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Publication 901

(Rev. September 2016) Contents


Cat. No. 46849F Reminders . . . . . . . . . . . . . . . . . . . 1
Department

U.S. Tax
of the Introduction . . . . . . . . . . . . . . . . . . 1
Treasury
Internal Application of Treaties ........... 2
Revenue
Service Treaties Tax Exemptions Provided by
Treaties . . . . . . . . . . . . . ..... 2
Personal Services Income . . . ..... 2
Professors, Teachers, and
Researchers . . . . . . . . . . . . 15
Students and Apprentices . . . . . . . 19
Wages and Pensions Paid by a
Foreign Government . . . . . . . . 27

How To Get Tax Help . . . . . . . . . . . 33

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

What’s New
Tax treaty tables. The treaty tables previously
contained in this publication have been updated
and moved to IRS.gov. You can locate the ta­
bles on IRS.gov by entering "Tax Treaty Table"
in the search box. Click on "Tax Treaty Tables."
You can also access the tables by going to
www.irs.gov/Individuals/International-
Taxpayers/Tax-Treaty-Tables.

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

Introduction
Get forms and other information faster and easier at: This publication will tell you whether a tax treaty
• IRS.gov (English) • IRS.gov/Korean (한국어) between the United States and a particular
• IRS.gov/Spanish (Español) • IRS.gov/Russian (Pусский) country offers a reduced rate of, or possibly a
• IRS.gov/Chinese (中文) • IRS.gov/Vietnamese (TiếngViệt)

Oct 12, 2016


complete exemption from, U.S. income tax for Useful Items Form 8833 does not apply to a reduced rate of
residents of that particular country. You may want to see: withholding tax on noneffectively connected in­
come, such as dividends, interest, rents or roy­
You should use this publication only for
Publication alties, or to a reduced rate of tax on pay re­
! quick reference. It is not a complete
ceived for services performed as an employee,
CAUTION guide to all provisions of every income
519 U.S. Tax Guide for Aliens including pensions, annuities, and social secur­
tax treaty.
ity. For more information, see Publication 519
597 Information on the United States–
For more detailed information on treaty ben­ and the Form 8833 instructions.
Canada Income Tax Treaty
efits, you should consult the text of the applica­ If you fail to file Form 8833, you may have to
ble treaty. The treaties are available at pay a $1,000 penalty. Corporations are subject
Form (and Instructions)
www.irs.gov/Individuals/International- to a $10,000 penalty for each failure.
Taxpayers/Tax-Treaty-Tables. 8833 Treaty­Based Return Position
Disclosure Under Section 6114 or
Comments and suggestions. We welcome
your comments about this publication and your
7701(b) Tax Exemptions
suggestions for future editions. See How To Get Tax Help near the end of this
publication for information about getting these
Provided by Treaties
You can send us comments from www/
irs.gov/formspubs. Click on “More information” publications and forms.
This publication contains discussions of the ex­
and then on “Give us feedback”. emptions from tax and certain other effects of
Or, you can write to:
Application of Treaties the tax treaties on the following types of in­
come.
Internal Revenue Service Pay for certain personal services per­
Business Forms and Publications Branch formed in the United States.
The United States has income tax treaties
SE:W:CAR:MP:T:B Pay of a professor, teacher, or researcher
with a number of foreign countries. Under these
1111 Constitution Ave. NW, IR­6526 who teaches or performs research in the
treaties, residents (not necessarily citizens) of
Washington, DC 20224 United States for a limited time.
foreign countries are taxed at a reduced rate, or
Amounts received for maintenance and
are exempt from U.S. income taxes on certain
We respond to many letters by telephone. studies by a foreign student or apprentice
items of income they receive from sources
Therefore, it would be helpful if you would in­ who is here for study or experience.
within the United States. These reduced rates
clude your daytime phone number, including Wages, salaries, and pensions paid by a
and exemptions vary among countries and spe­
the area code, in your correspondence. foreign government.
cific items of income.
Although we cannot respond individually to
each comment received, we do appreciate your If there is no treaty between your country
and the United States, you must pay tax on the
Personal Services Income
feedback and will consider your comments as
we revise our tax products. income in the same way and at the same rates Pay for certain personal services performed in
shown in the instructions for Form 1040NR. the United States is exempt from U.S. income
Ordering forms and publications. Visit Also see Publication 519. tax if you are a resident of one of the countries
www.irs.gov/formspubs to download forms and
Many of the individual states of the United discussed below, if you are in the United States
publications. Otherwise, you can go to
States tax the income of their residents. There­ for a limited number of days, and if you meet
www.irs.gov/orderforms to order current and
fore, you should consult the tax authorities of certain other conditions. For this purpose, the
prior year forms and instructions. Your oder
the state in which you live to find out if that state word “day” means a day during any part of
should arrive within 10 business days.
taxes the income of individuals and, if so, which you are physically present in the United
whether the tax applies to any of your income. States.
Internal Revenue Service
1201 N. Mitsubishi Motorway
Tax treaties reduce the U.S. taxes of resi­ Terms defined. Several terms appear in many
Bloomington, IL 61705­6613
dents of foreign countries. With certain excep­ of the discussions that follow. The exact mean­
tions, they do not reduce the U.S. taxes of U.S. ings of the terms are determined by the particu­
Tax questions. If you have a tax question citizens or residents. U.S. citizens and residents lar tax treaty under discussion; thus, the mean­
not answered by this publication, check are subject to U.S. income tax on their world­ ings vary among treaties. The definitions that
IRS.gov and How To Get Tax Help at the end of wide income. follow are, therefore, general definitions that
this publication. may not give the exact meaning intended by a
Treaty provisions generally are reciprocal particular treaty.
Obtaining copies of treaties. You can get (apply to both treaty countries); therefore, a
complete information about treaty provisions The terms fixed base and permanent estab­
U.S. citizen or resident who receives income
from the taxing authority in the country from lishment generally mean a fixed place of busi­
from a treaty country may refer to the tables in
which you receive income or from the treaty it­ ness, such as a place of management, a
this publication to see if a tax treaty might affect
self. branch, an office, a factory, a warehouse, or a
the tax to be paid to that foreign country. For­
You can obtain the text of most of the trea­ mining site, through which an enterprise carries
eign taxing authorities sometimes require certifi­
ties at www.irs.gov/businesses/international. on its business.
cation from the U.S. Government that an appli­
You can also obtain the text of most of the trea­ The term borne by generally means having
cant filed an income tax return as a U.S. citizen
ties at the following address: ultimate financial accounting responsibility for,
or resident, as part of the proof of entitlement to
or providing the monetary resources for, an ex­
the treaty benefits. See Form 8802, Application
Department of the Treasury penditure or payment, even if another entity in
for United States Residency Certification, to re­
Office of Public Correspondence another location actually made the expenditure
quest a certification.
1500 Pennsylvania Ave. NW — Rm. 3419 or payment.
Washington, D.C. 20220 Disclosure of a treaty-based position that
reduces your tax. If you take the position that Australia
any U.S. tax is overruled or otherwise reduced
by a U.S. treaty (a treaty­based position), you Income that residents of Australia receive for
generally must disclose that position on Form performing personal services as independent
8833 and attach it to your return. If you are not contractors or self­employed individuals (inde­
required to file a return because of your pendent personal services) in the United States
treaty­based position, you must file a return
anyway to report your position. The filing of

Page 2 Publication 901 (September 2016)


during the tax year is exempt from U.S. income Income received by a resident of Austria for during the tax year is exempt from U.S. income
tax if the residents: services performed as an employee and mem­ tax if the residents:
Are in the United States for no more than ber of the regular complement of a ship or air­ Are in the United States for no more than
183 days during the tax year, and craft operated in international traffic is exempt 89 days during the tax year,
Do not have a fixed base regularly availa­ from U.S. income tax. Earn net income for independent services
ble to them in the United States for the pur­ provided to U.S. residents that is not more
pose of performing the services. Bangladesh than $5,000 (there is no dollar limit if the
contractors are not U.S. residents), and
If they have a fixed base available in the United
Income that residents of Bangladesh receive for Do not have a regular base available in the
States, they are taxed on the income attributa­
performing personal services as independent United States for performing the services.
ble to the fixed base.
contractors or self­employed individuals (inde­ If they have a regular base available in the Uni­
Pay that residents of Australia receive for la­ pendent personal services) in the United States ted States but otherwise meet the conditions for
bor or personal services performed in the Uni­ during the tax year is exempt from U.S. income exemption, they are taxed only on the income
ted States as employees (dependent personal tax if the residents: attributable to the regular base.
services), including services as a director of a Are in the United States for no more than
company, is exempt from U.S. income tax if: 183 days in any 12­month period begin­ Income that residents of Barbados receive
The residents are in the United States for ning or ending in the tax year, or for personal services performed in the United
no more than 183 days during the tax year, Do not have a fixed base regularly availa­ States as employees (dependent personal
The pay is paid by, or on behalf of, an em­ ble to them in the United States for the pur­ services) is exempt from U.S. tax if the resi­
ployer or company that is not a resident of pose of performing the services. dents meet four requirements.
the United States, and If they have a fixed base available in the United They are in the United States for no more
The pay is not deductible in determining States, they are taxed on the income attributa­ than 183 days during the calendar year.
the taxable income of the trade or business ble to the fixed base. The income earned in the calendar year in
of the employer (or company) in the United the United States is not more than $5,000.
States. Income that residents of Bangladesh re­ Their income is paid by or for an employer
ceive for services performed in the United who is not a U.S. resident.
These exemptions do not apply to public en­ States as employees (dependent personal The income is not borne by a permanent
tertainers (such as theater, motion picture, ra­ services) is exempt from U.S. income tax if the establishment or regular base of the em­
dio, or television entertainers, musicians, and residents meet the following requirements. ployer in the United States.
athletes) from Australia who earn more than They are in the United States for no more
$10,000 in gross receipts, including reimbursed than 183 days in any 12­month period be­ Income of a Barbadian resident from em­
expenses, from their entertainment activities in ginning or ending in the tax year. ployment as a member of the regular comple­
the United States during the tax year. Their income is paid by, or on behalf of, an ment of a ship or aircraft operated in interna­
employer who is not a U.S. resident. tional traffic is exempt from U.S. tax.
Austria Their income is not borne by a permanent
establishment or a fixed base that the em­ These exemptions do not apply to Barba­
Income that residents of Austria receive for per­ ployer has in the United States. dian resident public entertainers (such as thea­
sonal services as independent contractors or ter, motion picture, radio, or television artists,
self­employed individuals (independent per­ These exemptions do not apply to pubic en­ musicians, or athletes) who receive gross re­
sonal services) in the United States is exempt tertainers (such as theater, motion picture, ra­ ceipts of more than $250 per day or $4,000 in
from U.S. income tax if they do not have a fixed dio, or television entertainers, musicians, and the tax year, not including reimbursed expen­
base regularly available to them in the United athletes) from Bangladesh who earn more than ses, from their entertainment activities in the
States for performing the services. If they have $10,000 in gross receipts, including reimbursed United States. However, the exemptions do ap­
a fixed base available in the United States, they expenses, from their entertainment activities in ply regardless of these limits on gross receipts if
are taxed on the income attributable to the fixed the United States during the tax year. Regard­ the entertainer's visit to the United States is
base. less of these limits, income of Bangladesh en­ substantially supported by Barbadian public
tertainers is exempt from U.S. income tax if their funds or if the entertainer's services are provi­
Income that residents of Austria receive for visit to the United States is wholly or mainly ded to a nonprofit organization.
services performed in the United States as em­ supported by public funds of Bangladesh, its
ployees (dependent personal services) is ex­ political subdivisions, or local authorities.
empt from U.S. income tax if the residents meet
Belgium
the following requirements. Income received from employment as a Income that residents of Belgium receive for
They are in the United States for no more member of the regular complement of a ship or personal services as independent contractors
than 183 days in any 12­month period be­ an aircraft operated by a Bangladesh enterprise or self­employed individuals are subject to the
ginning or ending in the tax year. in international traffic is exempt from U.S. tax. If provisions of Article 7 (Business Profits) of the
Their income is paid by, or on behalf of, an the ship or aircraft is operated by a U.S. enter­ treaty. Under that provision, business profits are
employer who is not a U.S. resident. prise, the income is subject to U.S. tax. exempt from U.S. income tax unless the individ­
Their income is not borne by a permanent
ual has a permanent establishment in the Uni­
establishment or a fixed base that the em­ If the resident of Bangladesh is a share­ ted States. If they have a permanent establish­
ployer has in the United States. holder in a U.S. corporation, these exemptions ment in the United States, they are taxed on the
do not apply to directors' fees received as a profit attributable to the permanent establish­
These exemptions do not apply to public en­ member of the board of directors of the U.S. ment.
tertainers (such as theater, motion picture, ra­ corporation. The amount received by the share­
dio, or television entertainers, musicians, and holder that is more than the amount paid to a di­
athletes) from Austria who earn more than Income that residents of Belgium receive for
rector that is not a shareholder is subject to U.S. services performed in the United States as em­
$20,000 in gross receipts, including reimbursed tax at the rate of 15%.
expenses, from their entertainment activities in ployees (dependent personal services) is ex­
the United States during the tax year. empt from U.S. income tax if the residents meet
Barbados the following requirements.
They are in the United States for no more
Income that residents of Barbados receive for than 183 days in any 12­month period be­
performing personal services as independent ginning or ending in the tax year.
contractors or self­employed individuals (inde­ Their income is paid by, or on behalf of, an
pendent personal services) in the United States employer who is not a U.S. resident.

Publication 901 (September 2016) Page 3


Their income is not borne by a permanent aircraft operated in international traffic is employees (dependent personal services) in
establishment that the employer has in the exempt from U.S. income tax. the United States is exempt from U.S. tax if:
United States. The residents are present in the United
Canada States for no more than 183 days in the
The exemption does not apply to directors' calendar year,
fees and similar payments received by a resi­ Income that residents of Canada receive for The pay is paid by or for an employer who
dent of Belgium for services performed in the personal services as independent contractors is not a U.S. resident, and
United States as a member of the board of di­ or self­employed individuals is subject to the The pay is not borne by a permanent es­
rectors of a company that is a resident of the provisions of Article VII (Business Profits) of the tablishment or fixed base that the em­
United States. treaty. Under that provision, business profits are ployer has in the United States.
exempt from U.S. income tax unless the individ­
Public entertainers (such as theater, motion ual has a permanent establishment in the Uni­ These exemptions do not apply to directors'
picture, radio, or television artists, musicians, or ted States. If they have a permanent establish­ fees for service on the board of directors of a
athletes) from Belgium who earn more than ment in the United States, they are taxed on the U.S. corporation.
$20,000 in gross receipts, including reimbursed profit attributable to the permanent establish­
expenses, from their entertainment activities in ment. Under Article V (Permanent Establish­ These exemptions generally do not apply to
the United States during the tax year are sub­ ment), you may be considered to provide serv­ income received as a public entertainer (such
ject to U.S. tax. ices through a permanent establishment in the as a theater, motion picture, radio, or television
United States even if you do not have a fixed artist, musician, or athlete). However, income of
Income received by a resident of Belgium place of business. athletes or public entertainers from China par­
for services performed as an employee and ticipating in a cultural exchange program
member of the regular complement of a ship or agreed upon by the U.S. and Chinese govern­
Income that residents of Canada receive for
aircraft operated in international traffic is ex­ ments is exempt from U.S. tax.
personal services performed as employees (de­
empt from U.S. income tax. pendent personal services) in the United States
is exempt from U.S. tax if it is not more than Commonwealth of
Bulgaria $10,000 for the year. If the income is more than Independent States
$10,000 for the year, it is exempt only if:
Income that residents of Bulgaria receive for The residents are present in the United Income that residents of a C.I.S. member re­
personal services as independent contractors States for no more than 183 days in any ceive for performing personal services in the
or self­employed individuals is subject to the 12­month period beginning or ending in the United States is exempt from U.S. income tax if
provisions of Article 7 (Business Profits) of the tax year, and those residents are in the United States for no
treaty. Under that provision, business profits are The income is not paid by, or on behalf of, more than 183 days during the tax year.
exempt from U.S. income tax unless the individ­ a U.S. resident, and is not borne by a per­
ual has a permanent establishment in the Uni­ manent establishment in the United States. Pay received by an employee who is a
ted States. If they have a permanent establish­ member of the regular complement of a ship or
ment in the United States, they are taxed on the Public entertainers (such as theater, motion aircraft operated in international traffic by a
profit attributable to the permanent establish­ picture, radio, or television artists, musicians, or C.I.S. member or a resident of a C.I.S. member
ment. Under Article 5 (Permanent Establish­ athletes) from Canada who derive more than is exempt from U.S. tax.
ment), you may be considered to provide serv­ $15,000 in gross receipts, including reimbursed
ices through a permanent establishment in the expenses, from their entertainment activities in Cyprus
United States even if you do not have a fixed the United States during the calendar year are
place of business. subject to U.S. tax. However, this article does Income that residents of Cyprus receive for per­
not apply to athletes participating in team sports forming personal services as independent con­
Income that residents of Bulgaria receive for in leagues with regularly scheduled games in tractors or self­employed individuals (independ­
services performed in the United States as em­ both Canada and the United States. ent personal services) in the United States
ployees (dependent personal services) is ex­ during the tax year is exempt from U.S. income
empt from U.S. income tax if the residents meet Pay received by a resident of Canada for tax if the residents:
the following requirements. employment regularly done in more than one Are present in the United States for less
They are in the United States for no more country on a ship, aircraft, motor vehicle, or than 183 days in the tax year, and
than 183 days in any 12­month period be­ train operated by a Canadian resident is ex­ Do not have a fixed base regularly availa­
ginning or ending in the tax year. empt from U.S. tax. ble to them in the United States for per­
Their income is paid by, or on behalf of, an forming the services.
employer who is not a U.S. resident. If they have a fixed base available in the United
Their income is not borne by a permanent China, People's Republic of
States, they are taxable on the income attributa­
establishment that the employer has in the ble to the fixed base.
Income that residents of the People's Republic
United States.
of China receive for personal services as inde­
pendent contractors or self­employed individu­ Pay received by residents of Cyprus from
The exemption does not apply to directors' services performed as employees (dependent
als (independent personal services) that they
fees and similar payments received by a resi­ personal services), including services as an offi­
perform during the tax year in the United States
dent of Bulgaria as a member of the board of di­ cer of a corporation, is exempt from U.S. in­
is exempt from U.S. income tax if the residents:
rectors of a U.S. company. come tax if:
Are present in the United States for no
more than 183 days in the calendar year, The residents are in the United States for
Public entertainers (such as theater, motion and less than 183 days during the tax year,
picture, radio, or television artists, musicians, or Do not have a fixed base regularly availa­ The pay is paid by or for an employer who
athletes) from Bulgaria who earn more than ble in the United States for performing the is not a U.S. resident, and
$15,000 in gross receipts, including reimbursed services. The pay is not borne by a permanent es­
expenses, from their entertainment activities in tablishment, fixed base, or trade or busi­
the United States during the tax year are sub­ If they have a fixed base available in the United ness that the employer has in the United
ject to U.S. tax. States, they are taxable on the income attributa­ States.
ble to the fixed base.
Income received by a resident of Bulgaria Pay received by a Cyprus resident for per­
for services performed as an employee and Pay received by residents of the People's forming personal services as an employee and
member of the regular complement of a ship or Republic of China for services performed as member of the regular complement of a ship or

