Lanka               16       Independent personal services22, 24         183   days        Any   contractor                    No limit         15
                                                        20          Public entertainment22                   183   days        Any   contractor                    $6,000 p.a.51    18
                                                        17       Dependent personal services15, 24           183   days        Any   foreign resident              No limit         16
                                                        20          Public entertainment15                   183   days        Any   foreign resident              $6,000 p.a.51    18
                                                        19       Studying and training:
                                                                    Remittances or allowances10              No limit          Any foreign resident                No limit         21(1)
                                                                    Compensation while gaining experience2   1 year            Sri Lankan resident55               $6,000           21(2)

                                Sweden                  16       Independent personal services22             No limit          Any   contractor                    No limit         14
                                                        20          Public entertainment                     No limit          Any   contractor                    $6,00042         18
                                                        17       Dependent personal services15,23            183 days          Any   foreign resident              No limit         15
                                                        20          Public entertainment                     No limit          Any   U.S. or foreign resident      $6,00042         18
                                                        19       Studying and training:
                                                                    Remittances or allowances10              No limit          Any   foreign resident              No limit         21
                                Switzerland             16       Independent personal services22             No limit          Any   contractor                    No limit         14
                                                        20          Public entertainment                     No limit          Any   contractor                    $10,00025        17
                                                        17       Dependent personal services7,15             183 days          Any   foreign resident              No limit         15
                                                        20          Public entertainment                     No limit          Any   U.S. or foreign resident      $10,00025        17
                                                        19       Studying and training:
                                                                  Remittances or allowances10                No limit          Any   foreign resident              No limit         20
                                Thailand                15       Scholarship or fellowship grant             5 years           Any   U.S. or foreign resident5     No limit         22(1)
                                                        16       Independent personal services22             89 days           Any   U.S. resident                 $10,000          15
                                                                                                             89 days           Any   foreign contractor            No limit45       15
                                                        20          Public entertainment                     No limit          Any   contractor                    $100 per day 9   19
                                                                                                                                                                   or $3,000 p.a.
                                                        17       Dependent personal services15,23            183 days          Any foreign resident                No limit         16
                                                        20         Public entertainment                      No limit          Any U.S. or foreign resident        $100 per day 9   19
                                                                                                                                                                   or $3,000 p.a.
                                                        18       Teaching or research4,38                    2 years           Any U.S. or foreign resident        No limit         23
                                                        19       Studying and training:
                                                                    Remittances or allowances                5 years           Any foreign resident                No limit         22(1)
                                                                    Compensation during training             5 years           Any U.S. or foreign resident        $3,000 p.a.      22(1)
                                                                 Compensation while gaining experience2      12 consec. mos.   Thai resident                       $7,500           22(2)
                                                                    Compensation under U.S.
                                                                      Government program                     1 year            U.S. Government                     $10,000          22(3)




Publication 901 (April 2008)
                               Table 2. ( Continued)
                                                                      Category of Personal Services                Maximum                                                            Maximum
                                                                                                                   Presence                                                          Amount of       Treaty Article
                                                             1




Publication 901 (April 2008)
                                          Country      Code                 Purpose                                 in U.S.            Required Employer or Payer                   Compensation        Citation
                                            (1)         (2)                     (3)                                    (4)                               (5)                              (6)              (7)
                                Trinidad and Tobago     15       Scholarship or fellowship grant                5 years          Any U.S. or foreign resident5                     No limit         19(1)
                                                        16       Independent personal services13                183 days         Any foreign resident contractor                   No limit         17
                                                                                                                183 days         Any U.S. contractor                               $3,0006          17
                                                        17       Dependent personal services13                  183 days         Any foreign resident                              No limit         17
                                                                                                                183 days         Any U.S. resident                                 $3,0006          17
                                                        18       Teaching4                                      2 years          U.S. educational institution or U.S. Government   No limit         18
                                                        19       Studying and training:
                                                                    Remittances or allowances                   5   years        Any foreign resident                              No limit         19(1)
                                                                    Compensation during training                5   years        U.S. or any foreign resident                      $2,000 p.a.6     19(1)
                                                                    Compensation during professional training   5   years        U.S. or any foreign resident                      $5,000 p.a.6     19(1)
                                                                    Compensation while gaining experience2      1   year         Trinidad–Tobago resident                          $5,0006          19(2)
                                                                    Compensation under U.S.