Page 4 Publication 901 (September 2016)


aircraft operated in international traffic by a resi­ Income from employment as a member of They are employees of a resident of, or a
dent of Cyprus is exempt from U.S. tax. the regular complement of a ship or aircraft op­ permanent establishment in, Egypt.
erated by a Czech enterprise in international Their income is not borne by a permanent
These exemptions do not apply to Cyprus traffic is exempt from U.S. income tax. If the establishment that the employer has in the
resident public entertainers (theater, motion pic­ ship or aircraft is operated by a U.S. enterprise, United States.
ture, radio, or television artists, musicians, or the income is subject to U.S. tax. Their income is subject to Egyptian tax.
athletes) who receive gross receipts of more
than $500 per day or $5,000 for the tax year, Denmark This exemption does not apply to pay re­
not including reimbursed expenses, from their ceived by a resident of Egypt who is an em­
entertainment activities in the United States. Income that residents of Denmark receive for ployee and member of the regular complement
personal services as independent contractors of a ship or an aircraft operated in international
or self­employed individuals (independent per­ traffic by a resident of the United States.
Directors' fees received by residents of Cy­
prus for service on the board of directors of a sonal services) in the United States is exempt
U.S. corporation are exempt from U.S. income from U.S. income tax if they do not have a fixed These exemptions do not apply to Egyptian
tax to the extent of a reasonable fixed amount base regularly available to them in the United resident public entertainers (theater, motion pic­
payable to all directors for each day of attend­ States for performing the services. If they have ture, radio, or television artists, musicians, or
ance at directors' meetings held in the United a fixed base available in the United States, they athletes), who earn income for services as pub­
States. are taxed on the income attributable to the fixed lic entertainers if the gross amount of the in­
base. come is more than $400 for each day they are
in the United States performing the services.
Czech Republic Income that residents of Denmark receive
Income that residents of the Czech Republic re­ for services performed in the United States as Estonia
ceive for performing personal services as inde­ employees (dependent personal services) is
pendent contractors or self­employed individu­ exempt from U.S. income tax if the residents Income that residents of Estonia receive for per­
als (independent personal services) in the meet the following requirements. forming personal services as independent con­
United States is exempt from U.S. income tax if They are in the United States for no more tractors or self­employed individuals (independ­
the residents: than 183 days in any 12­month period be­ ent personal services) in the United States is
Are present in the United States for no ginning or ending in the tax year. exempt from U.S. income tax if the residents:
more than 183 days in any 12­month pe­ Their income is paid by, or on behalf of, an Are in the United States for no more than
riod, and employer who is not a U.S. resident. 183 days in any 12­month period begin­
Do not have a fixed base regularly availa­ Their income is not borne by a permanent ning or ending in the tax year, and
ble to them in the United States for per­ establishment or a fixed base that the em­ Do not have a fixed base regularly availa­
forming the services. ployer has in the United States. ble to them in the United States for per­
forming the services.
If they have a fixed base available, they are These exemptions do not apply to directors'
taxed only on income attributable to the fixed If they have a fixed base available, they are
fees and similar payments received by a resi­ taxed on the income attributable to the fixed
base. dent of Denmark as a member of the board of base.
directors of a company that is a resident of the
Income that residents of the Czech Republic United States. Income that residents of Estonia receive for
receive for employment in the United States services performed in the United States as em­
(dependent personal services) is exempt from These exemptions do not apply to public en­ ployees (dependent personal services) is ex­
U.S. income tax if the following three require­ tertainers (such as theater, motion picture, ra­ empt from U.S. income tax if the following re­
ments are met. dio, or television artists, musicians, and ath­ quirements are met.
The resident is present in the United letes) from Denmark who earn more than The resident is in the United States for no
States for no more than 183 days in any $20,000 in gross receipts, including reimbursed more than 183 days in any 12­month pe­
12­month period. expenses, from their entertainment activities in riod beginning or ending in the tax year.
The income is paid by, or on behalf of, an the United States during the tax year. The income is paid by, or on behalf of, an
employer who is not a U.S. resident. employer who is not a U.S. resident.
The income is not borne by a permanent Income received by a resident of Denmark The income is not borne by a permanent
establishment or a fixed base that the em­ for services performed as an employee and establishment or a fixed base that the em­
ployer has in the United States. member of the regular complement of a ship or ployer has in the United States.
aircraft operated in international traffic is ex­
These exemptions do not apply to income empt from U.S. income tax. These exemptions do not apply to directors'
residents of the Czech Republic receive as pub­ fees and similar payments received by a resi­
lic entertainers (such as theater, motion picture, Egypt dent of Estonia as a member of the board of di­
radio, or television artists, or musicians) or rectors or similar body of a company that is a
sportsmen if their gross receipts, including re­ Income that residents of Egypt receive for per­ U.S. resident.
imbursed expenses, are more than $20,000 forming personal services as independent con­
during the tax year. Regardless of these limits, tractors or as self­employed individuals (inde­ Pay received for employment as a member
income of Czech entertainers and sportsmen is pendent personal services) in the United States of the regular complement of a ship or an air­
exempt from U.S. income tax if their visit to the during the tax year is exempt from U.S. income craft operated in international traffic by a United
United States is substantially supported by pub­ tax if they are in the United States for no more States enterprise is subject to U.S. tax.
lic funds of the Czech Republic, its political sub­ than 89 days during the tax year.
divisions, or local authorities, or the visit is These exemptions do not apply to income
made pursuant to a specific arrangement be­ Income that residents of Egypt receive for residents of Estonia receive as public entertain­
tween the United States and the Czech Repub­ labor or personal services performed in the Uni­ ers (such as theater, motion picture, radio, or
lic. ted States as employees (dependent personal television artists, or musicians) or sportsmen if
services), including income for services per­ their gross receipts, including reimbursed ex­
These exemptions do not apply to directors' formed by an officer of a corporation or com­ penses, are more than $20,000 for their per­
fees and similar payments received by a resi­ pany, is exempt from U.S. income tax if the resi­ sonal activities in the United States during the
dent of the Czech Republic as a member of the dents meet four requirements. tax year. Regardless of these limits, income of
board of directors of a company that is a resi­ They are in the United States for no more Estonian entertainers or athletes is exempt from
dent of the United States. than 89 days during the tax year. U.S. income tax if their visit to the United States

Publication 901 (September 2016) Page 5


is wholly or mainly supported by public funds of Income for services performed by a resident United States is substantially supported by pub­
Estonia, its political subdivisions, or local au­ of France as an employee and member of the lic funds of Germany, its political subdivisions,
thorities. regular complement of a ship or an aircraft op­ or local authorities.
erated in international traffic is exempt from tax
Finland in the United States. Greece
Income that residents of Finland receive for per­ These exemptions do not apply to public en­ Income that residents of Greece receive for la­
forming personal services as independent con­ tertainers (such as theater, motion picture, ra­ bor or personal services (including practicing
tractors or self­employed individuals (independ­ dio, or television artists, or musicians), or liberal and artistic professions) is exempt from
ent personal services) in the United States is sportsmen from France who earn more than U.S. income tax if they are in the United States
exempt from U.S. income tax if they do not $10,000 in gross receipts, including reimbursed for no more than 183 days during the tax year
have a fixed base regularly available to them in expenses, from their entertainment activities in and the pay is not more than $10,000. The pay,
the United States for performing the services. If the United States during the tax year. Regard­ regardless of amount, is exempt from U.S. in­
they have a fixed base available in the United less of these limits, income of French entertain­ come tax if it is for labor or personal services
States, they are taxed on the income attributa­ ers or sportsmen is exempt from U.S. tax if their performed as employees of, or under contract
ble to the fixed base. visit is principally supported by public funds of with, a resident of Greece or a Greek corpora­
France. tion or other entity of Greece, and if the resi­
Income that residents of Finland receive for dents are in the United States for no more than
labor or personal services performed in the Uni­ These exemptions do not apply to directors' 183 days during the tax year.
ted States as employees (dependent personal fees and similar payments received by a resi­
services) is exempt from U.S. income tax if the dent of France as a member of the board of di­
rectors of a company that is a resident of the Hungary
residents meet three requirements.
They are in the United States for no more United States.
Income that residents of Hungary receive for
than 183 days during any 12­month period. performing personal services as independent
Their income is paid by, or on behalf of, an Germany contractors or self­employed individuals (inde­
employer who is not a resident of the Uni­ pendent personal services) in the United States
ted States. Income that residents of Germany receive for during the tax year is exempt from U.S. tax if the
Their income is not borne by a permanent personal services as independent contractors residents:
establishment, fixed base, or trade or busi­ or self­employed individuals are subject to the Are in the United States for no more than
ness that the employer has in the United provisions of Article 7 (Business Profits) of the 183 days during the tax year, and
States. treaty. Under that provision, business profits are Do not have a fixed base regularly availa­
exempt from U.S. income tax unless the individ­ ble in the United States.
The exemption does not apply to pay re­ ual has a permanent establishment in the Uni­
ceived by a resident of Finland who is an em­ ted States. If they have a permanent establish­ If they have a fixed base available in the United
ployee and member of the regular complement ment in the United States, they are taxed on the States, they are taxed on the income attributa­
of a ship or aircraft operated in international traf­ profit attributable to the permanent establish­ ble to the fixed base.
fic by a resident of the United States. ment.
Income that residents of Hungary receive for
These exemptions do not apply to income Income that residents of Germany receive labor or personal services performed in the Uni­
residents of Finland receive as public entertain­ for labor or personal services performed in the ted States as employees (dependent personal
ers or sportsmen if the gross income, including United States as employees (dependent per­ services) is exempt from U.S. income tax if the
reimbursed expenses, is more than $20,000 for sonal services) is exempt from U.S. tax if the residents meet three requirements.
their personal activities in the United States dur­ residents meet three requirements. They are in the United States for no more
ing the calendar year. They are in the United States for no more than 183 days during the tax year.
than 183 days during the calendar year. Their income is paid by or on behalf of an
The income is paid by, or on behalf of, an employer who is not a resident of the Uni­
France ted States.
employer who is not a resident of the Uni­
ted States. Their income is not borne by a permanent
Income that residents of France receive for per­
The income is not borne by a permanent establishment or a fixed base that the em­
forming personal services as independent con­
establishment that the employer has in the ployer has in the United States.
tractors or self­employed individuals (independ­
ent personal services) in the United States is United States.
Pay received by an employee who is a
exempt from U.S. income tax if they do not
Pay received by a resident of Germany for member of the regular complement of a ship or
have a fixed base regularly available to them in
services performed as an employee and mem­ aircraft operated by a Hungarian enterprise in
the United States for performing the services. If
ber of the regular complement of a ship or air­ international traffic is exempt from U.S. tax. If
they have a fixed base available in the United
craft operated in international traffic is exempt the ship or aircraft is operated by a U.S. enter­
States, they are taxed on the income attributa­
from U.S. tax. prise, the pay is subject to U.S. tax.
ble to the fixed base.

Income that residents of France receive for The exemption does not apply to directors' Iceland
labor or personal services performed in the Uni­ fees and other similar payments received by a
ted States as employees (dependent personal resident of Germany for services performed in Income that residents of Iceland receive for per­
services) is exempt from U.S. income tax if the the United States as a member of the board of sonal services as independent contractors or
residents meet three requirements. directors of a company resident in the United self­employed individuals is subject to the provi­
They are in the United States for no more States. sions of Article 7 (Business Profits) of the treaty.
than 183 days in any 12­month period. Under that provision, business profits are ex­
Their income is paid by, or on behalf of, an Income residents of Germany receive as empt from U.S. income tax unless the individual
employer who is not a resident of the Uni­ public entertainers (such as theater, motion pic­ has a permanent establishment in the United
ted States. ture, radio, or television artists, or musicians) or States. If they have a permanent establishment
Their income is not borne by a permanent athletes is subject to U.S. tax if their gross re­ in the United States, they are taxed on the profit
establishment or a fixed base that the em­ ceipts, including reimbursed expenses, from attributable to the permanent establishment.
ployer has in the United States. their entertainment activities in the United
States are more than $20,000 during the calen­ Income that residents of Iceland receive for
dar year. Income of German entertainers or ath­ services performed in the United States as em­
letes is exempt from U.S. tax if their visit to the ployees (dependent personal services) is

Page 6 Publication 901 (September 2016)


exempt from U.S. income tax if the residents These exemptions do not apply to income self­employed individuals (independent per­
meet the following requirements. residents of India receive as public entertainers sonal services) in the United States is exempt
They are in the United States for no more (such as theater, motion picture, radio, or televi­ from U.S. income tax if they do not have a fixed
than 183 days in any 12­month period be­ sion artists, or musicians) or athletes if their net base regularly available to them in the United
ginning or ending in the tax year. income is more than $1,500 during the tax year States for performing the services. If they have
Their income is paid by, or on behalf of, an for their entertainment activities in the United a fixed base available in the United States, they
employer who is not a U.S. resident. States. Regardless of this limit, the income of are taxed on the income attributable to the fixed
Their income is not borne by a permanent Indian entertainers and athletes is exempt from base.
establishment that the employer has in the U.S. tax if their visit to the United States is
United States. wholly or substantially supported from the pub­ Income that residents of Ireland receive for
lic funds of the Indian Government, its political services performed in the United States as em­
The exemption does not apply to directors' subdivisions, or local authorities. ployees (dependent personal services) is ex­
fees and similar payments received by a resi­ empt from U.S. income tax if the residents meet
dent of Iceland as a member of the board of di­ Indonesia the following requirements.
rectors of a U.S. company. They are in the United States for no more
Income that residents of Indonesia receive for than 183 days in any 12­month period be­
Public entertainers (such as theater, motion performing personal services as individual con­ ginning or ending in the tax year.
picture, radio, or television artists, musicians, or tractors or self­employed individuals (independ­ Their income is paid by, or on behalf of, an
athletes) from Iceland who earn more than ent personal services) in the United States dur­ employer who is not a U.S. resident.
$20,000 in gross receipts, including reimbursed ing the tax year is exempt from U.S. income tax Their income is not borne by a permanent
expenses, from their entertainment activities in if the residents: establishment or a fixed base that the em­
the United States during the tax year are sub­ Are present in the United States for no ployer has in the United States.
ject to U.S. tax. more than 119 days during any consecu­
tive 12­month period, and These exemptions do not apply to directors'
Income received by a resident of Iceland for Do not have a fixed base regularly availa­ fees and similar payments received by a resi­
services performed as an employee and mem­ ble to them in the United States for per­ dent of Ireland as a member of the board of di­
ber of the regular complement of a ship or air­ forming the services. rectors of a company that is a resident of the
craft operated in international traffic is exempt United States. However, amounts received for
from U.S. income tax. attending meetings in Ireland are not subject to
If they have a fixed base available, they are
U.S. income tax.
taxed only on the income attributable to the
India fixed base.
Income received by a resident of Ireland for
services performed as an employee and mem­
Income that residents of India receive for per­ Income that residents of Indonesia receive ber of the regular complement of a ship or air­
forming personal services in the United States for personal services performed in the United craft operated in international traffic is exempt
during the tax year as independent contractors States as employees (dependent personal from U.S. income tax.
or self­employed individuals (independent per­ services) is exempt from U.S. income tax if the
sonal services) is exempt from U.S. income tax residents meet three requirements. These exemptions do not apply to public en­
if the residents: They are present in the United States no tertainers (such as theater, motion picture, ra­
Are present in the United States for no more than 119 days during any consecu­ dio, or television entertainers, musicians, and
more than 89 days during the tax year, and tive 12­month period. athletes) from Ireland who earn more than
Do not have a fixed base regularly availa­ The income is paid by, or on behalf of, an $20,000 in gross receipts, including reimbursed
ble to them in the United States for per­ employer who is not a resident of the Uni­ expenses, from their entertainment activities in
forming the services. ted States. the United States during the tax year.
The income is not borne or reimbursed by
If they have a fixed base available, they are a permanent establishment the employer
taxed only on income attributable to the fixed has in the United States. Israel
base. Income that residents of Israel receive for per­
Pay received by an individual for services
forming personal services as independent con­
Income that residents of India receive for performed as an employee aboard a ship or air­
tractors or as self­employed individuals (inde­
personal services performed in the United craft operated by an Indonesian resident in in­
pendent personal services) in the United States
States as employees (dependent personal ternational traffic is exempt from U.S. tax if the
during the tax year is exempt from U.S. income
services) is exempt from U.S. income tax if the individual is a member of the regular comple­
tax if they are in the United States for no more
residents meet three requirements. ment of the ship or aircraft.
than 182 days during the tax year.
They are present in the United States for
no more than 183 days during the tax year. These exemptions do not apply to income Income that residents of Israel receive for la­
The income is paid by, or on behalf of, an residents of Indonesia receive as public enter­ bor or personal services performed in the Uni­
employer who is not a resident of the Uni­ tainers (such as theater, motion picture, radio, ted States as employees (dependent personal
ted States. or television artists, or musicians) or athletes if services), including income for services per­
The income is not borne by a permanent their gross receipts, including reimbursed ex­ formed by an officer of a corporation or com­
establishment, fixed base, or trade or busi­ penses, are more than $2,000 during any con­ pany, is exempt from U.S. income tax if the resi­
ness the employer has in the United secutive 12­month period. Regardless of these dents meet four requirements.
States. limits, income of Indonesian entertainers and They are in the United States for no more
athletes is exempt from U.S. tax if their visit to than 182 days during the tax year.
The exemption does not apply to pay re­ the United States is substantially supported or They are employees of a resident of, or a
ceived by a resident of India for services per­ sponsored by the Indonesian Government and permanent establishment in, Israel.
formed as an employee aboard a ship or aircraft the Indonesian competent authority certifies Their income is not borne by a permanent
operated in international traffic by a U.S. enter­ that the entertainers or athletes qualify for this establishment that the employer has in the
prise. exemption. United States.
Their income is subject to Israeli tax.
These exemptions do not apply to directors' Ireland
fees and similar payments received by an In­ The exemption does not apply to pay re­
dian resident as a member of the board of di­ Income that residents of Ireland receive for per­ ceived by an employee for labor or personal
rectors of a company that is a U.S. resident. sonal services as independent contractors or services performed as a member of the regular

Publication 901 (September 2016) Page 7


complement of a ship or an aircraft operated in Earn net income for those services that is Their income is not borne by a permanent
international traffic by a U.S. resident. not more than $5,000 during the tax year if establishment that the employer has in the
the income is from a U.S. contractor. United States.
These exemptions do not apply to income If they have a fixed base available in the United
that residents of Israel receive as public enter­ States, they are taxed only on the income that is The exemption does not apply to directors'
tainers (such as theater, motion picture, radio, attributable to the fixed base. There is no dollar fees and similar payments received by a resi­
or television artists, musicians, or athletes), if limit for condition (3) if the contractor is from a dent of Japan for services performed as a mem­
the gross amount of the income is more than country other than the United States. ber of the board of directors of a company that
$400 for each day they are in the United States is a resident of the United States.
performing the services. Income that residents of Jamaica receive for
personal services performed in the United The exemption does not apply to a resident
Italy States as employees (dependent personal of Japan who performs services as an em­
services) is exempt from U.S. income tax if the ployee aboard a ship or an aircraft operated in
Income that residents of Italy receive for per­ residents meet four requirements. international traffic by a U.S. resident.
sonal services as independent contractors or They are in the United States for no more
self­employed individuals (independent per­ than 183 days during the tax year. Public entertainers (such as theater, motion
sonal services) in the United States is exempt Their income is paid by or for an employer picture, radio, or television artists, musicians, or
from U.S. income tax if they do not have a fixed who is not a resident of the United States. athletes) from Japan who earn more than
base regularly available to them in the United Their income is not borne by a permanent $10,000 in gross receipts, including reimbursed
States for performing the services. If they have establishment or a fixed base that the em­ expenses, from their entertainment activities in
a fixed base available in the United States, they ployer has in the United States. the United States during the tax year are sub­
are taxed on the income attributable to the fixed Their net income received for the services ject to U.S. tax.
base. is not more than $5,000 during the tax
year. Kazakhstan
Income that residents of Italy receive for la­
bor or personal services performed in the Uni­ Pay received from employment as a mem­ Income that residents of Kazakhstan receive for
ted States as employees (dependent personal ber of the regular complement of a ship or an performing personal services as independent
services) is exempt from U.S. income tax if the aircraft operated in international traffic by a Ja­ contractors or self­employed individuals (inde­
following requirements are met. maican enterprise is exempt from U.S. tax. If pendent personal services) in the United States
The residents are in the United States for the ship or aircraft is operated by a U.S. enter­ is exempt from U.S. income tax if:
no more than 183 days during the tax year. prise, the pay is subject to U.S. tax. The residents are in the United States for
The income is paid by, or on behalf of, an no more than 183 days in any consecutive
employer who is not a resident of the Uni­ These exemptions do not apply to income 12­month period, and
ted States. that residents of Jamaica receive for performing The income is not attributable to a fixed
The income is not borne by a permanent services in the United States as entertainers, base in the United States which is regularly
establishment or a fixed base that the em­ such as theater, motion picture, radio, or televi­ available to the residents.
ployer has in the United States. sion artists, musicians, or athletes, if the gross
receipts (excluding reimbursements for expen­ If the residents have a fixed base available, they
ses) from the services are more than $400 a are taxed only on the income attributable to the
These exemptions do not apply to directors' fixed base.
fees and similar payments received by a resi­ day or $5,000 for the tax year.
dent of Italy for services performed in the United Income that residents of Kazakhstan receive
States as a member of the board of directors of Directors' fees received by residents of Ja­
maica for services performed in the United for employment in the United States (depend­
a company that is a U.S. resident. ent personal services) is exempt from U.S. in­
States as members of boards of directors of
U.S. corporations are exempt from U.S. tax if come tax if the following three requirements are
Pay received for employment regularly exer­ met.
the fees (excluding reimbursed expenses) are
cised aboard a ship or aircraft operated by a The resident is in the United States for no
not more than $400 per day for each day the di­
U.S. enterprise is subject to U.S. tax. more than 183 days in any 12­month pe­
rectors are present in the United States to per­
form the services. riod.
These exemptions do not apply to income The income is paid by, or on behalf of, an
residents of Italy receive as public entertainers employer who is not a resident of the Uni­
(such as theater, motion picture, radio, or televi­
Japan ted States.
sion artists, musicians, or athletes) if they are The income is not borne by a permanent
Income that residents of Japan receive for per­
present in the United States for more than 90 establishment or a fixed base that the em­
sonal services as independent contractors or
days during the tax year or their gross receipts, ployer has in the United States.
self­employed individuals is subject to the provi­
including reimbursed expenses, are more than
sions of Article 7 (business profits) of the treaty.
$20,000 during the tax year for their entertain­ Income derived by a resident of Kazakhstan
Under that provision, business profits are ex­
ment activities in the United States. from employment as a member of the regular
empt from U.S. income tax unless the individual
has a permanent establishment in the United complement of a ship or aircraft operated in in­
Jamaica States. If they have a permanent establishment ternational traffic is exempt from U.S. tax.
in the United States, they are taxed on the prof­
Income that residents of Jamaica receive for its attributable to the permanent establishment. These exemptions do not apply to directors'
the performance of personal services as inde­ fees and similar payments received by a resi­
pendent contractors or self­employed individu­ Income that residents of Japan receive for dent of Kazakhstan as a member of the board
als (independent personal services) in the Uni­ services performed in the United States as em­ of directors or similar body of a company that is
ted States during the tax year is exempt from ployees (dependent personal services) is ex­ a U.S. resident.
U.S. income tax if the residents: empt from U.S. income tax if the residents meet
Are in the United States for no more than the following requirements. Korea, South
89 days during the tax year, They are in the United States for no more
Do not have a fixed base regularly availa­ than 183 days in any 12­month period be­ Income that residents of South Korea receive
ble to them in the United States for per­ ginning or ending in the tax year. for performing personal services as independ­
forming their services, and Their income is paid by, or on behalf of, an ent contractors or self­employed individuals (in­
employer who is not a U.S. resident. dependent personal services) in the United

Page 8 Publication 901 (September 2016)


States during the tax year is exempt from U.S. resident of Latvia as a member of the board of Luxembourg
tax if the residents: directors or similar body of a company that is a
Are in the United States for no more than U.S. resident. Income that residents of Luxembourg receive
182 days during the tax year, for personal services as independent contrac­
Earn income for those services that is not The exemptions do not apply to income resi­ tors or self­employed individuals (independent
more than $3,000 during the tax year, and dents of Latvia receive as public entertainers personal services) in the United States is ex­
Do not maintain a fixed base in the United (such as theater, motion picture, radio, or televi­ empt from U.S. income tax if they do not have a
States for more than 182 days during the sion artists, or musicians) or sportsmen if their fixed base regularly available to them in the Uni­
tax year. gross receipts, including reimbursed expenses, ted States for performing the services. If they
If they maintain a fixed base in the United are more than $20,000 for their personal activi­ have a fixed base available in the United
States for more than 182 days, they are taxed ties in the United States during the tax year. Re­ States, they are taxed on the income attributa­
on the income attributable to the fixed base. gardless of these limits, income of Latvian en­ ble to the fixed base.
tertainers or athletes is exempt from U.S.
Income that residents of Korea receive for income tax if their visit to the United States is Income that residents of Luxembourg re­
labor or personal services performed in the Uni­ wholly or mainly supported by public funds of ceive for services performed in the United
ted States as employees (dependent personal Latvia, its political subdivisions, or local authori­ States as employees (dependent personal
services), including pay for services performed ties. services) is exempt from U.S. income tax if the
as an officer of a corporation, is exempt from residents meet the following requirements.
U.S. tax if the residents meet four requirements. Lithuania They are in the United States for no more
They are in the United States for no more than 183 days in any 12­month period be­
than 182 days during the tax year. Income that residents of Lithuania receive for ginning or ending in the tax year.
They are employees of a resident of Korea performing personal services as independent Their income is paid by, or on behalf of, an
or of a permanent establishment main­ contractors or self­employed individuals (inde­ employer who is not a U.S. resident.
tained in Korea. pendent personal services) in the United States Their income is not borne by a permanent
Their compensation is not borne by a per­ is exempt from U.S. income tax if the residents: establishment or a fixed base that the em­
manent establishment that the employer Are in the United States for no more than ployer has in the United States.
has in the United States. 183 days in any 12­month period begin­
Their income for those services is not more ning or ending in the tax year, and The exemption does not apply to pay re­
than $3,000. Do not have a fixed base regularly availa­ ceived for employment exercised continuously
ble to them in the United States for per­ or predominantly aboard a ship or aircraft oper­
Pay received by employees who are mem­ forming the services. ated in international traffic by a U.S. enterprise.
bers of the regular complement of a ship or air­ If they have a fixed base available, they are
craft operated by a resident of Korea in interna­ taxed only on the income attributable to the The exemptions do not apply to directors'
tional traffic is exempt. fixed base. fees and similar payments received by a resi­
dent of Luxembourg for services performed in
Latvia Income that residents of Lithuania receive the United States as a member of the board of
for services performed in the United States as directors of a company that is a resident of the
Income that residents of Latvia receive for per­ employees (dependent personal services) is United States.
forming personal services as independent con­ exempt from U.S. income tax if the following re­
tractors or self­employed individuals (independ­ quirements are met. The exemptions do not apply to public en­
ent personal services) in the United States is The resident is in the United States for no tertainers (such as theater, motion picture, ra­
exempt from U.S. income tax if the residents: more than 183 days in any 12­month pe­ dio, or television artists, musicians, or athletes)
Are in the United States for no more than riod beginning or ending in the tax year. from Luxembourg who earn more than $10,000
183 days in any 12­month period begin­ The income is paid by, or on behalf of, an in gross receipts, including reimbursed expen­
ning or ending in the tax year, and employer who is not a U.S. resident. ses, from their entertainment activities in the
Do not have a fixed base regularly availa­ The income is not borne by a permanent United States during the tax year.
ble to them in the United States for per­ establishment or a fixed base that the em­
forming the services. ployer has in the United States. Malta
If they have a fixed base available, they are
taxed only on the income attributable to the The exemption does not apply to pay re­ Income that residents of Malta receive for per­
fixed base. ceived for employment as a member of the reg­ sonal services as independent contractors or
ular complement of a ship or an aircraft oper­ self­employed individuals is subject to the provi­
Income that residents of Latvia receive for ated in international traffic by a U.S. enterprise. sions of Article 7 (Business Profits) of the treaty.
services performed in the United States as em­ Under that provision, business profits are ex­
ployees (dependent personal services) is ex­ The exemptions do not apply to directors' empt from U.S. income tax unless the individual
empt from U.S. income tax if the following re­ fees and similar payments received by a resi­ has a permanent establishment in the United
quirements are met. dent of Lithuania as a member of the board of States. If they have a permanent establishment
The resident is in the United States for no directors or similar body of a company that is a in the United States, they are taxed on the prof­
more than 183 days in any 12­month pe­ U.S. resident. its attributable to the permanent establishment.
riod beginning or ending in the tax year.
The income is paid by, or on behalf of, an The exemptions do not apply to income resi­ Income that residents of Malta receive for
employer who is not a U.S. resident. dents of Lithuania receive as public entertainers services performed in the United States as em­
The income is not borne by a permanent (such as theater, motion picture, radio, or televi­ ployees (dependent personal services) is ex­
establishment or a fixed base that the em­ sion artists, or musicians) or sportsmen if their empt from U.S. income tax if the residents meet
ployer has in the United States. gross receipts, including reimbursed expenses, the following requirements.
are more than $20,000 for their personal activi­ They are in the United States for no more
The exemption does not apply to pay re­ ties in the United States during the tax year. Re­ than 183 days in any 12­month period be­
ceived for employment as a member of the reg­ gardless of these limits, income of Lithuanian ginning or ending in the tax year.
ular complement of a ship or an aircraft oper­ entertainers or athletes is exempt from U.S. in­ Their income is paid by, or on behalf of, an
ated in international traffic by a U.S. enterprise. come tax if their visit to the United States is employer who is not a U.S. resident.
wholly or mainly supported by public funds of Their income is not borne by a permanent
The exemptions do not apply to directors' Lithuania, its political subdivisions, or local au­ establishment that the employer has in the
fees and similar payments received by a thorities. United States.

Publication 901 (September 2016) Page 9


The exemption does not apply to directors' Morocco income tax if the following three requirements
fees and similar payments received by a resi­ are met.
dent of Malta for services performed in the Uni­ Income that residents of Morocco receive for The resident is in the United States for no
ted States as a member of the board of direc­ performing personal services as independent more than 183 days during the tax year.
tors of a company that is a resident of the contractors or as self­employed persons (inde­ The income is paid by, or on behalf of, an
United States. pendent personal services) in the United States employer who is not a U.S. resident.
during the tax year is exempt from U.S. income The income is not borne by a permanent
Public entertainers (such as theater, motion tax if the residents: establishment or fixed base the employer
picture, radio, or television artists, musicians, or Are in the United States for no more than has in the United States.
athletes) from Malta who earn more than 182 days during the tax year,
$20,000 in gross receipts, including reimbursed Do not maintain a fixed base in the United Income received by a Netherlands resident
expenses, from their entertainment activities in States for more than 89 days during the tax for employment as a member of the regular
the United States during the tax year are sub­ year, and complement of a ship or aircraft operated in in­
ject to U.S. tax. Earn total income for those services that is ternational traffic is exempt from U.S. tax.
not more than $5,000.
These exemptions do not apply to directors'
Income received by a resident of Malta for If they have a fixed base in the United States for
fees and other similar payments received by a
employment aboard a ship or an aircraft oper­ more than 89 days, they are taxed only on the
resident of the Netherlands for services per­
ated in international traffic is exempt from U.S. income attributable to the fixed base.
formed outside the Netherlands as a member of
income tax if the individual is a member of the the board of directors of a company that is a
regular complement of the ship or aircraft. Income that residents of Morocco receive
resident of the United States.
for labor or personal services performed in the
United States as employees (dependent per­
Mexico sonal services) is exempt from U.S. income tax
These exemptions do not apply to income
residents of the Netherlands receive as public
Income that residents of Mexico receive for per­ if the residents meet three requirements.
entertainers (such as theater, motion picture,
forming personal services as independent con­ They are in the United States for less than
radio, or television artists, or musicians) or ath­
tractors or self­employed individuals (independ­ 183 days during the tax year.
letes if the gross income, including reimbursed
ent personal services) in the United States is They are employees of a resident of Mo­
expenses, is more than $10,000.
exempt from U.S. income tax if the residents: rocco or of a permanent establishment of a
resident of a country other than Morocco if
Are in the United States for no more than New Zealand
the permanent establishment is located in
182 days in a 12­month period, and
Morocco.
Do not have a fixed base that they regu­ Income that residents of New Zealand receive
larly use for performing the services. Their income is not borne by a permanent
establishment that the employer has in the for performing personal services as independ­
If they have a fixed base available, they are United States. ent contractors or self­employed individuals is
taxed only on income attributable to the fixed subject to the provisions of Article 7 (Business
base. Compensation received for services per­ Profits) of the treaty. Under that provision, busi­
formed by a member of the board of directors of ness profits are exempt from U.S. income tax
Income that residents of Mexico receive for a corporation does not qualify for this exemp­ unless the individual has a permanent estab­
employment in the United States (dependent tion. lishment in the United States. If they have a per­
personal services) is exempt from U.S. tax if the manent establishment in the United States, they
following three requirements are met. Income received by an individual for per­ are taxed on the profits attributable to the per­
The resident is present in the United forming labor or personal services as an em­ manent establishment.
States for no more than 183 days in a ployee aboard a ship or an aircraft operated in
12­month period. international traffic by a Moroccan resident is Income that residents of New Zealand re­
The income is paid by, or on behalf of, an exempt from U.S. income tax if the individual is ceive for labor or personal services performed
employer who is not a resident of the Uni­ a member of the regular complement of the ship in the United States as employees (dependent
ted States. or aircraft. personal services) is exempt from U.S. income
The income is not borne by a permanent tax if the residents meet these requirements.
establishment or fixed base that the em­ These exemptions do not apply to income They are present in the United States for
ployer has in the United States. received for services performed in the United no more than 183 days in any consecutive
States by professional entertainers, including 12­month period.
theater, film, radio, and television performers, Their income is paid by or on behalf of an
These exemptions do not apply to directors' employer that is not a resident of the Uni­
musicians, and athletes, unless the services are
fees and similar payments received by a resi­ ted States.
performed by, or for the account of, a Moroccan
dent of Mexico for services performed outside Their income is not borne by a permanent
nonprofit organization.
Mexico as a director or overseer of a company establishment that the employer has in the
that is a U.S. resident. United States.
Netherlands
These exemptions do not apply to income The exemption does not apply to public en­
Income that residents of the Netherlands re­
residents of Mexico receive as public entertain­ tertainers (artists, athletes, etc.) from New Zea­
ceive for performing personal services as inde­
ers (such as theater, motion picture, radio, or land who earn more than $10,000 in gross re­
pendent contractors or self­employed individu­
television artists, or musicians) or athletes if the ceipts, including reimbursed expenses, from
als (independent personal services) in the
income, including reimbursed expenses, is their entertainment activities in the United
United States is exempt from U.S. income tax if
more than $3,000 during the tax year for their States during the tax year.
the income is not attributable to a fixed base in
entertainment activities in the United States.
the United States that is regularly available for
This includes income from activities performed Pay received by a New Zealand resident as
performing the services.
in the United States relating to the entertainer or an employee and member of the regular com­
athlete's reputation, such as endorsements of plement of a ship or aircraft operated in interna­
Income that residents of the Netherlands re­
commercial products. Regardless of this limit, tional traffic is exempt from U.S. tax.
ceive for employment in the United States (de­
the income of Mexican entertainers and ath­
pendent personal services) is exempt from U.S.
letes is exempt from U.S. tax if their visit to the
United States is substantially supported by pub­
lic funds of Mexico, its political subdivisions, or
local authorities.