                                                                       Government program                       1 year           U.S. Government or its contractor                 $10,0006         19(3)
                                Tunisia                 15       Scholarship or fellowship grant10              5 years          Any U.S. or foreign resident5                     No limit         20
                                                        16       Independent personal services22                183 days         U.S. resident contractor                          $7,500 p.a.      14
                                                        20          Public entertainment                        No limit         Any contractor                                    $7,500 p.a.25    17
                                                        17       Dependent personal services15                  183 days         Any foreign resident                              No limit         15
                                                        20          Public entertainment                        No limit         Any U.S. or foreign resident                      $7,500 p.a.25    17
                                                        19       Studying and training:10
                                                                    Remittances or allowances                   5 years          Any   foreign resident                            No limit         20
                                                                    Compensation during training                5 years          Any   U.S. or foreign resident                    $4,000 p.a.      20
                                Turkey                  16       Independent personal services22                183 days         Any   contractor                                  No limit         14
                                                        20          Public entertainment46                      No limit         Any   contractor                                  $3,00053         17
                                                        17       Dependent personal services15,24               183 days         Any   foreign resident                            No limit         15
                                                        20          Public entertainment46                      No limit         Any   U.S. or foreign resident                    $3,00053         17
                                                        18       Teaching or research                           2 years          Any   foreign resident                            No limit         20(2)
                                                        19       Studying and training:
                                                                    Remittances or allowances10                 No limit         Any foreign resident                              No limit         20(1)
                                                                                                  44                        31                                   5
                                Ukraine                 15       Scholarship or fellowship grant                5 years          Any U.S. or foreign resident                      No limit         20
                                                        16       Independent personal services22,50             No limit         Any contractor                                    No limit         14
                                                        17       Dependent personal services15,23,50            183 days         Any foreign resident                              No limit         15
                                                        19       Studying and training:
                                                                    Remittances or allowances10                 5 years31        Any foreign resident                              No limit         20
                                                                                                  7,54
                                United Kingdom          16       Independent personal services
                                                        20          Public entertainment                        No limit         Any   contractor                                  $20,000 p.a.25   16
                                                        17       Dependent personal services15, 24              183 days         Any   foreign resident                            No limit         14
                                                        20          Public entertainment                        No limit         Any   U.S. or foreign resident                    $20,000 p.a.25   16
                                                        18       Teaching or research4                          2 years          Any   U.S. educational institution                No limit         20A
                                                        19       Studying and training:
                                                                    Remittances or allowances10                 No limit57       Any foreign resident                              No limit         20




Page 47
Page 48
                               Table 2. (Continued)
                                                                    Category of Personal Services       Maximum                                          Maximum
                                                                                                        Presence                                        Amount of      Treaty Article
                                                            1
                                        Country       Code                  Purpose                      in U.S.          Required Employer or Payer   Compensation       Citation
                                          (1)          (2)                    (3)                          (4)                       (5)                    (6)              (7)
                                Venezuela              15       Scholarship or fellowship grants4    5 years47     Any   U.S. or foreign resident5     No limit       21(1)
                                                       16       Independent personal services22,24   No limit      Any   contractor                    No limit       14
                                                       20          Public entertainment              No limit      Any   contractor                    $6,00030       18
                                                       17       Dependent personal services15,24     183 days      Any   foreign resident              No limit       15
                                                       20          Public entertainment              No limit      Any   U.S. or foreign resident      $6,00030       18
                                                       18       Teaching4                            2 years48     Any   U.S. or foreign resident      No limit       21(3)
                                                       19       Studying and training:4
                                                                   Remittances or allowances         5 years47     Any foreign resident                No limit       21(1)
                                                                   Compensation during training      12 mos.       Venezuelan resident                 $8,000         21(2)
                                                                                                            47
                                                                                                     5 years       Other foreign or U.S. resident      $5,000 p.a.    21(1)
                                                                   Compensation2 while gaining
                                                                     experience                      12 mos.       Venezuelan resident                 $8,000         21(2)




Publication 901 (April 2008)
                               1                                                                         21                                                                      39
                                    Refers to income code numbers under which the income is                   Amounts received in excess of a reasonable fixed amount                 Exemption does not apply if the individual previously claimed
                                    reported on Forms 1042-S. Personal services must be                       payable to all directors for attending meetings in the United           the benefit of this Article.