Page 10 Publication 901 (September 2016)


Norway Do not have a fixed base regularly availa­ Pay received by employees who are mem­
ble to them in the United States for per­ bers of the regular complement of a ship or air­
Income that residents of Norway receive for forming their services. craft operated by a resident of Poland in inter­
performing personal services as independent national traffic is exempt from U.S. tax.
If they have a fixed base available in the United
contractors or self­employed individuals (inde­ States, they are taxed only on the income attrib­
pendent personal services) in the United States Portugal
utable to the fixed base. There is no dollar limit
during the tax year is exempt from U.S. income for condition (2) if the contractor is a resident of
tax if the residents: Income that residents of Portugal receive for
a country other than the United States.
Are present in the United States for no performing personal services as independent
more than 182 days during the tax year, Income that residents of the Philippines re­ contractors or self­employed individuals (inde­
and ceive for personal services performed in the pendent personal services) in the United States
Do not maintain a fixed base in the United United States as employees (dependent per­ is exempt from U.S. income tax if the residents:
States for more than 182 days during the sonal services) is exempt from U.S. income tax Are in the United States for no more than
tax year. if the residents meet three requirements. 182 days in any 12­month period, and
If they do not meet requirement (2), they are They are in the United States for no more Do not have a fixed base regularly availa­
taxed only on the income attributable to the than 89 days during the tax year. ble to them in the United States for per­
fixed base. They are employees of a resident of the forming the activities.
Philippines or of a permanent establish­ If they have a fixed base available, they are
This exemption does not apply to residents ment maintained in the Philippines. taxed only on the income attributable to the
of Norway who are public entertainers (theater, Their income is not borne by a permanent fixed base.
motion picture, or television artists, musicians, establishment that the employer has in the
or athletes) if they are in the United States for United States.
Income that residents of Portugal receive for
more than 90 days during the tax year or their
Pay received by an employee of a resident employment in the United States (dependent
pay for services as public entertainers is more
of the Philippines for personal services per­ personal services) is exempt from U.S. income
than $10,000 during the tax year.
formed as a member of the regular complement tax if the following three requirements are met.
of a ship or an aircraft operated in international The resident is in the United States for no
Income that residents of Norway receive for more than 183 days in any 12­month pe­
labor or personal services performed in the Uni­ traffic by a resident of the Philippines is exempt
from U.S. tax. riod.
ted States as employees (dependent personal
The income is paid by, or on behalf of, an
services) is exempt from U.S. income tax if the
These exemptions do not apply to income employer who is not a U.S. resident.
residents meet three requirements.
residents of the Philippines receive for perform­ The income is not borne by a permanent
They are in the United States less than 183
ing services (both independent and dependent establishment or fixed base that the em­
days during the tax year.
personal services) in the United States as en­ ployer has in the United States.
They are employees of a resident of Nor­
way or of a permanent establishment of a tertainers, such as theater, motion picture, ra­
resident of a state other than Norway if the dio, or television artists, musicians, or athletes, Income received by a resident of Portugal
permanent establishment is situated in if the income is more than $100 a day or $3,000 for employment as a member of the regular
Norway. for the tax year. Regardless of these limits, in­ complement of a ship or aircraft operated in in­
Their income is not borne by a permanent come of Philippine entertainers is exempt from ternational traffic is exempt from U.S. tax.
establishment that the employer has in the U.S. tax if their visit to the United States is sub­
United States. stantially supported or sponsored by the Philip­ These exemptions do not apply to income
pine Government and the entertainers are certi­ residents of Portugal receive as public enter­
The exemption does not apply to a resident fied as qualified for this exemption by the tainers (such as theater, motion picture, radio,
of Norway who performs services as an em­ Philippine competent authority. or television artists, or musicians) or athletes if
ployee aboard a ship or an aircraft operated by that income, including reimbursed expenses, is
a United States resident in international traffic Poland more than $10,000. The income of Portuguese
or in fishing on the high seas if the resident of entertainers and athletes is exempt from U.S.
Norway is a member of the regular complement Income that residents of Poland receive for per­ tax if their visit to the United States is substan­
of the ship or aircraft. forming personal services as independent con­ tially supported by public funds of Portugal or its
tractors or self­employed individuals (independ­ political or administrative subdivisions.
Pakistan ent personal services) in the United States is
exempt from U.S. income tax if they are in the These exemptions do not apply to directors'
Residents of Pakistan who perform personal United States for no more than 182 days during fees and similar payments received by a resi­
services (including professional services) for or the tax year. dent of Portugal for services performed outside
on behalf of a resident of Pakistan while in the of Portugal as a member of the board of direc­
United States for no more than 183 days during Income that residents of Poland receive for tors of a company that is a resident of the Uni­
the tax year are exempt from U.S. income tax labor or personal services performed as em­ ted States.
on the income from the services if they are sub­ ployees (dependent personal services), includ­
ing services performed by an officer of a corpo­
ject to Pakistani tax.
ration or company, in the United States during Romania
the tax year is exempt from U.S. income tax if
Philippines the residents meet three requirements.
Income that residents of Romania receive for
performing personal services as independent
They are in the United States for no more
Income that residents of the Philippines receive contractors or self­employed individuals (inde­
than 182 days during the tax year.
for performing personal services as independ­ pendent personal services) in the United States
Their income is paid by or on behalf of an
ent contractors or as self­employed individuals during the tax year is exempt from U.S. income
employer who is not a U.S. resident.
(independent personal services) in the United tax if the residents:
Their income is not borne by a permanent
States during the tax year is exempt from U.S. Are present in the United States for no
establishment that the employer has in the
income tax if the residents: more than 182 days during the tax year,
United States.
Are in the United States for no more than and
89 days during the tax year, Do not maintain a permanent establish­
Earn gross income for those services that ment in the United States with which the in­
is not more than $10,000 for the tax year if come is effectively connected.
the income is from U.S. contractors, and

Publication 901 (September 2016) Page 11


Income that residents of Romania receive assembly or installation project, or drilling oper­ board of directors of a company that is a resi­
for labor or personal services performed as em­ ation. dent of the United States.
ployees (dependent personal services), includ­
ing services performed by an officer of a corpo­ Income derived by a resident of Russia from Income from employment as a member of
ration or company, in the United States during employment as a member of the regular com­ the regular complement of a ship or aircraft op­
the tax year is exempt from U.S. income tax if plement of a ship or aircraft operated in interna­ erated by a Slovak enterprise in international
the residents meet these requirements. tional traffic is exempt from U.S. tax. traffic is exempt from U.S. income tax. If the
They are in the United States for no more ship or aircraft is operated by a U.S. enterprise,
than 182 days during the tax year. the income is subject to U.S. income tax.
Income from technical services directly con­
They are employees of a resident of Ro­
nected with the application of a right or property
mania or of a permanent establishment
giving rise to a royalty is exempt if those serv­ Slovenia
maintained in Romania by a resident of the
ices are provided as part of a contract granting
United States. Income that residents of Slovenia receive for
the use of the right or property.
Their income is not borne by a permanent personal services as independent contractors
establishment that the employer has in the or self­employed individuals (independent per­
United States. These exemptions do not apply to directors'
fees and similar payments received by a resi­ sonal services) in the United States is exempt
dent of Russia as a member of the board of di­ from U.S. income tax if they do not have a fixed
These exemptions do not apply to entertain­ base regularly available to them in the United
ers, such as theater, motion picture, radio, or rectors or similar body of a company that is a
resident of the United States. States for performing the services. If they have
television artists, musicians, or athletes, who a fixed base available in the United States, they
are present in the United States for more than are taxed on the income attributable to the fixed
90 days during the tax year (90 days or more if Slovak Republic base.
the entertainers are employees) or who earn
gross income as entertainers in the United Income that residents of the Slovak Republic re­
Income that residents of Slovenia receive for
States of more than $3,000 during the tax year ceive for performing personal services as inde­
services performed in the United States as em­
($3,000 or more if they are employees). How­ pendent contractors or self­employed individu­
ployees (dependent personal services) is ex­
ever, the exemptions do apply, without regard als (independent personal services) in the
empt from U.S. income tax if the residents meet
to the 90 day, $3,000 requirement, if the enter­ United States is exempt from U.S. income tax if
the following requirements.
tainers are present in the United States by spe­ the residents:
They are in the United States for no more
cific arrangements between the United States Are present in the United States for no
than 183 days in any 12­month period be­
and Romania. more than 183 days in any 12­month pe­
ginning or ending in the tax year.
riod, and
Their income is paid by, or on behalf of, an
Pay received by employees who are mem­ Do not have a fixed base regularly availa­
employer who is not a U.S. resident.
bers of the regular complement of a ship or air­ ble to them in the United States for per­
Their income is not borne by a permanent
craft operated by a resident of Romania in inter­ forming the activities.
establishment or a fixed base that the em­
national traffic is exempt from U.S. tax. If they have a fixed base available, they are ployer has in the United States.
taxed only on income attributable to the fixed
Russia base. These exemptions do not apply to directors'
fees and similar payments received by a resi­
Income that residents of Russia receive for per­ Income that residents of the Slovak Repub­ dent of Slovenia for services performed in the
forming personal services as independent con­ lic receive for employment in the United States United States as a member of the board of di­
tractors or self­employed individuals (independ­ (dependent personal services) is exempt from rectors of a company that is a resident of the
ent personal services) in the United States is U.S. income tax if the following three require­ United States.
exempt from U.S. income tax if: ments are met.
The residents are in the United States for The resident is present in the United Income received by a Slovenian resident for
no more than 183 days during the calendar States for no more than 183 days in any employment as a member of the regular com­
year, or 12­month period. plement of a ship or aircraft operated in interna­
The income is not attributable to a fixed The income is paid by, or on behalf of, an tional traffic is exempt from U.S. tax.
base in the United States which is regularly employer who is not a U.S. resident.
available to the residents. The income is not borne by a permanent These exemptions do not apply to income
If the residents have a fixed base available, they establishment or a fixed base that the em­ residents of Slovenia receive as public enter­
are taxed only on the income attributable to the ployer has in the United States. tainers (such as theater, motion picture, radio,
fixed base. or television artists, or musicians) or athletes if
These exemptions do not apply to income their gross receipts, including reimbursed ex­
Income that residents of Russia receive for residents of the Slovak Republic receive as penses, are more than $15,000 during the tax
employment in the United States (dependent public entertainers (such as theater, motion pic­ year. Regardless of these limits, income of
personal services) is exempt from U.S. income ture, radio, or television artists, or musicians) or Slovenian entertainers or athletes is exempt
tax if the following three requirements are met. sportsmen if their gross receipts, including re­ from U.S. tax if their visit to the United States is
The resident is in the United States for no imbursed expenses, are more than $20,000 wholly or mainly paid by public funds of either
more than 183 days during the calendar during the tax year. Regardless of these limits, the United States or Slovenia or their political
year. income of Slovak entertainers and sportsmen is subdivisions, or local authorities.
The income is paid by, or on behalf of, an exempt from U.S. income tax if their visit to the
employer who is not a resident of the Uni­ United States is substantially supported by pub­
ted States.
South Africa
lic funds of the Slovak Republic, its political
The income is not borne by a permanent subdivisions, or local authorities, or the visit is Income that residents of South Africa receive
establishment or a fixed base that the em­ made pursuant to a specific arrangement be­ for performing personal services as independ­
ployer has in the United States. tween the United States and the Slovak Repub­ ent contractors or self­employed individuals (in­
However, income from employment directly lic. dependent personal services) in the United
connected with a place of business that is not a States is exempt from U.S. income tax if the
permanent establishment is exempt if the resi­ These exemptions do not apply to directors' residents:
dent is present in the United States not longer fees and similar payments received by a resi­ Are in the United States for no more than
than 12 consecutive months. For this purpose, dent of the Slovak Republic for services per­ 183 days in any 12­month period begin­
a place of business means a construction site, formed in the United States as a member of the ning or ending in the tax year, and

Page 12 Publication 901 (September 2016)


Do not have a fixed base regularly availa­ The exemption does not apply to pay re­ United States as a member of the board of di­
ble to them in the United States for per­ ceived by employees who are members of a rectors of a company resident in the United
forming the services. regular complement of a ship or aircraft oper­ States.
ated in international traffic by a U.S. enterprise.
If they have a fixed base available, they are
taxed only on income attributable to the fixed Sweden
base. These exemptions do not apply to public en­
tertainers (such as theater, motion picture, ra­ Income that residents of Sweden receive for
dio, or television artists, or musicians) or ath­ performing personal services as independent
Income that residents of South Africa re­
letes from Spain who earn more than $10,000 in contractors or self­employed individuals (inde­
ceive for services performed in the United
income, including reimbursed expenses, from pendent personal services) in the United States
States as employees (dependent personal
their entertainment activities in the United during the tax year is exempt from U.S. income
services) is exempt from U.S. income tax if the
States during the tax year. Regardless of these tax if they do not have a fixed base regularly
following requirements are met.
limits, Spanish entertainers and athletes are ex­ available to them in the United States for per­
The resident is in the United States for no
empt from U.S. tax if their visit to the United forming the services. If they have a fixed base
more than 183 days in any 12­month pe­
States is substantially supported by public available in the United States, they are taxed on
riod beginning or ending in the tax year.
funds of Spain, a political subdivision, or local the income attributable to the fixed base.
The income is paid by, or on behalf of, an
authority.
employer who is not a U.S. resident.
The income is not borne by a permanent Income that residents of Sweden receive for
establishment or a fixed base that the em­ Sri Lanka labor or personal services performed in the Uni­
ployer has in the United States. ted States as employees (dependent personal
Income that residents of Sri Lanka receive for services) is exempt from U.S. income tax if the
performing personal services as independent residents meet three requirements.
These exemptions do not apply to directors'
contractors or self­employed individuals (inde­ They are in the United States for no more
fees and similar payments received by a resi­
pendent personal services) in the United States than 183 days during any consecutive
dent of South Africa for services performed in
during the tax year is exempt from U.S. income 12­month period.
the United States as a member of the board of
tax if the residents: Their income is paid by, or on behalf of, an
directors of a company resident in the United
Are in the United States for no more than employer who is not a resident of the Uni­
States.
183 days in any 12­month period, or ted States.
Do not have a fixed base regularly availa­ Their income is not borne by a permanent
These exemptions do not apply to income ble to them in the United States for the pur­ establishment or a fixed base that the em­
residents of South Africa receive as public en­ pose of performing the services. ployer has in the United States.
tertainers (such as theater, motion picture, ra­
dio, or television artists, or musicians) or ath­ If they have a fixed base available in the Income received by a resident of Sweden
letes if their gross receipts, including United States, they are taxed on the income at­ for employment as a member of the regular
reimbursed expenses, are more than $7,500 tributable to the fixed base. complement of a ship or aircraft operated in in­
during the tax year. Regardless of these limits, ternational traffic is exempt from U.S. tax.
income of South African entertainers or athletes
Income that residents of Sri Lanka receive
is exempt from U.S. income tax if their visit to These exemptions do not apply to income
for services performed in the United States as
the United States is wholly or mainly supported residents of Sweden receive as public enter­
employees (dependent personal services) is
by public funds of South Africa, its political sub­ tainers (such as theater, motion picture, radio,
exempt from U.S. income tax if the residents
divisions, or local authorities. or television artists, or musicians) or athletes if
meet the following requirements.
They are in the United States for no more the gross income, including reimbursed expen­
Income received by a resident of South Af­ than 183 days in any 12­month period. ses, is more than $6,000 for any 12­month pe­
rica for services performed as an employee and Their income is paid by, or on behalf of, an riod.
member of the complement of a ship or aircraft employer who is not a U.S. resident.
operated in international traffic is exempt from Their income is not borne by a permanent These exemptions do not apply to directors'
U.S. income tax. establishment or a fixed base that the em­ fees received by a resident of Sweden for serv­
ployer has in the United States. ices performed outside of Sweden as a member
Spain of the board of directors of a company that is a
Income received from employment as a resident of the United States.
Income that residents of Spain receive as inde­ member of the regular complement of a ship or
pendent contractors or self­employed individu­ an aircraft operated in international traffic by a Switzerland
als (independent personal services) in the Uni­ Sri Lanka enterprise is exempt from U.S. tax. If
ted States is exempt from U.S. income tax if the the ship or aircraft is operated by a U.S. enter­ Income that residents of Switzerland receive for
residents do not have a fixed base available to prise, the income is subject to U.S. tax. personal services as independent contractors
them in the United States for performing the or self­employed individuals (independent per­
services. If they have a fixed base, they are These exemptions do not apply to public en­ sonal services) that they perform during the tax
taxed only on the income attributable to the tertainers (such as theater, motion picture, ra­ year in the United States is exempt from U.S.
fixed base. dio, or television entertainers, musicians, and income tax if they do not have a fixed base reg­
athletes) from Sri Lanka who earn more than ularly available to them in the United States for
Income that residents of Spain receive for $6,000 in gross receipts, including reimbursed performing the services. If they have a fixed
personal services performed in the United expenses, from their entertainment activities in base available in the United States, they are
States as employees (dependent personal the United States during the tax year. Regard­ taxed on the income attributable to the fixed
services) is exempt from U.S. income tax if: less of these limits, income of Sri Lanka enter­ base.
The residents are present in the United tainers is exempt from U.S. income tax if their
States no more than 183 days in any visit to the United States is directly or indirectly Income that residents of Switzerland receive
12­month period, supported wholly or substantially by public for services performed in the United States as
The income is paid by, or on behalf of, an funds of Sri Lanka or the United States, their employees (dependent personal services) is
employer who is not a U.S. resident, and political subdivisions, or local authorities. exempt from U.S. income tax if the residents
The income is not borne by a permanent meet the following requirements.
establishment or fixed base the employer These exemptions do not apply to directors' They are in the United States for no more
has in the United States. fees and other compensation received by a res­ than 183 days in any 12­month period be­
ident of Sri Lanka for services performed in the ginning or ending in the tax year.

Publication 901 (September 2016) Page 13


Their income is paid by, or on behalf of, an services in the United States as entertainers Their income is paid by, or on behalf of, an
employer who is not a U.S. resident. (such as theater, motion picture, radio, or televi­ employer who is not a resident of the Uni­
Their income is not borne by a permanent sion artists, or musicians) and athletes, if the in­ ted States, and
establishment or a fixed base that the em­ come is more than $100 a day or $3,000 for the Their income is not borne by a permanent
ployer has in the United States. tax year. Regardless of these limits, income of establishment or fixed base the employer
Thai entertainers is exempt from U.S. tax if their has in the United States.
These exemptions do not apply to directors' visit to the United States is substantially suppor­
fees and similar payments received by a resi­ ted by public funds of Thailand or its political Pay received by employees who are mem­
dent of Switzerland as a member of the board subdivisions or local authorities. bers of the regular complement of a ship or air­
of directors of a company that is a resident of craft operated by an enterprise in international
the United States. The exemption does not apply to pay re­ traffic is exempt from U.S. tax if the place of
ceived by employees who are members of the management of the enterprise is in Tunisia.
These exemptions do not apply to public en­ regular complement of a ship or aircraft oper­ However, if the enterprise is created under the
tertainers (such as theater, motion picture, ra­ ated in international traffic by a U.S. enterprise. laws of the United States (or a U.S. state), the
dio, or television entertainers, musicians, and pay is subject to U.S. tax.
athletes) from Switzerland who earn more than
$10,000 in gross receipts, including reimbursed
Trinidad and Tobago These exemptions do not apply to income
expenses, from their entertainment activities in residents of Tunisia receive as public entertain­
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
during the tax year for personal services per­ their gross receipts, including reimbursed ex­
Income received by a resident of Switzer­ formed in the United States is exempt from U.S.
land for services performed as an employee penses, are more than $7,500 during the tax
income tax if the individuals are in the United year.
and member of the regular complement of a States for no more than 183 days during the tax
ship or aircraft operated in international traffic is year and either:
exempt from U.S. income tax. These exemptions do not apply to fees re­
The residents are employees of a resident ceived by a resident of Tunisia for services per­
of a country other than the United States or formed as a director of a U.S. corporation if the
Thailand are employees of a permanent establish­ fees are treated as a distribution of profits and
ment of a U.S. resident outside the United cannot be taken as a deduction by the corpora­
Income that residents of Thailand receive for States and the income is not deducted in tion.
performing personal services as independent figuring the profits of a permanent estab­
contractors or as self­employed individuals (in­ lishment in the United States, or
dependent personal services) in the United The income is not more than $3,000 (ex­ Turkey
States during the tax year is exempt from U.S. cluding reimbursed travel expenses).
income tax if the residents: Income that residents of Turkey receive for per­
Are in the United States for no more than forming personal services as independent con­
These exemptions do not apply to the pro­ tractors or self­employed individuals (independ­
89 days during the tax year, and fessional earnings of public entertainers such
Do not have a fixed base regularly availa­ ent personal services) in the United States is
as actors, musicians, and professional athletes exempt from U.S. income tax if the residents:
ble to them in the United States for per­ or to any person providing their services if the
forming their services. Are in the United States for purposes of
pay is more than $100 per day (excluding reim­ performing the services or activities for no
If they have a fixed base available in the United bursed travel expenses). more than 183 days in any 12­month pe­
States, they are taxed only on the income attrib­ riod, and
utable to the fixed base. Pay received by members of the regular Do not have a fixed base regularly availa­
complement of a ship or aircraft operated in in­ ble to them in the United States for per­
This exemption does not apply if a resident ternational traffic by a resident of Trinidad and forming the services.
of Thailand earns more than $10,000 for inde­ Tobago is exempt from U.S. tax.
pendent personal services and that income is If they have a fixed base available, they are
paid by a U.S. resident or borne by a perma­ taxed only on income attributable to the fixed
Tunisia base.
nent establishment or fixed base in the United
States. Income that residents of Tunisia receive for per­ Income that residents of Turkey receive for
forming personal services as independent con­ services performed in the United States as em­
Income that residents of Thailand receive for tractors or self­employed individuals (independ­ ployees (dependent personal services) is ex­
services performed in the United States as em­ ent personal services) in the United States are empt from U.S. income tax if the following re­
ployees (dependent personal services) is ex­ exempt from U.S. income tax if: quirements are met.
empt from U.S. income tax if the following re­ They are in the United States for no more The resident is in the United States for no
quirements are met. than 183 days during the tax year, more than 183 days in any 12­month pe­
The resident is in the United States for no They do not have a fixed base regularly riod.
more than 183 days in any 12­month pe­ available in the United States for perform­ The income is paid by, or on behalf of, an
riod beginning or ending in the tax year. ing the services, and employer who is not a U.S. resident.
The income is paid by, or on behalf of, an The gross income for the tax year from The income is not borne by a permanent
employer who is not a U.S. resident. U.S. residents for services performed in establishment or a fixed base that the em­
The income is not borne by a permanent the United States is no more than $7,500. ployer has in the United States.
establishment or a fixed base that the em­
ployer has in the United States.
If they do not meet condition (2), they are This exemption does not apply to a resident
taxed on the income that is attributable to the of Turkey who performs services as a member
These exemptions do not apply to directors' of the regular complement of a ship or an air­
fixed base.
fees and similar payments received by a resi­ craft operated by a U.S. resident in international
dent of Thailand for services performed outside traffic.
of Thailand as a member of the board of direc­ Income that residents of Tunisia receive for
tors of a company that is a resident of the Uni­ personal services performed in the United
ted States. States as employees (dependent personal
services) is exempt from U.S. income tax if:
These exemptions do not apply to income The residents are in the U.S. for no more
residents of Thailand receive for performing than 183 days during the tax year,

Page 14 Publication 901 (September 2016)


These exemptions do not apply to directors' contractors or self­employed individuals are United States as a member of the board of di­
fees and similar payments received by a resi­ subject to the provisions of Article 7 (Business rectors of a company resident in the United
dent of Turkey for services provided in the Uni­ Profits) of the treaty. Under that provision, busi­ States.
ted States as a member of the board of direc­ ness profits are exempt from U.S. income tax
tors of a company that is a resident of the unless the individual has a permanent estab­ Pay received by a resident of Venezuela for
United States. lishment in the United States. If they have a per­ services performed as an employee of a ship or
manent establishment in the United States, they an aircraft operated in international traffic is ex­
These exemptions do not apply to income are taxed on the profits attributable to the per­ empt from U.S. income tax.
residents of Turkey receive as public entertain­ manent establishment.
ers (such as theater, motion picture, radio, or These exemptions do not apply to income
television artists, or musicians) or athletes if Income that residents of the United King­ residents of Venezuela receive as public enter­
their gross receipts are more than $3,000 dur­ dom receive for services performed in the Uni­ tainers (such as theater, motion picture, radio,
ing the tax year for their entertainment activities ted States as employees (dependent personal or television artists, or musicians) or sportsmen
in the United States. If their visit to the United services) is exempt from U.S. income tax if the if their gross income, including reimbursed ex­
States is substantially supported by a Turkish residents meet the following requirements. penses, is more than $6,000 for their personal
non­profit organization or from the public funds They are in the United States for no more activities in the United States during the tax
of Turkey, its political subdivisions, or local au­ than 183 days in any 12­month period be­ year. Regardless of these limits, income of Ven­
thorities, the income is taxed as independent ginning or ending in the tax year. ezuelan entertainers or athletes is exempt from
personal services or dependent personal serv­ Their income is paid by, or on behalf of, an U.S. income tax if their visit to the United States
ices. employer who is not a U.S. resident. is wholly or mainly supported by public funds of
Their income is not borne by a permanent Venezuela, its political subdivisions, or local au­
establishment that the employer has in the thorities.
Ukraine United States.
Income that residents of Ukraine receive for
The exemption does not apply to directors'
Professors, Teachers,
performing personal services as independent
fees and similar payments received by a resi­ and Researchers
contractors or self­employed individuals (inde­
dent of the United Kingdom for services per­
pendent personal services) in the United States Pay of professors and teachers who are resi­
formed in the United States as a member of the
is exempt from U.S. income tax if the income is dents of the following countries is generally ex­
board of directors of a company resident in the
not attributable to a fixed base in the United empt from U.S. income tax for 2 or 3 years if
United States.
States that is regularly available for performing they temporarily visit the United States to teach
the services. or do research. The exemption applies to pay
Public entertainers (such as theater, motion
picture, radio, or television artists, musicians, or earned by the visiting professor or teacher dur­
Income that residents of Ukraine receive for ing the applicable period. For most of the fol­
athletes) from the United Kingdom who earn
employment in the United States (dependent lowing countries, the applicable period begins
more than $20,000 in gross receipts, including
personal services) is exempt from U.S. income on the date of arrival in the United States for the
reimbursed expenses, from their entertainment
tax if the following three requirements are met. purpose of teaching or engaging in research.
activities in the United States during the tax
The resident is in the United States for no Furthermore, for most of the following countries,
year are subject to U.S. tax.
more than 183 days during the tax year. the exemption applies even if the stay in the
The income is paid by, or on behalf of, an Income received by a resident of the United United States extends beyond the applicable
employer who is not a resident of the Uni­ Kingdom for services performed as an em­ period.
ted States. ployee and member of the regular complement
The income is not borne by a permanent The exemption generally applies to pay re­
of a ship or aircraft operated in international traf­ ceived during a second teaching assignment if
establishment or a fixed base that the em­ fic is exempt from U.S. income tax.
ployer has in the United States. both are completed within the specified time,
even if the second assignment was not ar­
These exemptions do not apply to directors' Venezuela ranged until after arrival in the United States on
fees and similar payments received by a resi­ the first assignment. For each of the countries
Income that residents of Venezuela receive for listed, the conditions are stated under which the
dent of Ukraine for services performed outside
personal services as independent contractors pay of a professor or teacher from that country
of Ukraine as a member of the board of direc­
or self­employed individuals (independent per­ is exempt from U.S. income tax.
tors of a company that is a resident of the Uni­
sonal services) in the United States is exempt
ted States. If you do not meet the requirements for ex­
from U.S. income tax if they do not have a fixed
base regularly available to them in the United emption as a teacher or if you are a resident of
These exemptions generally do not apply to a treaty country that does not have a special
States for performing the services. If they have
income received as a public entertainer (such provision for teachers, you may qualify under a
a fixed base available, they are taxed on the in­
as a theater, motion picture, radio, or television personal services income provision discussed
come attributable to the fixed base.
artist, musician, or athlete). However, income of earlier.
Ukrainian entertainers and sportsmen is exempt Income that residents of Venezuela receive
from U.S. income tax if their visit to the United
States is substantially supported by public
for services performed in the United States as Bangladesh
employees (dependent personal services) is
funds of Ukraine, its political subdivisions, or lo­ exempt from U.S. income tax if the residents An individual is exempt from U.S. income tax on
cal authorities, or the visit is made pursuant to a meet the following requirements. income from teaching or research for not more
specific arrangement between the United They are in the United States for no more than 2 years from the date of arrival for such
States and Ukraine. than 183 days in any 12­month period be­ purposes if he or she:
ginning or ending in the tax year. Is a resident of Bangladesh immediately
Income derived by a resident of Ukraine Their income is paid by, or on behalf of, an before visiting the United States, and
from employment as a member of the regular employer who is not a U.S. resident. Is in the United States to teach or engage
complement of a ship or aircraft operated in in­ The income is not borne by a permanent in research at a university, college, or other
ternational traffic is exempt from U.S. tax. establishment or a fixed base that the em­ recognized educational institution.
ployer has in the United States.
United Kingdom This exemption does not apply to income
These exemptions do not apply to directors' from research carried on mainly for the private
Income that residents of the United Kingdom re­ fees and similar payments received by a resi­ benefit of any person rather than in the public
ceive for personal services as independent dent of Venezuela for services performed in the interest.

Publication 901 (September 2016) Page 15


Belgium The exemption does, however, apply if the in research, or both, at a university or other edu­
research is conducted through an cational or research institution is exempt from
An individual who is a resident of Belgium at the intergovernmental agreement on cooperation. U.S. income tax on income from teaching or re­
beginning of the visit to the United States and search for a maximum of 2 years from the date
who is temporarily in the United States to teach This exemption also applies to journalists of arrival in the United States.
or carry on research at a school, college, uni­ and correspondents who are temporarily in the
versity or other educational or research institu­ United States for periods not longer than 2 An individual may claim this benefit only
tion is exempt from U.S. income tax for a period years and who receive their compensation from once. Also, this benefit and the benefits descri­
not exceeding 2 years from the date of arrival in abroad. It is not necessary that the journalists or bed later under Students and Apprentices can
the United States on income received for teach­ correspondents be invited by the U.S. Govern­ be claimed for no more than 5 years.
ing or carrying on research. ment or other appropriate institution, nor does it
matter that they are employed by a private per­ This exemption does not apply to income
This exemption does not apply to income son, including commercial enterprises and for­ from research carried on mainly for the private
from research carried on mainly for the private eign trade organizations. benefit of any person rather than in the public
benefit of any person rather than in the public interest.
interest.
Czech Republic
Germany
Bulgaria An individual is exempt from U.S. income tax on
income for teaching or research for up to 2 A professor or teacher who is a resident of Ger­
An individual who is a resident of Bulgaria at the years if he or she: many and who is temporarily in the United
beginning of the visit to the United States and Is a resident of the Czech Republic imme­ States to engage in advanced study or research
who is temporarily in the United States to teach diately before visiting the United States, or teaching at an accredited educational institu­
or carry on research at a school, college, uni­ and tion or institution engaged in research for the
versity or other recognized educational or re­ Is in the United States primarily to teach or public benefit is exempt from U.S. tax on in­
search institution is exempt from U.S. income conduct research at a university, college, come received for such study, research, or
tax for a period not exceeding 2 years from the school, or other accredited educational or teaching for a maximum of 2 years from the
date of arrival in the United States on income research institution. date of arrival in the United States.
received for teaching or carrying on research.
A Czech resident is entitled to these benefits The exemption does not apply to income
This exemption does not apply to income only once. However, the exemption does not from research carried on mainly for the private
from research carried on mainly for the private apply if: benefit of any person rather than in the public
benefit of any person rather than in the public The resident claimed during the immediate interest. The exemption does not apply if, dur­
interest. preceding period the benefits described ing the preceding period, the benefit described
later under Students and Apprentices, or in paragraph (2), (3), or (4) of Article 20 of the
China, People's Republic of The income is from research undertaken treaty, pertaining to students, was claimed.
primarily for the private benefit of a specific
An individual who is a resident of the People's person or persons. Greece
Republic of China and who is temporarily in the
United States primarily to teach, lecture, or con­ Egypt A professor or teacher who is a resident of
duct research at a university or other accredited Greece and who is temporarily in the United
educational institution or scientific research in­ An individual who is a resident of Egypt on the States to teach at a university, college, or other
stitution is exempt from U.S. income tax on in­ date of arrival in the United States and who is educational institution for a maximum of 3 years
come for the teaching, lecturing, or research for temporarily in the United States primarily to is exempt from U.S. income tax on the income
a total of not more than 3 years. teach or engage in research, or both, at a uni­ received for teaching during that period.
versity or other recognized educational institu­
This exemption does not apply to income
from research carried on mainly for the private
tion is exempt from U.S. income tax on income Hungary
from the teaching or research for a maximum of
benefit of any person rather than in the public 2 years from the date of arrival in the United An individual who is a resident of Hungary on
interest. States. The individual must have been invited to the date of arrival in the United States and who
the United States for a period not expected to is temporarily in the United States primarily to
Commonwealth of be longer than 2 years by the U.S. Government teach or engage in research, or both, at a uni­
Independent States (C.I.S.) or a state or local government, or by a university versity or other recognized educational institu­
or other recognized educational institution in the tion is exempt from U.S. income tax on income
An individual who is a resident of a C.I.S. mem­ United States. for the teaching or research for a maximum of 2
ber on the date of arrival in the United States years from the date of arrival in the United
and who is temporarily in the United States at The exemption does not apply if the resident States. The individual must have been invited to
the invitation of the U.S. Government or an edu­ claimed, during the immediately preceding pe­ the United States for a period not expected to
cational or scientific research institution in the riod, the benefits described later under Stu- be longer than 2 years by the U.S. Government
United States primarily to teach, engage in re­ dents and Apprentices. or a state or local government, or by a university
search, or participate in scientific, technical, or or other recognized educational institution in the
professional conferences is exempt from U.S. This exemption does not apply to income United States.
income tax on income for teaching, research, or from research carried on mainly for the private
participation in these conferences for a maxi­ benefit of any person rather than in the public The exemption does not apply to income
mum period of 2 years. interest. from research carried on mainly for the private
benefit of any person rather than in the public
This exemption does not apply to income interest.
from research carried on mainly for the benefit
France
of a private person, including a commercial en­
terprise of the United States or a foreign trade
An individual who is a resident of France on the Iceland
date of arrival in the United States and who is
organization of a C.I.S. member.
temporarily in the United States at the invitation Although there is no provision to exempt in­
of the U.S. Government, a university, or other come derived by teachers or researchers in the
recognized educational or research institution in treaty, an individual who was otherwise entitled
the United States primarily to teach or engage to treaty benefits under Article 21 (Teachers) of