                                    performed by a nonresident alien individual who is a resident             States are taxable.                                                40
                                                                                                                                                                                      The combined period of benefits under Articles 20 and 21(1)
                                    of the specified treaty country.                                     22
                                                                                                              Exemption does not apply to the extent income is attributable           cannot exceed 5 years.
                               2                                                                                                                                                 41
                                    Applies only if training or experience is received from a person          to the recipient’s fixed U.S. base. For residents of Iceland,           Exemption does not apply if the individual either (a)
                                    other than alien’s employer.                                              Korea, and Norway, the fixed base must be maintained for                previously claimed the benefit of this Article, or (b) during the
                               3                                                                              more than 182 days; for residents of Morocco, the fixed
                                    Employment with a team which participates in a league with                                                                                        immediately preceding period, claimed the benefit of Article
                                    regularly scheduled games in both countries is covered                    base must be maintained for more than 89 days.                          23. The benefits under Articles 22 and 23 cannot be claimed
                                    under the provisions for dependent personal services.                23                                                                           at the same time.
                                                                                                              Fees paid to a resident of the treaty country for services as a
                               4                                                                                                                                                 42
                                    Does not apply to compensation for research work primarily                director of a U.S. corporation are subject to U.S. tax, unless          Exemption does not apply if gross receipts (including
                                    for private benefit.                                                      the services are performed in the country of residence.                 reimbursements) exceed this amount during any 12-month
                               5                                                                         24




Publication 901 (April 2008)
                                    Grant must be from a nonprofit organization. In many cases,               Fees paid to a resident of the treaty country for services              period.
                                                                                                                                                                                 43
                                    the exemption also applies to amounts from either the U.S. or             performed in the United States as a director of a U.S.                  This provision does not apply if the competent authority of
                                    foreign government. For Indonesia and the Netherlands, the                corporation are subject to U.S. tax.                                    the treaty country certifies that the visit is substantially
                                    exemption also applies if the amount is awarded under a              25                                                                           supported by that treaty country.
                                                                                                              Exemption does not apply if gross receipts (including
                                    technical assistance program entered into by the United States                                                                               44
                                                                                                              reimbursements) exceed this amount.                                     Applies to grants, allowances, and other similar payments
                                    or the foreign government, or its political subdivisions or local    26                                                                           received for studying or doing research.
                                                                                                              Exemption does not apply if net income exceeds this
                                    authorities.                                                                                                                                 45
                               6
                                                                                                              amount.                                                                 A $10,000 limit applies if the expense is borne by a permanent
                                    Reimbursed expenses are not taken into account in figuring           27                                                                           establishment or a fixed base in the United States.
                                                                                                              Exemption does not apply to payments borne by a
                                    any maximum compensation to which the exemption applies.                                                                                     46
                                                                                                              permanent establishment in the United States or paid by a               This provision does not apply if these activities are substantially
                                    For Japan and Trinidad and Tobago, only reimbursed travel                 U.S. citizen or resident or the federal, state, or local                supported by a nonprofit organization or by public funds of the
                                    expenses are disregarded in figuring the maximum                          government.                                                             treaty country or its political subdivisions or local authorities.