Page 16 Publication 901 (September 2016)


the treaty in effect before 2009 can continue to is expected to last no more than 2 years to Luxembourg
apply those provisions. teach or conduct research at a university, col­
lege, school, or other recognized educational A resident of Luxembourg who is temporarily in
India institution, or at a medical facility primarily fun­ the United States at the invitation of a U.S. uni­
ded from government sources, is exempt from versity, college, school, or other recognized ed­
An individual is exempt from U.S. tax on income U.S. income tax for up to 2 years on pay from ucational institution only to teach or engage in
received for teaching or research if he or she: this teaching or research. research, or both, at that educational institution
Is a resident of India immediately before is exempt from U.S. income tax on income for
visiting the United States, and This exemption does not apply to income the teaching or research for not more than 2
Is in the United States to teach or engage from research carried on mainly for the private years from the date of arrival in the United
in research at an accredited university or benefit of any person rather than in the public States.
other recognized educational institution in interest.
the United States for a period not longer If the individual's visit to the United States is
than 2 years. Jamaica longer than 2 years, the exemption is lost for the
entire visit unless the competent authorities of
If the individual's visit to the United States An individual who is a resident of Jamaica on Luxembourg and the United States agree other­
exceeds 2 years, the exemption is lost for the the date of arrival in the United States and who wise.
entire visit. temporarily visits the United States to teach or
engage in research at a university, college, or This exemption does not apply to pay for re­
This exemption does not apply to income other recognized educational institution for a search carried on for the benefit of any person
from research carried on mainly for the private period not expected to exceed 2 years, is ex­ other than the educational institution that exten­
benefit of any person rather than in the public empt from U.S. income tax on the income re­ ded the invitation.
interest. ceived for the teaching or research for not more
than 2 years from the date of arrival in the Uni­ Netherlands
Indonesia ted States. A resident of Jamaica is entitled to
this exemption only once. An individual is exempt from U.S. income tax on
An individual is exempt from U.S. tax on income income received for teaching or research for a
for teaching or research for a maximum of 2 This exemption does not apply to income maximum of 2 years from the date of arrival if
years from the date of arrival in the United from research carried on mainly for the private he or she:
States if he or she: benefit of any person rather than in the public Is a resident of the Netherlands immedi­
Is a resident of Indonesia immediately be­ interest. ately before visiting the United States, and
fore visiting the United States, and Is in the United States to teach or engage
Is in the United States at the invitation of a Japan in research at a university, college, or other
university, school, or other recognized ed­ recognized educational institution for not
ucational institution to teach or engage in An individual who is a resident of Japan and more than 2 years.
research, or both, at that educational insti­ who is temporarily in the United States primarily
tution. to teach or engage in research at a university, If the individual's visit to the United States is
college, or other recognized educational institu­ longer than 2 years, the exemption is lost for the
A resident of Indonesia is entitled to this ex­ tion is exempt from U.S. income tax on income entire visit unless the competent authorities of
emption only once. But this exemption does not for the teaching or research for a maximum of 2 the Netherlands and the United States agree
apply to income from research carried on years from the date of arrival in the United otherwise.
mainly for the private benefit of any person. States.
The exemption does not apply to income
The exemption does not apply to income from research carried on primarily for the pri­
Israel from research carried on mainly for the private vate benefit of any person rather than in the
benefit of any person rather than in the public public interest. Nor does the exemption apply if
An individual who is a resident of Israel on the
interest. the resident claimed during the immediate pre­
date of arrival in the United States and who is
temporarily in the United States primarily to ceding period the benefits described later under
teach or engage in research, or both, at a uni­ Korea, South Students and Apprentices.
versity or other recognized educational institu­
tion is exempt from U.S. income tax on income An individual who is a resident of South Korea Norway
from the teaching or research for a maximum of on the date of arrival in the United States and
2 years from the date of arrival in the United who is temporarily in the United States primarily An individual who is a resident of Norway on the
States. The individual must have been invited to to teach or engage in research, or both, at a date of arrival in the United States and who is
the United States for a period not expected to university or other recognized educational insti­ temporarily in the United States at the invitation
be longer than 2 years by the U.S. Government tution is exempt from U.S. income tax on in­ of the U.S. Government, a university, or other
or a state or local government, or by a university come for the teaching or research for a maxi­ recognized educational institution in the United
or other recognized educational institution in the mum of 2 years from the date of arrival in the States primarily to teach or engage in research,
United States. United States. The individual must have been or both, at a university or other recognized edu­
invited to the United States for a period not ex­ cational institution is exempt from U.S. income
This exemption does not apply to income pected to be longer than 2 years by the U.S. tax on income for the teaching or research for a
from research carried on mainly for the private Government or a state or local government, or maximum period of 2 years from the date of ar­
benefit of any person rather than in the public by a university or other recognized educational rival in the United States.
interest. The exemption does not apply if, dur­ institution in the United States.
ing the immediately preceding period, the bene­ This exemption does not apply to income
fits described in Article 24(1) of the treaty, per­ The exemption does not apply to income from research carried on mainly for the private
taining to students, were claimed. 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 interest.
interest.
Italy
Pakistan
A professor or teacher who is a resident of Italy
immediately before the date of arrival in the Uni­ A professor or teacher who is a resident of Paki­
ted States and whose visit to the United States stan and who temporarily visits the United

Publication 901 (September 2016) Page 17


States to teach at a university, college, school, This exemption does not apply to income U.S. income tax on income for the teaching or
or other educational institution for not longer from research carried on mainly for the private research. The exemption from tax applies only
than 2 years is exempt from U.S. income tax on benefit of any person rather than in the public if the visit does not exceed 2 years from the
the income received for teaching for that period. interest. date the individual first visits the United States
for the purpose of engaging in teaching or re­
Philippines Romania search.

An individual who is a resident of the Philip­ An individual who is a resident of Romania on This exemption does not apply to income
pines on the date of arrival in the United States the date of arrival in the United States and who from research carried on mainly for the private
and who is temporarily in the United States pri­ is temporarily in the United States at the invita­ benefit of any person rather than in the public
marily to teach or engage in research, or both, tion of the U.S. Government, a university, or interest. This exemption does not apply if, dur­
at a university or other recognized educational other recognized educational institution in the ing the immediately preceding period, the bene­
institution is exempt from U.S. income tax on in­ United States primarily to teach or engage in re­ fits described in treaty Article 22(1), pertaining
come from the teaching or research for not search, or both, at a university or other recog­ to students, were claimed.
more than 2 years from the date of arrival in the nized educational institution is exempt from
United States. The individual must have been U.S. income tax on income for the teaching or Trinidad and Tobago
invited to the United States for a period not ex­ research for a maximum of 2 years from the
pected to be longer than 2 years by the U.S. date of arrival in the United States. An individual who is a resident of Trinidad and
Government or a state or local government, or Tobago on the date of arrival in the United
by a university or other recognized educational This exemption does not apply to income States and who is temporarily in the United
institution in the United States. from research carried on mainly for the private States at the invitation of the U.S. Government,
benefit of any person rather than in the public a university, or other accredited educational in­
This exemption does not apply to income interest. stitution in the United States primarily to teach
from research carried on mainly for the private or engage in research, or both, at a university or
benefit of any person rather than in the public Slovak Republic other accredited educational institution is ex­
interest. The exemption does not apply if, dur­ empt from U.S. income tax on the income re­
ing the immediately preceding period, the bene­ An individual is exempt from U.S. income tax on ceived for the teaching or research for a maxi­
fits described in Article 22(1) of the treaty, per­ income for teaching or research for up to 2 mum of 2 years from the date of arrival in the
taining to students, were claimed. years if he or she: United States.
Is a resident of the Slovak Republic imme­
diately before visiting the United States, This exemption does not apply to income
Poland from research carried on mainly for the private
and
Is in the United States primarily to teach or benefit of any person rather than in the public
An individual who is a resident of Poland on the
conduct research at a university, college, interest. Nor does the exemption apply to in­
date of arrival in the United States and who is
school, or other accredited educational or come if an agreement exists between the Gov­
temporarily in the United States at the invitation
research institution. ernments of Trinidad and Tobago and the Uni­
of the U.S. Government, a university, or other
ted States for providing the services of these
recognized educational institution in the United
A Slovak resident is entitled to these bene­ individuals.
States primarily to teach or engage in research,
or both, at a university or other recognized edu­ fits only once. However, the exemption does
cational institution is exempt from U.S. income not apply if: Turkey
tax on income for the teaching or research for a The resident claimed during the immediate
maximum of 2 years from the date of arrival in preceding period the benefits described An individual who was a resident of Turkey im­
the United States. later under Students and Apprentices, or mediately before visiting the United States who
The income is from research undertaken is in the United States for not longer than 2
primarily for the private benefit of a specific years for the purpose of teaching or engaging in
The exemption does not apply if the resident
person or persons. scientific research is exempt from U.S. income
claimed, during the immediately preceding pe­
tax on payments received from outside the Uni­
riod, the benefits described later under Stu-
Slovenia ted States for teaching or research.
dents and Apprentices.

This exemption does not apply to income


An individual who is a resident of Slovenia on United Kingdom
the date of arrival in the United States and who
from research carried on mainly for the private
temporarily visits the United States to teach or A professor or teacher who is a resident of the
benefit of any person rather than in the public
engage in research at a recognized educational United Kingdom on the date of arrival in the Uni­
interest.
or research institution is exempt from U.S. in­ ted States and who is in the United States for
come tax on the income received for the teach­ not longer than 2 years primarily to teach or en­
Portugal ing or research for not more than 2 years from gage in research at a university, college, or
the date of arrival in the United States. This other recognized educational institution is ex­
An individual who is a resident of Portugal on benefit can be claimed for no more than 5 empt from U.S. income tax on income for the
the date of arrival in the United States and who years. teaching or research. If the individual's 2­year
is temporarily in the United States at the invita­ period is exceeded, the exemption is lost for the
tion of the U.S. Government, a university, other The exemption does not apply to income entire visit, including the 2­year period.
accredited educational institution, or recognized from research carried on mainly for the private
research institution in the United States, or un­ benefit of any person rather than in the public The exemption does not apply to income
der an official cultural exchange program, only interest. from research carried on mainly for the private
to teach or engage in research, or both, at a benefit of any person rather than in the public
university or educational institution is exempt interest.
from U.S. income tax on income from teaching Thailand
or research for a maximum of 2 years from the
date of arrival in the United States. An individual
An individual who is a resident of Thailand on Venezuela
the date of arrival in the United States and who
is entitled to these benefits only once. However,
is in the United States for not longer than 2 An individual who is a resident of Venezuela on
these benefits, and the benefits described later
years primarily to teach or engage in research the date of arrival in the United States and who
under Students and Apprentices cannot be
at a university, college, school, or other recog­ temporarily visits the United States to teach or
claimed either simultaneously or consecutively.
nized educational institution is exempt from engage in research at a recognized educational

Page 18 Publication 901 (September 2016)


or research institution is exempt from U.S. in­ and who is temporarily present in the United Bulgaria
come tax on the income received for the teach­ States for the primary purpose of:
ing or research for not more than 2 years from A student or business trainee who is a resident
1. Studying at a university, college, school,
the date of arrival in the United States. This of Bulgaria immediately before visiting the Uni­
or other recognized educational institution
benefit can be claimed for no more than 5 ted States and is in the United States for the
in the United States,
years. purpose of full­time education at a college, uni­
2. Securing training as a business or techni­ versity, or other recognized educational institu­
The exemption does not apply to income cal apprentice, or tion of a similar nature, or full­time training is ex­
from research carried on mainly for the private empt from U.S. income tax on the following
3. Studying or doing research as a recipient
benefit of any person rather than in the public amounts.
of a grant, allowance, or award from a
interest. Payments received from abroad for main­
governmental, religious, charitable, or ed­
tenance, education, or training.
ucational organization
Income from personal services of up to
Students and Apprentices is exempt from U.S. tax on the following $9,000 for each tax year.
amounts.
Residents of the following countries who are in The payments from abroad for the purpose An apprentice or a business trainee is enti­
the United States to study or acquire technical of maintenance, education, or training. tled to the benefit of this exemption for a maxi­
experience are exempt from U.S. income tax, The grant, allowance, or award. mum period of 2 years.
under certain conditions, on amounts received The income from personal services per­
from abroad for their maintenance and studies. formed in the United States of up to $8,000 For this purpose, a business trainee is an in­
for the tax year. dividual who is temporarily in the United States:
This exemption does not apply to the salary To secure training to practice a profession
paid by a foreign corporation to one of its exec­ or professional specialty, or
utives, a citizen and resident of a foreign coun­ For an individual described in (2), the ex­
emption from tax applies for not more than 2 As an employee of, or under contract with,
try who is temporarily in the United States to a resident of Bulgaria, for the primary pur­
study a particular industry for an employer. That years from the date the individual first arrived in
the United States. pose of acquiring technical, professional,
amount is a continuation of salary and is not re­ or business experience from a person
ceived to study or acquire experience. other than that resident of Bulgaria or other
Barbados than a person related to that resident.
For each country listed there is a statement
of the conditions under which the exemption A student or business apprentice who is a resi­
applies to students and apprentices from that dent of Barbados on the date of arrival in the Canada
country. United States and is here for full­time education
or training is exempt from U.S. income tax on A student, business trainee, or apprentice who
Amounts received from the National Insti­ payments received from outside the United is or was a Canadian resident immediately be­
tutes of Health (NIH) under provisions of the States for the individual's maintenance, educa­ fore visiting the United States, and is in the Uni­
Visiting Fellows Program are generally treated tion, or training. ted States for the purpose of full­time education
as a grant, allowance, or award for purposes of or full­time training, is exempt from U.S. income
whether an exemption is provided by treaty. tax on amounts received from sources outside
Nevertheless, an individual who qualifies for
Amounts received from NIH under the Visiting the United States for maintenance, education,
this exemption may instead choose to be
Associate Program and Visiting Scientist Pro­ or training.
treated as a resident alien of the United States
gram are not exempt from U.S. tax as a grant,
for all U.S. income tax purposes. Once made,
allowance, or award. Apprentices and business trainees are enti­
this choice applies for the entire period that the
tled to the benefit of this exemption for a maxi­
individual remains qualified for exemption and
mum period of 1 year.
Australia may not be revoked without the permission of
the U.S. competent authority.
A resident of Australia or an individual who was Also see Publication 597, Information on the
a resident of Australia immediately before visit­ United States–Canada Income Tax Treaty.
ing the United States who is temporarily here for
Belgium
full­time education is exempt from U.S. income
A student or business trainee who is a resident
China, People's Republic of
tax on payments received from outside the Uni­
of Belgium immediately before visiting the Uni­
ted States for the individual's maintenance or A student, business apprentice, or trainee who
ted States and is in the United States for the
education. is a resident of the People's Republic of China
purpose of full­time education or training is ex­
on the date of arrival in the United States and
empt from U.S. income tax on the following
who is present in the United States solely to ob­
Austria amounts.
tain training, education, or special technical ex­
Payments received from abroad for main­
A student, apprentice, or business trainee who perience is exempt from U.S. income tax on the
tenance, education, or training.
is a resident of Austria immediately before visit­ following amounts.
Income from personal services of up to
ing the United States and is in the United States Payments received from abroad for main­
$9,000 for each tax year.
for the purpose of full­time education at a recog­ tenance, education, study, research, or
nized educational institution or full­time training training.
An apprentice or a business trainee is enti­ Grants or awards from a government, sci­
is exempt from U.S. income tax on amounts re­ tled to the benefit of this exemption for a maxi­
ceived from sources outside the United States entific, educational, or other tax­exempt or­
mum period of 2 years. ganization.
for the individual's maintenance, education, or
training. Income from personal services performed
For this purpose, a business trainee is an in­ in the United States of up to $5,000 for
dividual who is temporarily in the United States: each tax year.
Apprentices and business trainees are enti­ To secure training to practice a profession
tled to the benefit of this exemption for a maxi­ or professional specialty, or An individual is entitled to this exemption
mum period of 3 years. As an employee of, or under contract with, only for the time reasonably necessary to com­
a resident of Belgium, for the primary pur­ plete the education or training.
Bangladesh pose of acquiring technical, professional,
or business experience from a person
An individual who is a resident of Bangladesh other than that resident of Belgium or other
immediately before visiting the United States than a person related to that resident.

Publication 901 (September 2016) Page 19


Commonwealth of on income from personal services for a maxi­ of income from personal services for that train­
Independent States (C.I.S.) mum of $7,500 if the individual is in the United ing, research, or study.
States primarily to either:
An individual who is a resident of a C.I.S. mem­ Acquire technical, professional, or busi­ These exemptions do not apply to income
ber and who is temporarily in the United States ness experience from a person other than from research undertaken primarily for the pri­
primarily to study at an educational or scientific a resident of Cyprus or other than a person vate benefit of a specific person or persons.
research institution or to obtain training for qual­ related to that resident, or
ification in a profession or specialty is exempt Study at a university or other recognized
from U.S. income tax on amounts received as educational institution. Denmark
stipends, scholarships, or other substitute al­
A student, apprentice, or business trainee who
lowances necessary to provide ordinary living An individual who is a resident of Cyprus on is a resident of Denmark immediately before
expenses. An individual is entitled to the benefit the date of arrival in the United States and who visiting the United States and is in the United
of this exemption for a maximum of 5 years and is temporarily here for a period of not more than States for the purpose of full­time education at
for less than $10,000 in each tax year. 1 year as a participant in a program sponsored an accredited educational institution, or full­time
by the U.S. Government primarily to train, re­ training, is exempt from U.S. income tax on
An individual who is a resident of a C.I.S. search, or study is exempt from U.S. income tax amounts received from sources outside the Uni­
member and who is temporarily in the United on income for personal services for the training, ted States for the individual's maintenance, ed­
States primarily to acquire technical, professio­ research, or study. This exemption is limited to ucation, or training.
nal, or commercial experience or perform tech­ $10,000.
nical services and who is an employee of, or
under contract with, a resident of a C.I.S. mem­ Apprentices and business trainees are enti­
ber is exempt from U.S. income tax on the
Czech Republic tled to the benefit of this exemption for a maxi­
amounts received from that resident. Also ex­ mum period of 3 years.
An individual who is a resident of the Czech Re­
empt is an amount received from U.S. sources, public at the beginning of his or her visit to the
of not more than $10,000, that is necessary to United States and who is temporarily present in The exemption does not apply to income
provide for ordinary living expenses. The ex­ the United States is exempt from U.S. income from research undertaken primarily for the pri­
emption contained in this paragraph is limited to tax on certain amounts for a period of up to 5 vate benefit of a specific person or persons.
1 year. years. To be entitled to the exemption, the indi­
vidual must be in the United States for the pri­ Egypt
An individual who is a resident of a C.I.S.
mary purpose of:
member and who is temporarily present in the An individual who is a resident of Egypt on the
Studying at a university or other accredited
United States under an exchange program pro­ date of arrival in the United States and who is
educational institution in the United States,
vided for by an agreement between govern­ temporarily in the United States primarily to
Obtaining training required to qualify him or
ments on cooperation in various fields of sci­ study at a university or other recognized educa­
her to practice a profession or professional
ence and technology is exempt from U.S. tional institution in the United States, obtain pro­
specialty, or
income tax on all income received in connec­ fessional training, or study or do research as a
Studying or doing research as a recipient
tion with the exchange program for a period not recipient of a grant, allowance, or award from a
of a grant, allowance, or award from a gov­
longer than 1 year. governmental, religious, charitable, scientific,
ernmental, religious, charitable, scientific,
literary, or educational organization. literary, or educational organization is exempt
Cyprus from U.S. income tax on the following amounts.
If the individual meets any of these require­
Gifts from abroad for maintenance, educa­
An individual who is a resident of Cyprus on the ments, the following amounts are exempt from
tion, study, research, or training.
date of arrival in the United States and who is U.S. tax.
The grant, allowance, or award.
temporarily here primarily to study at a univer­ The payments from abroad, other than
Income from personal services performed
sity or other recognized educational institution compensation for personal services, for
in the United States of up to $3,000 each
in the United States, obtain professional train­ the purpose of maintenance, education,
tax year.
ing, or study or do research as a recipient of a study, research, or training.
grant, allowance, or award from a governmen­ The grant, allowance, or award.
The income from personal services per­ An individual is entitled to the benefit of this
tal, religious, charitable, scientific, literary, or exemption for a maximum of 5 tax years and for
educational organization is exempt from U.S. formed in the United States of up to $5,000
for the tax year. any additional period of time needed to com­
income tax on the following amounts. plete, as a full­time student, educational re­
Gifts from abroad for maintenance, educa­ quirements as a candidate for a postgraduate
tion, or training. An individual who is a Czech resident at the
beginning of the visit to the United States and or professional degree from a recognized edu­
The grant, allowance, or award. cational institution.
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
each tax year. Czech resident is exempt from U.S. income tax An individual who is a resident of Egypt on
for a period of 12 consecutive months on up to the date of arrival in the United States and who
An individual is entitled to this exemption for $8,000 received for personal services if the indi­ is temporarily in the United States as an em­
up to 5 tax years and for an additional period as vidual is in the United States primarily to: ployee of, or under contract with, a resident of
is necessary to complete, as a full­time student, Acquire technical, professional, or busi­ Egypt is exempt from U.S. income tax for a pe­
educational requirements for a postgraduate or ness experience from a person other than riod of 12 consecutive months on up to $7,500
professional degree from a recognized educa­ the Czech resident, or received for personal services if the individual is
tional institution. Study at a university or other accredited in the United States primarily to:
educational institution in the United States. Acquire technical, professional, or busi­
An individual who is a resident of Cyprus on ness experience from a person other than
the date of arrival in the United States and who An individual who is a Czech resident at the that resident of Egypt or other than a per­
is temporarily here as an employee of, or under time he or she becomes temporarily present in son related to that resident, or
contract with, a resident of Cyprus is exempt the United States and who is temporarily Study at a university or other educational
from U.S. income tax for not more than 1 year present in the United States for a period not lon­ institution.
ger than 1 year as a participant in a program
sponsored by the U.S. Government for the pri­ An individual who is a resident of Egypt on
mary purpose of training, research, or study is the date of arrival in the United States and who
exempt from U.S. income tax on up to $10,000 is temporarily in the United States for no more