                                    compensation.                                                        28                                                                      47
                               7                                                                              Exemption does not apply if compensation exceeds this                   Applies to any additional period that a full-time student needs
                                    Does not apply to fees of a foreign director of a U.S.                    amount.                                                                 to complete the educational requirements as a candidate for
                                    corporation.                                                         29                                                                           a postgraduate or professional degree from a recognized
                               8                                                                              The exemption applies only to income from activities
                                    Does not apply to compensation for research work for other                performed under special cultural exchange programs agreed               educational institution.
                                    than the U.S. educational institution involved.                                                                                              48
                               9
                                                                                                              to by the U.S. and Chinese governments.                                 The combined benefit for teaching cannot exceed 5 years.
                                    Exemption does not apply if gross receipts exceed this amount.       30                                                                      49
                                                                                                              Exemption does not apply if gross receipts (or compensation             Exemption does not apply if the recipient maintains a
                                    Income is fully exempt if visit to the United States is                   for Portugal), including reimbursements, exceed this amount.            permanent establishment in the U.S. with which the income is
                                    substantially supported by public funds of the treaty country             Income is fully exempt if visit to the United States is                 effectively connected.
                                    or its political subdivisions or local authorities.                       substantially supported by public funds of the treaty country      50
                               10                                                                                                                                                     The exemption does not apply to income received for
                                    Applies only to full-time student or trainee.                             or its political subdivisions or local authorities.
                               11
                                                                                                                                                                                      performing services in the United States as an entertainer or
                                    The time limit pertains only to an apprentice or business trainee.   31
                                                                                                              The 5-year limit pertains only to training or research.                 a sportsman. However, this income is exempt for U.S. income
                               12                                                                        32
                                    Does not apply to compensation paid to public entertainers                Compensation from employment directly connected with a                  tax if the visit is (a) substantially supported by public funds of
                                    (actors, artists, musicians, athletes, etc.).                             place of business that is not a permanent establishment is              Ukraine, its political subdivisions, or local authorities, or (b)
                               13
                                    Does not apply to compensation paid to public entertainers                exempt if the alien is present in the United States for a               made under a specific arrangement agreed to by the
                                    that is more than $100 a day.                                             period not exceeding 12 consecutive months. Compensation                governments of the treaty countries.
                               14                                                                                                                                                51
                                    Exemption applies only if the compensation is subject to tax              for technical services directly connected with the application          Exemption does not apply if gross receipts, including
                                    in the country of residence.                                              of a right or property giving rise to a royalty is exempt if the        reimbursements, exceed this amount during the year. Income
                               15                                                                             services are provided as part of a contract granting the use            is fully exempt if visit is wholly or mainly supported by public
                                    The exemption does not apply if the employee’s
                                    compensation is borne by a permanent establishment (or in                 of the right or property.                                               funds of one or both of the treaty countries or their political
                                                                                                         33
                                    some cases a fixed base) that the employer has in the                     Exemption does not apply if, during the immediately                     subdivisions or local authorities.
                                                                                                                                                                                 52
                                    United States.                                                            preceding period, the individual claimed the benefits of                If the compensation exceeds $400 per day, the entertainer may
                               16                                                                             Article 21.                                                             be taxed on the full amount. If the individual receives a fixed
                                    The exemption also applies if the employer is a permanent            34
                                    establishment in the treaty country but is not a resident of              Exemption does not apply if, during the immediately                     amount for more than one performance, the amount is prorated
                                    the treaty country.                                                       preceding period, the individual claimed the benefits of                over the number of days the individual performs the services
                               17                                                                             Article 22.                                                             (including rehearsals).
                                    This exemption does not apply in certain cases if the                35                                                                      53
                                    employee is a substantial owner of that employer and the                  Exemption does not apply if the individual either (a) claimed           Exemption does not apply if gross receipts exceed this amount.
                                                                                                                                                                                 54
                                    employer is engaged in certain defined activities.                        the benefit of Article 21(5) during a previous visit, or (b)            Treated as business profits under Article 7 of the treaty.
                               18                                                                             during the immediately preceding period, claimed the benefit       55
                                    The exemption is also extended to journalists and                                                                                                 Applies also to a participant in a program sponsored by the
                                    correspondents who are temporarily in the U.S. for periods                of Article 21(1), (2), or (3).                                          U.S. Government or an international organization.
                                                                                                         36
                                    not longer than 2 years and who receive compensation from                 Exemption applies only to compensation for personal                56
                                                                                                                                                                                      Exemption does not apply if during the immediately preceding
                                    abroad.                                                                   services performed in connection with, or incidental to, the            period, the individual claimed the benefit of Article 20(2), (3),
                               19                                                                             individual’s study, research, or training.
                                    Also exempt are amounts of up to $10,000 received from                                                                                            or (4).
                                                                                                         37                                                                      57
                                    U.S. sources to provide ordinary living expenses. For                     Exemption does not apply if, during the immediately                     Exemption applies to buisiness apprentice (trainee) only for a
                                    students, the amount will be less than $10,000, determined                preceding period, the individual claimed the benefits of                period not exceeding 1 year (2 years for Belgium) from the date
                                    on a case by case basis.                                                  Article 24(1).                                                          of arrival in the United States.
                               20                                                                        38
                                    A student or trainee may choose to be treated as a U.S.                   Exemption does not apply if, during the immediately
                                    resident for tax purposes. If the choice is made, it may not              preceding period, the individual claimed the benefits of
                                    be changed without the consent of the U.S. competent                      Article 22(1).
                                    authority.




Page 49
Table 3. List of Tax Treaties (Updated through December 31, 2007)
                                                                                              Applicable Treasury
                                  Official 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. 246
    Protocol                  TIAS                Jan. 1, 2004
Austria                       TIAS                Jan. 1, 1999
Bangladesh                    TIAS                Jan. 1, 2007
Barbados                      TIAS 11090          Jan. 1, 1984         1991-2 C.B. 436    1991-2 C.B. 466
    Protocol                  TIAS                Jan. 1, 2005
Belgium                       TIAS                Jan. 1, 2008
Canada2                       TIAS 11087          Jan. 1, 1985         1986-2 C.B. 258    1987-2 C.B. 298
    Protocol                  TIAS                Jan. 1, 1996
China, People’s Republic of   TIAS 12065          Jan. 1, 1987         1988-1 C.B. 414    1988-1 C.B. 447
Commonwealth of Independent
   States3                    TIAS 8225           Jan. 1, 1976         1976-2 C.B. 463    1976-2 C.B. 475
Cyprus                        TIAS 10965          Jan. 1, 1986         1989-2 C.B. 280    1989-2 C.B. 314
Czech Republic                TIAS                Jan. 1, 1993
Denmark                       TIAS                Jan. 1, 2001
    Protocol                  TIAS                Jan. 1, 2008
Egypt                         TIAS 10149          Jan. 1, 1982         1982-1 C.B. 219    1982-1 C.B. 243
Estonia                       TIAS                Jan. 1, 2000
Finland                       TIAS 12101          Jan. 1, 1991
    Protocol                  TIAS                Jan. 1, 2008
France                        TIAS                Jan. 1, 1996
    Protocol                  TIAS                Jan. 1, 2007
Germany                       TIAS                Jan. 1, 1990
    Protocol                  TIAS                Jan. 1, 2008