Page 20 Publication 901 (September 2016)


than 1 year as a participant in a program spon­ study at a university or other recognized educa­ or by a nonprofit religious, charitable, scientific,
sored by the U.S. Government primarily to train, tional institution in the United States, obtain pro­ literary, or educational organization is exempt
research, or study is exempt from U.S. income fessional training, or study, or do research as a from U.S. tax on compensation paid by the em­
tax on income received for personal services for recipient of a grant, allowance, or award from a ployer from outside the United States if:
the training, research, or study for a maximum not­for­profit governmental, religious, charita­ The individual is temporarily in the United
of $10,000. ble, scientific, artistic, cultural, or educational States for not more than 1 year to acquire
organization is exempt from U.S. income tax on technical, professional, or business experi­
Estonia the following amounts. ence from any person other than his or her
Gifts from abroad for maintenance, educa­ employer, and
An individual who is a resident of Estonia on the tion, study, research, or training. The compensation is not more than
date of arrival in the United States and who is The grant, allowance, or award. $10,000.
temporarily in the United States primarily to Income from personal services performed If the compensation is more than $10,000, none
study at a university or other accredited educa­ in the United States of up to $5,000 each of the income is exempt.
tional institution in the United States, obtain pro­ tax year.
fessional training, or study or do research as a
recipient of a grant, allowance, or award from a An individual is entitled to this benefit and Greece
governmental, religious, charitable, scientific, the benefit described earlier under Professors,
Teachers, and Researchers for a maximum of 5 A student or business apprentice who is a resi­
literary, or educational organization is exempt
tax years. dent of Greece and is temporarily in the United
from U.S. income tax on the following amounts. States only to study or acquire business experi­
Payments from abroad, other than com­
This exemption does not apply to income ence is exempt from U.S. income tax on
pensation for personal services, for main­
from research carried on mainly for the private amounts received from sources outside the Uni­
tenance, education, study, research, or
benefit of any person rather than in the public ted States for maintenance or studies.
training.
The grant, allowance, or award. interest.
Income from personal services performed Hungary
in the United States of up to $5,000 for An individual who is a resident of France on
each tax year. the date of arrival in the United States and who An individual who is a resident of Hungary im­
is in the United States as an employee of, or un­ mediately before arrival in the United States
An individual is entitled to the benefit of this der contract with, a resident of France is ex­ and is here for full­time education or training is
exemption for a maximum of 5 years. empt from U.S. income tax for a period of 12 exempt from U.S. income tax on payments re­
consecutive months on up to $8,000 received ceived from outside the United States for the in­
for personal services if the individual is in the dividual's maintenance, education, or training.
An individual who is a resident of Estonia on
United States primarily to:
the date of arrival in the United States and who
Acquire technical, professional, or busi­ The full­time student or trainee may instead
is in the United States as an employee of, or un­
ness experience from a person other than choose to be treated as a resident alien of the
der contract with, a resident of Estonia is ex­
that resident of France, or United States for U.S. income tax purposes.
empt from U.S. income tax for a period of 12
Study at an educational institution. Once made, the choice applies for the entire
consecutive months on up to $8,000 received
period that the individual remains qualified for
for personal services if the individual is in the
Germany exemption as a full­time student or trainee and
United States primarily to:
may not be changed unless permission is ob­
Acquire technical, professional, or busi­
A student or business apprentice (including Vo­ tained from the U.S. competent authority.
ness experience from a person other than
that resident of Estonia, or lontaere and Praktikanten) who is or was imme­
Study at an educational institution. diately before visiting the United States a resi­ Iceland
dent of Germany and who is present in the
An individual who is a resident of Estonia on United States for full­time education or training An individual who is a resident of Iceland on the
the date of arrival in the United States and who is exempt from U.S. income tax on amounts date of arrival in the United States and who is
is temporarily present in the United States for from sources outside the United States for temporarily in the United States primarily to
not longer than 1 year as a participant in a pro­ maintenance, education, or training. study at a university or other recognized educa­
gram sponsored by the U.S. Government pri­ tional institution in the United States, obtain pro­
marily to train, research, or study is exempt An individual who is or was immediately be­ fessional training, or study or do research as a
from U.S. income tax on income received for fore visiting the United States a resident of Ger­ recipient of a grant, allowance, or award from a
personal services for the training, research, or many is exempt from U.S. tax on amounts re­ governmental, religious, charitable, scientific,
study in the amount of $10,000. ceived as a grant, allowance, or award from a literary, or educational organization is exempt
nonprofit religious, charitable, scientific, literary, from U.S. income tax on the following amounts.
These provisions do not apply to income or educational organization. Gifts from abroad for maintenance, educa­
from research carried on mainly for the private tion, study, research, or training.
Individuals described in the previous two The grant, allowance, or award.
benefit of any person rather than in the public
paragraphs are also exempt from U.S. tax on Income from personal services performed
interest.
compensation for dependent personal services in the United States of up to $9,000 each
of up to $9,000 per year if: tax year.
Finland They are present in the United States for
not more than 4 years, and An individual is entitled to the benefit of this
A full­time student, trainee, or business appren­ The services are performed for the pur­ exemption for a maximum of 5 years.
tice who is a resident of Finland immediately pose of supplementing funds available oth­
before visiting the United States is exempt from erwise for maintenance, education, or An individual who is a resident of Iceland on
U.S. income tax on amounts received from training. the date of arrival in the United States and who
sources outside the United States for mainte­ is temporarily in the United States as an em­
nance, education, or training. If the individual's visit exceeds 4 years, the ployee of, or under contract with, a resident of
exemption is lost for the entire visit unless the Iceland is exempt from U.S. income tax for a
France competent authorities of Germany and the Uni­ period of 12 consecutive months on up to
ted States agree otherwise. $9,000 received for personal services if the indi­
An individual who is a resident of France on the vidual is in the United States primarily to:
date of arrival in the United States and who is An individual who is a resident of Germany Acquire technical, professional, or busi­
temporarily in the United States primarily to and who is employed by a German enterprise ness experience from a person other than

Publication 901 (September 2016) Page 21


that resident of Iceland or other than a per­ An individual who is a resident of Indonesia Italy
son related to that person, or immediately before visiting the United States
Study at a university or other educational and is temporarily in the United States only as a A student or business apprentice (trainee) who
institution. business or technical apprentice is exempt from is a resident of Italy immediately before the date
U.S. income tax for a period of 12 consecutive of arrival in the United States and who is
An individual who is a resident of Iceland on months on up to $7,500 received for personal present in the United States only for education
the date of arrival in the United States and who services. or training at a recognized educational institu­
is temporarily present in the United States for tion is exempt from U.S. income tax on amounts
not longer than 1 year as a participant in a pro­ Ireland received from outside the United States for
gram sponsored by the U.S. Government pri­ maintenance, education, and training.
marily to train, research, or study is exempt A student, apprentice, or business trainee who
from U.S. income tax on income received for is a resident of Ireland immediately before visit­ Jamaica
personal services for the training, research, or ing the United States and is in the United States
study for a maximum of $9,000. for the purpose of full­time education at a recog­ A student who is a resident of Jamaica on the
nized educational institution or full­time training date of arrival in the United States and is here
India is exempt from U.S. income tax on amounts re­ for full­time education or training is exempt from
ceived from sources outside the United States U.S. income tax on payments received from
An individual who is a resident of India immedi­ for the individual's maintenance, education, or outside the United States for the student's
ately before visiting the United States and who training. maintenance, education, or training.
is temporarily in the United States primarily for
studying or training is exempt from U.S. income Apprentices and business trainees are enti­ An individual who is a resident of Jamaica
tax on payments from abroad for maintenance, tled to the benefit of this exemption for a maxi­ on the date of arrival in the United States and
study, or training. The exemption does not ap­ mum period of 1 year. who is temporarily in the United States as an
ply to payments borne by a permanent estab­ employee of, or under contract with, a resident
lishment in the United States or paid by a U.S. Israel of Jamaica is exempt from U.S. income tax for a
citizen or resident, the U.S. Government, or any period of 12 consecutive months on up to
of its agencies, instrumentalities, political subdi­ An individual who is a resident of Israel on the $7,500 of net income from personal services if
visions, or local authorities. 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 Acquire technical, professional, or busi­
Under the treaty, if the payments are not ex­ study at a university or other recognized educa­ ness experience from a person other than
empt under the rule described above, an indi­ tional institution in the United States, obtain pro­ that resident of Jamaica or other than a
vidual described in the previous paragraph may fessional training, or study or do research as a person related to that resident, or
be eligible to deduct exemptions for his or her recipient of a grant, allowance, or award from a Study at a university or other recognized
spouse and dependents and the standard de­ governmental, religious, charitable, scientific, educational institution.
duction. The individual must file Form 1040NR literary, or educational organization is exempt
or Form 1040NR­EZ to claim these amounts. from U.S. income tax on the following amounts. An individual who qualifies for one of the ex­
For information on how to claim these amounts, Gifts from abroad for maintenance, educa­ emptions discussed above may instead choose
see chapter 5 in Publication 519. tion, study, research, or training. to be treated as a resident alien of the United
The grant, allowance, or award. States for all U.S. income tax purposes. Once
The individual is entitled to these benefits Income from personal services performed made, the choice applies for the entire period
only for a period of time considered reasonable in the United States of up to $3,000 each that the individual remains qualified for exemp­
or customarily required to complete studying or tax year. tion and may not be revoked unless permission
training. is obtained from the U.S. competent authority.
An individual is entitled to the benefit of this
Indonesia exemption for a maximum of 5 tax years. Japan
An individual who is a resident of Indonesia im­ An individual who is a resident of Israel on A student or business apprentice who is a resi­
mediately before visiting the United States and the date of arrival in the United States and who dent of Japan immediately before visiting the
who is temporarily in the United States is ex­ is temporarily in the United States as an em­ United States and is in the United States for the
empt from U.S. income tax on certain amounts ployee of, or under contract with, a resident of purpose of education or training is exempt from
for a period of up to 5 years. To be entitled to Israel is exempt from U.S. income tax for a pe­ U.S. income tax on amounts received from
the exemption, the individual must be tempora­ riod of 12 consecutive months on up to $7,500 abroad for the individual's maintenance, educa­
rily in the United States for full­time study at a received for personal services if the individual is tion, or training.
U.S. university, school, or other recognized ed­ in the United States primarily to:
ucational institution, or for full­time study, re­ Acquire technical, professional, or busi­
Business apprentices are entitled to the
search, or training as a recipient of a grant, al­ ness experience from a person other than
benefit of this exemption for a maximum period
lowance, or award from either the U.S. or that resident of Israel or other than a per­
of 1 year.
Indonesian Government, a scientific, educa­ son related to that resident, or
tional, religious, or charitable organization, or Study at a university or other educational
under a technical assistance program entered institution. Kazakhstan
into by either the U.S. or Indonesian Govern­
ment. If the individual meets any of these re­ An individual who is a resident of Israel on An individual who is a resident of Kazakhstan at
quirements, the following amounts are exempt the date of arrival in the United States and who the beginning of his or her visit to the United
from tax. is temporarily in the United States for no more States is exempt from U.S. tax on payments
All payments from abroad for mainte­ than 1 year as a participant in a program spon­ from abroad for maintenance, education, study,
nance, education, study, research, or train­ sored by the U.S. Government primarily to train, research, or training and on any grant, allow­
ing. research, or study is exempt from U.S. income ance, or other similar payments. To be entitled
The grant, allowance, or award. tax on income received for personal services for to the exemption, the individual must be tempo­
Income from personal services performed the training, research, or study for a maximum rarily present in the United States primarily to:
in the United States of up to $2,000 each of $10,000. Study at a university or other accredited
tax year. educational institution,
Obtain training required to qualify him or
her to practice a profession or professional
specialty, or,

Page 22 Publication 901 (September 2016)


Study or do research as a recipient of a literary, or educational organization is exempt for personal services if the individual is in the
grant, allowance, or other similar payments from U.S. income tax on the following amounts. United States primarily to:
from a governmental, religious, charitable, Payments from abroad, other than com­ Acquire technical, professional, or busi­
scientific, literary, or educational organiza­ pensation for personal services, for main­ ness experience from a person other than
tion. tenance, education, study, research, or that resident of Lithuania, or
training. Study at an educational institution.
The individual is entitled to this exemption The grant, allowance, or award.
only for a period of time necessary to complete Income from personal services performed An individual who is a resident of Lithuania
the study, training, or research, but the exemp­ in the United States of up to $5,000 for on the date of arrival in the United States and
tion for training or research may not extend for a each tax year. who is temporarily present in the United States
period exceeding 5 years. for not longer than 1 year as a participant in a
An individual is entitled to the benefit of this program sponsored by the U.S. Government
exemption for a maximum of 5 years. primarily to train, research, or study is exempt
These exemptions do not apply to income from U.S. income tax on income received for
from research if it is undertaken primarily for the personal services for the training, research, or
private benefit of a specific person or persons. An individual who is a resident of Latvia on study in the amount of $10,000.
the date of arrival in the United States and who
Korea, South is in the United States as an employee of, or un­ These provisions do not apply to income
der contract with, a resident of Latvia is exempt from research carried on mainly for the private
An individual who is a resident of South Korea from U.S. income tax for a period of 12 consec­ benefit of any person rather than in the public
on the date of arrival in the United States and utive months on up to $8,000 received for per­ interest.
who is temporarily in the United States primarily sonal services if the individual is in the United
to study at a university or other recognized edu­ States primarily to:
Acquire technical, professional, or busi­ Luxembourg
cational institution in the United States, obtain
professional training, or study or do research as ness experience from a person other than
that resident of Latvia, or A student, apprentice, or business trainee who
a recipient of a grant, allowance, or award from is a resident of Luxembourg immediately before
a governmental, religious, charitable, scientific, Study at an educational institution.
visiting the United States and is in the United
literary, or educational organization is exempt States for the purpose of full­time education at a
from U.S. income tax on the following amounts. An individual who is a resident of Latvia on recognized educational institution or full­time
Amounts from abroad for maintenance, ed­ the date of arrival in the United States and who training is exempt from U.S. income tax on
ucation, study, research, or training. is temporarily present in the United States for amounts received for the individual's mainte­
The grant, allowance, or award. not longer than 1 year as a participant in a pro­ nance, education, or training.
Income from personal services performed gram sponsored by the U.S. Government pri­
in the United States of up to $2,000 each marily to train, research, or study is exempt Apprentices and business trainees are enti­
tax year. from U.S. income tax on income received for tled to the benefit of this exemption for a maxi­
personal services for the training, research, or mum period of 2 years.
An individual is entitled to the benefit of this study in the amount of $10,000.
exemption for a maximum of 5 years. If the individual's visit to the United States is
These provisions do not apply to income longer than 2 years, the exemption is lost for the
An individual who is a resident of Korea on from research carried on mainly for the private entire visit unless the competent authorities of
the date of arrival in the United States and who benefit of any person rather than in the public Luxembourg and the United States agree other­
is temporarily in the United States as an em­ interest. wise.
ployee of, or under contract with, a resident of
Korea is exempt from U.S. income tax for 1 year Lithuania Malta
on up to $5,000 received for personal services
if the individual is in the United States primarily An individual who is a resident of Lithuania on A student or business trainee, who is a resident
to: the date of arrival in the United States and who of Malta immediately before visiting the United
Acquire technical, professional, or busi­ is temporarily in the United States primarily to States and is in the United States for the pur­
ness experience from a person other than study at a university or other accredited educa­ pose of full­time education or training, is exempt
that resident of Korea or other than a per­ tional institution in the United States, obtain pro­ from U.S. income tax on the following amounts.
son related to that resident, or fessional training, or study or do research as a Payments received from sources outside
Study at an educational institution. recipient of a grant, allowance, or award from a the United States for the individual's main­
governmental, religious, charitable, scientific, tenance, education, or training. Apprenti­
An individual who is a resident of Korea on literary, or educational organization is exempt ces and business trainees are entitled to
the date of arrival in the United States and who from U.S. income tax on the following amounts. this benefit for a maximum period of 1
is temporarily present in the United States for Payments from abroad, other than com­ year.
not longer than 1 year as a participant in a pro­ pensation for personal services, for main­ Income from personal services performed
gram sponsored by the U.S. Government pri­ tenance, education, study, research, or in the United States of up to $9,000 for
marily to train, research, or study is exempt training. each tax year.
from U.S. income tax on income received for The grant, allowance, or award.
personal services for the training, research, or Income from personal services performed Mexico
study for a maximum of $10,000. in the United States of up to $5,000 for
each tax year. A student or business apprentice who is a resi­
Latvia dent of Mexico immediately before visiting the
An individual is entitled to the benefit of this United States and is in the United States solely
An individual who is a resident of Latvia on the exemption for a maximum of 5 years. for the purpose of education or training is ex­
date of arrival in the United States and who is empt from U.S. tax on amounts received from
temporarily in the United States primarily to An individual who is a resident of Lithuania sources outside the United States for the indi­
study at a university or other accredited educa­ on the date of arrival in the United States and vidual's maintenance, education, or training.
tional institution in the United States, obtain pro­ who is in the United States as an employee of,
fessional training, or study or do research as a or under contract with, a resident of Lithuania is
recipient of a grant, allowance, or award from a exempt from U.S. income tax for a period of 12
governmental, religious, charitable, scientific, consecutive months on up to $8,000 received