Greece                        TIAS 2902           Jan. 1, 1953         1958-2 C.B. 1054   T.D. 6109, 1954-2 C.B. 638
Hungary                       TIAS 9560           Jan. 1, 1980         1980-1 C.B. 333    1980-1 C.B. 354
Iceland                       TIAS 8151           Jan. 1, 1976         1976-1 C.B. 442    1976-1 C.B. 456
India                         TIAS                Jan. 1, 1991
Indonesia                     TIAS 11593          Jan. 1, 1990
Ireland                       TIAS                Jan. 1, 1998
Israel                        TIAS                Jan. 1, 1995
Italy                         TIAS 11064          Jan. 1, 1985         1992-1 C.B. 442    1992-1 C.B. 473
Jamaica                       TIAS 10207          Jan. 1, 1982         1982-1 C.B. 257    1982-1 C.B. 291
Japan                         TIAS                Jan. 1, 2005
Kazakhstan                    TIAS                Jan. 1, 1996
Korea, Republic of            TIAS 9506           Jan. 1, 1980         1979-2 C.B. 435    1979-2 C.B. 458
Latvia                        TIAS                Jan. 1, 2000
Lithuania                     TIAS                Jan. 1, 2000
Luxembourg                    TIAS                Jan. 1, 2001
Mexico                        TIAS                Jan. 1,1994
    Protocol                  TIAS                Jan. 1, 2004
Morocco                       TIAS 10195          Jan. 1, 1981         1982-2 C.B. 405    1982-2 C.B. 427
Netherlands                   TIAS                Jan. 1, 1994
    Protocol                  TIAS                Jan. 1, 2005
New Zealand                   TIAS 10772          Nov. 2, 1983         1990-2 C.B. 274    1990-2 C.B. 303
Norway                        TIAS 7474           Jan. 1, 1971         1973-1 C.B. 669    1973-1 C.B. 693
    Protocol                  TIAS 10205          Jan. 1, 1982         1982-2 C.B. 440    1982-2 C.B. 454
Pakistan                      TIAS 4232           Jan. 1, 1959         1960-2 C.B. 646    T.D. 6431, 1960-1 C.B. 755




Page 50                                                                                   Publication 901 (April 2008)
Table 3. (continued)
                                                                                                                                          Applicable Treasury
                                                 Official 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. 412
 Poland                                    TIAS 8486                     Jan. 1, 1974                  1977-1 C.B. 416                1977-1 C.B. 427
 Portugal                                  TIAS                          Jan. 1, 1996
 Romania                                   TIAS 8228                     Jan. 1, 1974                  1976-2 C.B. 492                1976-2 C.B. 504
 Russia                                    TIAS                          Jan. 1, 1994
 Slovak Republic                           TIAS                          Jan. 1, 1993
 Slovenia                                  TIAS                          Jan. 1, 2002
 South Africa                              TIAS                          Jan. 1, 1998
 Spain                                     TIAS                          Jan. 1, 1991
 Sri Lanka                                 TIAS                          Jan. 1, 2004
 Sweden                                    TIAS                          Jan. 1, 1996
   Protocol                                TIAS                          Jan. 1, 2007
 Switzerland                               TIAS                          Jan. 1, 1998
 Thailand                                  TIAS                          Jan. 1, 1998
 Trinidad and Tobago                       TIAS 7047                     Jan. 1, 1970                  1971-2 C.B. 479
 Tunisia                                   TIAS                          Jan. 1, 1990
 Turkey                                    TIAS                          Jan. 1, 1998
 Ukraine                                   TIAS                          Jan. 1, 2001
 United Kingdom                            TIAS                          Jan. 1, 2004
 Venezuela                                 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 using
How To Get Tax Help                                       tax education and outreach for taxpayers with
                                                          limited English proficiency or who speak English
                                                                                                                         the withholding calculator online at
                                                                                                                         www.irs.gov/individuals.
You can get help with unresolved tax issues,              as a second language. Publication 4134, Low
                                                          Income Taxpayer Clinic List, provides informa-               • Determine if Form 6251 must be filed us-
order free publications and forms, ask tax ques-
                                                          tion on clinics in your area. It is available at www.          ing our Alternative Minimum Tax (AMT)
tions, and get information from the IRS in sev-
eral ways. By selecting the method that is best           irs.gov or at your local IRS office.                           Assistant.
for you, you will have quick and easy access to                                                                        • Sign up to receive local and national tax
tax help.                                                 Free tax services. To find out what services                   news by email.
                                                          are available, get Publication 910, IRS Guide to
Contacting your Taxpayer Advocate. The
                                                          Free Tax Services. It contains a list of free tax            • Get information on starting and operating
Taxpayer 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 and
ployees assist taxpayers who are experiencing
                                                          assistance programs and a list of TeleTax top-
economic harm, who are seeking help in resolv-
                                                          ics.                                                                Phone. Many services are available by
ing tax problems that have not been resolved
                                                               Accessible versions of IRS published prod-                     phone.
through normal channels, or who believe that an
IRS system or procedure is not working as it              ucts are available on request in a variety of
should.                                                   alternative formats for people with disabilities.            • Ordering forms, instructions, and publica-
     You can contact the TAS by calling the TAS                     Internet. You can access the IRS web-                tions. Call 1-800-829-3676 to order cur-
toll-free case intake line at 1-877-777-4778 or                     site at www.irs.gov 24 hours a day, 7                rent-year forms, instructions, and
TTY/TDD 1-800-829-4059 to see if you are eligi-                     days a week to:                                      publications, and prior-year forms and in-
ble for assistance. You can also call or write to                                                                        structions. You should receive your order
your local taxpayer advocate, whose phone                    • E-file your return. Find out about commer-
                                                                                                                         within 10 days.
number and address are listed in your local                    cial tax preparation and e-file services
telephone directory and in Publication 1546, The               available free to eligible taxpayers.                   • Asking tax questions. Call the IRS with
Taxpayer Advocate Service of the IRS - How To                • Check the status of your 2007 refund.                     your tax questions at 1-800-829-1040.
Get Help With Unresolved Tax Problems. You                     Click on Where’s My Refund. Wait at least               • Solving problems. You can get
can file Form 911, Request for Taxpayer Advo-                  6 weeks from the date you filed your re-                  face-to-face help solving tax problems
cate 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-
ployee to complete it on your behalf. For more                                                                           sistance Centers. An employee can ex-
                                                               cause you will need to know your social                   plain IRS letters, request adjustments to
information, go to www.irs.gov/advocate.                       security number, your filing status, and the              your account, or help you set up a pay-
   Taxpayer Advocacy Panel (TAP). The                          exact whole dollar amount of your refund.
                                                                                                                         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 find
sues, and makes suggestions for improving IRS                  tions.                                                    the number, go to www.irs.gov/localcon-
services and customer satisfaction. If you have
suggestions for improvements, contact the TAP,               • Order IRS products online.                                tacts or look in the phone book under
toll free at 1-888-912-1227 or go to                                                                                     United States Government, Internal Reve-
                                                             • Research your tax questions online.                       nue Service.
www.improveirs.org.
                                                             • Search publications online by topic or                  • TTY/TDD equipment. If you have access
   Low Income Taxpayer Clinics (LITCs).
                                                               keyword.                                                  to TTY/TDD equipment, call
LITCs are independent organizations that pro-
vide low income taxpayers with representation                • View Internal Revenue Bulletins (IRBs)                    1-800-829-4059 to ask tax questions or to
in federal tax controversies with the IRS for free             published in the last few years.                          order forms and publications.

Publication 901 (April 2008)                                                                                                                                   Page 51
  • 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
    various tax topics.                                  records and talk with an IRS representa-
                                                                                                            • Toll-free and email technical support.
                                                         tive face-to-face. No appointment is nec-          • The CD which is released twice during the
  • Refund information. To check the status of           essary, but if you prefer, you can call your         year.
    your 2007 refund, call 1-800-829-4477
                                                         local Center and leave a message re-                 – The first release will ship the beginning
    and press 1 for automated refund informa-
                                                         questing an appointment to resolve a tax             of January 2008.
    tion or call 1-800-829-1954. Be sure to
                                                         account issue. A representative will call            – The final release will ship the beginning
    wait at least 6 weeks from the date you
                                                         you back within 2 business days to sched-            of March 2008.
    filed your return (3 weeks if you filed elec-
                                                         ule an in-person appointment at your con-
    tronically). Have your 2007 tax return
                                                         venience. To find the number, go to www.           Purchase the CD/DVD from National Techni-
    available because you will need to know
                                                         irs.gov/localcontacts or look in the phone       cal Information Service (NTIS) at www.irs.gov/
    your social security number, your filing
                                                         book under United States Government, In-         cdorders for $35 (no handling fee) or call
    status, and the exact whole dollar amount
                                                         ternal Revenue Service.                          1-877-CDFORMS (1-877-233-6767) toll free to
    of your refund.
                                                                                                          buy the CD/DVD for $35 (plus a $5 handling
                                                              Mail. You can send your order for           fee). Price is subject to change.
  Evaluating the quality of our telephone
services. To ensure IRS representatives give                  forms, instructions, and publications to
                                                                                                                    CD for small businesses. Publication
accurate, courteous, and professional answers,                the address below. You should receive
                                                                                                                    3207, The Small Business Resource
we use several methods to evaluate the quality       a response within 10 days after your request is
                                                                                                                    Guide CD for 2007, is a must for every
of our telephone services. One method is for a       received.
                                                                                                          small business owner or any taxpayer about to
second IRS representative to listen in on or                                                              start a business. This year’s CD includes:
record random telephone calls. Another is to ask         National Distribution Center
some callers to complete a short survey at the           P.O. Box 8903                                      • Helpful information, such as how to pre-
end of the call.                                         Bloomington, IL 61702-8903                           pare a business plan, find financing for
                                                                                                              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
                                                                                                              manage a business.
  • Products. You can walk in to many post                    Internal Revenue Service
                                                                                                            • Tax law changes for 2007.
    offices, libraries, and IRS offices to pick up            1201 N. Mitsubishi Motorway
    certain forms, instructions, and publica-                 Bloomington, IL 61704-6613                    • Tax Map: an electronic research tool and
    tions. Some IRS offices, libraries, grocery                                                               finding aid.
    stores, copy centers, city and county gov-                CD/DVD for tax products. You can
                                                              order Publication 1796, IRS Tax Prod-         • Web links to various government agen-
    ernment offices, credit unions, and office
                                                              ucts CD/DVD, and obtain:                        cies, business associations, and IRS orga-
    supply stores have a collection of products
                                                                                                              nizations.
    available to print from a CD or photocopy          • Current-year forms, instructions, and pub-
    from reproducible proofs. Also, some IRS             lications.                                         • “Rate the Product” survey — your opportu-
    offices and libraries have the Internal Rev-                                                              nity to suggest changes for future editions.
    enue Code, regulations, Internal Revenue           • Prior-year forms, instructions, and publica-
                                                         tions.                                             • A site map of the CD to help you navigate
    Bulletins, and Cumulative Bulletins avail-
                                                                                                              the pages of the CD with ease.
    able for research purposes.                        • Bonus: Historical Tax Products DVD -
                                                                                                            • An interactive “Teens in Biz” module that
  • Services. You can walk in to your local              Ships with the final release.
                                                                                                              gives practical tips for teens about starting
    Taxpayer Assistance Center every busi-             • Tax Map: an electronic research tool and             their own business, creating a business
    ness day for personal, face-to-face tax              finding aid.                                         plan, and filing taxes.
    help. An employee can explain IRS letters,
    request adjustments to your tax account,           • Tax law frequently asked questions.
                                                                                                            An updated version of this CD is available
    or 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 copy
    need 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
    individual tax return, or you’re more com-         • Fill-in, print, and save features for most tax   gov/smallbiz.
    fortable talking with someone in person,             forms.




Page 52                                                                                                                      Publication 901 (April 2008)

								
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