Publication 901 (September 2016) Page 23


Morocco United States for full­time education is exempt they are under contract. To qualify for this ex­
from U.S. income tax on amounts received from emption, they must be employees of, or under
An individual who is a resident of Morocco on abroad for maintenance or education. contract with, a Pakistani enterprise or religious,
the date of arrival in the United States and who charitable, scientific, or educational organiza­
is temporarily in the United States primarily to Norway tion and be in the United States only to acquire
study at a university or other recognized educa­ technical, professional, or business experience
tional institution in the United States, obtain pro­ An individual who is a resident of Norway on the from a person other than that enterprise or or­
fessional training, or study or do research as a date of arrival in the United States and who is ganization.
recipient of a grant, allowance, or award from a temporarily in the United States primarily to
governmental, religious, charitable, scientific, study at a university or other recognized educa­ Also exempt from U.S. income tax on cer­
literary, or educational organization is exempt tional institution in the United States, obtain pro­ tain income are residents of Pakistan tempora­
from U.S. income tax on the following amounts. fessional training, or study or do research as a rily in the United States under an arrangement
Gifts from abroad for maintenance, educa­ recipient of a grant, allowance, or award from a with the U.S. Government, or any of its agen­
tion, study, research, or training. governmental, religious, charitable, scientific, cies or instrumentalities, only for study, training,
The grant, allowance, or award. literary, or educational organization is exempt or orientation. They are exempt from tax on in­
Income from personal services performed from U.S. income tax on the following amounts. come of not more than $10,000 for services di­
in the United States of up to $2,000 each Gifts from abroad for maintenance, educa­ rectly related to their training, study, or orienta­
tax year. tion, study, research, or training. tion, including income from their employer
The grant, allowance, or award. abroad.
An individual is entitled to the benefit of this Income from personal services performed
exemption for a maximum of 5 years. in the United States of up to $2,000 each Philippines
tax year.
Netherlands An individual who is a resident of the Philip­
An individual is entitled to the benefit of this pines on the date of arrival in the United States
An individual who immediately before visiting exemption for a maximum of 5 tax years. and who is temporarily in the United States pri­
the United States is a resident of the Nether­ marily to study at a university or other recog­
lands and who is present in the United States An individual who is a resident of Norway on nized educational institution in the United
primarily for full­time study at a recognized uni­ the date of arrival in the United States and who States, obtain professional training, or study or
versity, college, or school or securing training is in the United States as an employee of, or un­ do research as a recipient of a grant, allowance,
as a business apprentice is exempt from U.S. der contract with, a resident of Norway is ex­ or award from a governmental, religious, chari­
income tax on the following amounts. empt from U.S. income tax for a period of 12 table, scientific, literary, or educational organi­
Payments from abroad for maintenance, consecutive months on up to $5,000 received zation is exempt from U.S. income tax on the
education, or training. for personal services if the individual is in the following amounts.
Income from personal services performed United States primarily to: Gifts from abroad for maintenance, educa­
in the United States of up to $2,000 each Acquire technical, professional, or busi­ tion, study, research, or training.
tax year. ness experience from a person other than The grant, allowance, or award.
that resident of Norway or other than a per­ Income from personal services performed
The individual is entitled to this exemption son related to that resident of Norway, or in the United States of up to $3,000 each
only for a period of time considered reasonable Study at an educational institution. tax year.
or customarily required to complete studying or
training. An individual is entitled to the benefit of this
Also exempt is a resident of Norway who is
exemption for a maximum of 5 years.
present in the United States for not longer than
An individual who immediately before visit­ 1 year as a participant in a program sponsored
ing the United States is a resident of the Nether­ by the Government of the United States primar­ An individual who is a resident of the Philip­
lands and is temporarily present in the United ily to train, research, or study. The individual is pines on the date of arrival in the United States
States for a period not exceeding 3 years for exempt from tax on income from personal serv­ and who is temporarily in the United States as
the purpose of study, research, or training ices performed in the United States and re­ an employee of, or under contract with, a resi­
solely as a recipient of a grant, allowance, or ceived for the training, research, or study, for a dent of the Philippines is exempt from U.S. in­
award from a scientific, educational, religious, maximum of $10,000. come tax for a period of 12 consecutive months
or charitable organization or under a technical on up to $7,500 received for personal services
assistance program entered into by either the if the individual is in the United States primarily
Netherlands or the United States, or its political Pakistan to:
subdivisions or local authorities is exempt from Acquire technical, professional, or busi­
U.S. income tax on the following amounts. Residents of Pakistan temporarily in the United ness experience from a person other than
The amount of the grant, allowance, or States are exempt from U.S. income tax on cer­ that resident of the Philippines or other
award. tain income they may receive. To be entitled to than a person related to that resident, or
Income of up to $2,000 for personal serv­ this exemption, they must be in the United Study at an educational institution.
ices performed in the United States for any States only as students at a recognized univer­
tax year if the services are connected with, sity, college, or school, or as recipients of
An individual who is a resident of the Philip­
or incidental to, the study, research, or grants, allowances, or awards from religious,
pines on the date of arrival in the United States,
training. charitable, scientific, or educational organiza­
and who is temporarily in the United States (for
tions of Pakistan primarily to study or research.
no more than 1 year as a participant in a pro­
The income exempt in these cases is any pay­
An individual is not entitled to these exemp­ gram sponsored by the U.S. Government) pri­
ment from abroad for maintenance, education,
tions if, during the immediately preceding pe­ marily to train, research, or study is exempt
or training, and any pay for personal services of
riod, the individual claimed the exemption dis­ from U.S. income tax on income received for
not more than $5,000 for any tax year.
cussed earlier under Professors, Teachers, and personal services for the training, research, or
Researchers. study, up to a maximum of $10,000.
Other residents of Pakistan who are tempo­
rarily in the United States for no more than 1
New Zealand year are exempt from U.S. income tax on pay of Poland
not more than $6,000 received for that period,
A resident of New Zealand or an individual who An individual who is a resident of Poland on the
including pay from the enterprise or organiza­
was a resident of New Zealand immediately be­ date of arrival in the United States and who is
tion of which they are employees or with which
fore visiting the United States who is in the temporarily in the United States primarily to

Page 24 Publication 901 (September 2016)


study at a university or other recognized educa­ or under contract with, a resident of Portugal is from a governmental, religious, charitable,
tional institution in the United States, obtain pro­ exempt from U.S. income tax for a period of 12 scientific, literary, or educational organiza­
fessional training, or study or do research as a consecutive months on up to $8,000 received tion.
recipient of a grant, allowance, or award from a for personal services if the individual is in the
governmental, religious, charitable, scientific, United States primarily to: The individual is entitled to this exemption
literary, or educational organization is exempt Acquire technical, professional, or busi­ only for a period of time necessary to complete
from U.S. income tax on the following amounts. ness experience from a person other than the study, training, or research, but the exemp­
Gifts from abroad for maintenance, educa­ that resident of Portugal, or tion for training or research may not extend for a
tion, study, research, or training. Study at an educational institution. period exceeding 5 years.
The grant, allowance, or award.
Any other payments received from Poland, Romania These exemptions do not apply to income
except income from performing personal from research if it is undertaken primarily for the
services. An individual who is a resident of Romania on private benefit of a specific person or persons.
Income from personal services performed the date of arrival in the United States and who
in the United States of up to $2,000 each is temporarily in the United States primarily to
tax year.
Slovak Republic
study at a university or other recognized educa­
tional institution in the United States, obtain pro­ An individual who is a resident of the Slovak
An individual is entitled to the benefit of this fessional training, or study or do research as a Republic at the beginning of his or her visit to
exemption for a maximum of 5 years. recipient of a grant, allowance, or award from a the United States and who is temporarily
governmental, religious, charitable, scientific, present in the United States is exempt from
An individual who is a resident of Poland on literary, or educational organization is exempt U.S. income tax on certain amounts for a period
the date of arrival in the United States and who from U.S. income tax on the following amounts. of up to 5 years. To be entitled to the exemp­
is temporarily in the United States as an em­ Gifts from abroad for maintenance, educa­ tion, the individual must be in the United States
ployee of, or under contract with, a resident of tion, study, research, or training. for the primary purpose of:
Poland is exempt from U.S. income tax for 1 The grant, allowance, or award. Studying at a university or other accredited
year on up to $5,000 received for personal serv­ Income from personal services performed educational institution in the United States,
ices if the individual is in the United States pri­ in the United States of up to $2,000 each Obtaining training required to qualify him or
marily to: tax year. her to practice a profession or professional
Acquire technical, professional, or busi­
specialty, or
ness experience from a person other than
An individual is entitled to the benefit of this Studying or doing research as a recipient
that resident of Poland or other than a per­
exemption for a maximum of 5 years. of a grant, allowance, or award from a gov­
son related to that resident, or
ernmental, religious, charitable, scientific,
Study at an educational institution.
An individual who is a resident of Romania literary, or educational organization.
An individual who is a resident of Poland on on the date of arrival in the United States and If the individual meets any of these require­
the date of arrival in the United States and who who is temporarily in the United States as an ments, the following amounts are exempt from
is temporarily in the United States for not longer employee of, or under contract with, a resident U.S. tax.
than 1 year as a participant in a program spon­ of Romania is exempt from U.S. income tax for The payments from abroad, other than
sored by the U.S. Government primarily to train, 1 year on up to $5,000 received for personal compensation for personal services, for
research, or study is exempt from U.S. income services if the individual is in the United States the purpose of maintenance, education,
tax on up to $10,000 of income received for per­ primarily to: study, research, or training.
sonal services for the training, research, or Acquire technical, professional, or busi­ The grant, allowance, or award.
study. ness experience from a person other than The income from personal services per­
that resident of Romania or other than a formed in the United States of up to $5,000
person related to that resident, or for the tax year.
Portugal Study at an educational institution.
An individual who is a resident of Portugal on An individual who is a Slovak resident at the
the date of arrival in the United States and who An individual who is a resident of Romania beginning of the visit to the United States and
is temporarily in the United States primarily to on the date of arrival in the United States and who is temporarily present in the United States
study at a university or other accredited educa­ who is temporarily in the United States for not as an employee of, or under contract with, a
tional institution in the United States, obtain pro­ longer than 1 year as a participant in a program Slovak resident is exempt from U.S. income tax
fessional training, or study, or do research as a sponsored by the U.S. Government primarily to for a period of 12 consecutive months on up to
recipient of a grant, allowance, or award from a train, research, or study is exempt from U.S. in­ $8,000 received from personal services if the
governmental, religious, charitable, scientific, come tax on up to $10,000 of income received individual is in the United States primarily to:
literary, or educational organization is exempt for personal services for the training, research, Acquire technical, professional, or busi­
from U.S. income tax on the following amounts. or study. ness experience from a person other than
Payments from abroad for maintenance, the Slovak resident, or
education, study, research, or training. Russia Study at a university or other accredited
The grant, allowance, or award. educational institution in the United States.
Income from personal services performed An individual who is a resident of Russia at the
in the United States of up to $5,000 each beginning of his or her visit to the United States An individual who is a Slovak resident at the
tax year. is exempt from U.S. tax on payments from time he or she becomes temporarily present in
abroad for maintenance, education, study, re­ the United States and who is temporarily
An individual is entitled to the benefit of this search, or training and on any grant, allowance, present in the United States for a period not lon­
exemption for a maximum of 5 tax years from or other similar payments. To be entitled to the ger than 1 year as a participant in a program
the date of arrival in the United States. The ben­ exemption, the individual must be temporarily sponsored by the U.S. government for the pri­
efits provided here and the benefits described present in the United States primarily to: mary purpose of training, research, or study is
earlier under Professors, Teachers, and Re- Study at a university or other accredited exempt from U.S. income tax on up to $10,000
searchers cannot be claimed simultaneously or educational institution, of income from personal services for that train­
consecutively. Obtain training required to qualify him or ing, research, or study.
her to practice a profession or professional
An individual who is a resident of Portugal specialty, or These exemptions do not apply to income
on the date of arrival in the United States and Study or do research as a recipient of a from research undertaken primarily for the pri­
who is in the United States as an employee of, grant, allowance, or other similar payments vate benefit of a specific person or persons.

Publication 901 (September 2016) Page 25


Slovenia as a recipient of a grant, allowance, or award training is exempt from U.S. tax on amounts re­
from a governmental, religious, charitable, sci­ ceived from sources outside the United States
An individual who is a resident of Slovenia at entific, literary, or educational organization is for the individual's maintenance, education, and
the beginning of the visit to the United States exempt from U.S. income tax on the following training.
and who is temporarily in the United States pri­ amounts.
marily to study at a U.S. university or other rec­ Payments from abroad (other than com­ Switzerland
ognized educational institution, to obtain train­ pensation for personal services) for main­
ing to become qualified to practice a profession tenance, education, study, research, or A student, apprentice, or business trainee who
or professional specialty, or to study or do re­ training. is a resident of Switzerland immediately before
search as a recipient of a grant, allowance, or The grant, allowance, or award. visiting the United States and is in the United
award from a governmental, religious, charita­ Income from personal services performed States for the purpose of full­time education or
ble, scientific, literary, or educational organiza­ in the United States of up to $5,000 for training is exempt from U.S. income tax on
tion is exempt from U.S. income tax on the fol­ each tax year. amounts received from sources outside the Uni­
lowing amounts. ted States for the individual's maintenance, ed­
An individual is entitled to the benefit of this ex­
Payments from abroad (other than com­ ucation, or training.
emption for a maximum of 5 years.
pensation for personal services) for main­
tenance, education, study, research, or
training.
An individual who is a resident of Spain at Thailand
the beginning of the visit to the United States
The grant, allowance, or award.
and is temporarily in the United States as an An individual who is a resident of Thailand at
Income from personal services performed
employee of, or under contract with, a resident the beginning of his or her visit to the United
in the United States of up to $5,000 for
of Spain is exempt from U.S. income tax for a States and who is temporarily present in the
each tax year.
period of 12 consecutive months on up to United States is exempt from U.S. income tax
An individual is entitled to the benefit of this ex­ $8,000 received for personal services if the indi­ on certain amounts for a period of up to 5 years.
emption for a maximum of 5 tax years and for vidual is in the United States primarily to: To be entitled to the exemption, the individual
any additional period of time needed to com­ Acquire technical, professional, or busi­ must be in the United States for the primary pur­
plete, as a full­time student, educational re­ ness experience from a person other than pose of:
quirements as a candidate for a postgraduate that Spanish resident, or Studying at a university or other recog­
or professional degree from a recognized edu­ Study at a university or other accredited nized educational institution in the United
cational institution. educational institution in the United States. States,
Obtaining training required to qualify him or
An individual who is a resident of Slovenia Both the $5,000 and $8,000 exemptions in­ her to practice a profession or professional
on the date of arrival in the United States and clude any amount excluded or exempted from specialty, or
who is temporarily in the United States as an tax under U.S. tax law. Studying or doing research as a recipient
employee of, or under contract with, a resident of a grant, allowance, or award from a gov­
of Slovenia is exempt from U.S. income tax for These exemptions do not apply to income ernmental, religious, charitable, scientific,
a period not exceeding 12 months on up to from research carried on mainly for the private literary, or educational organization.
$8,000 received for personal services if the indi­ benefit of any person rather than in the public If the individual meets any of these require­
vidual is in the United States primarily to: interest. ments, the following amounts are exempt from
Acquire technical, professional, or busi­
U.S. tax.
ness experience from a person other than Sri Lanka Gifts from abroad for the purpose of main­
that resident of Slovenia, or
tenance, education, study, research, or
Study at a university or other recognized A student, apprentice, or business trainee, who training.
educational institution. is a resident of Sri Lanka resident immediately The grant, allowance, or award.
before visiting the United States and is in the Income from personal services performed
These provisions do not apply to income United States for the purpose of full­time educa­ in the United States of up to $3,000 for the
from research carried on mainly for the private tion or training, is exempt from U.S. income tax tax year.
benefit of any person rather than in the public on amounts received from sources outside the
interest. United States for the individual's maintenance, An individual who is a resident of Thailand at
education, or training. the beginning of the visit to the United States
South Africa and who is temporarily present in the United
An individual who is a resident of Sri Lanka States as an employee of, or under contract
A student, apprentice, or business trainee who on the date of arrival in the United States and with, a resident of Thailand is exempt from U.S.
is a resident of South Africa immediately before who is temporarily in the United States as an income tax for a period of 12 consecutive
visiting the United States and is in the United employee of, or under contract with, a resident months on up to $7,500 received from personal
States for the purpose of full­time education or of Sri Lanka, or as a participant in a program services if the individual is in the United States
training is exempt from U.S. income tax on sponsored by the United States or by any inter­ primarily to:
amounts received from sources outside the Uni­ national organization, is exempt from U.S. in­ Acquire technical, professional, or busi­
ted States for the individual's maintenance, ed­ come tax for a period not exceeding 1 year on ness experience from a person other than
ucation, or training. up to $6,000 received for personal services if the Thai resident, or
the individual is in the United States primarily to: Study at a university or other recognized
Apprentices and business trainees are enti­ Acquire technical, professional, or busi­ educational institution in the United States.
tled to the benefit of this exemption for a maxi­ ness experience from a person other than
mum period of 1 year. that resident of Sri Lanka or other than a
person related to that resident, or An individual who is a resident of Thailand at
Study at a university or other recognized the time he or she becomes temporarily present
Spain in the United States and who is temporarily
educational institution.
present in the United States for a period not lon­
An individual who is a resident of Spain at the ger than 1 year as a participant in a program
beginning of the visit to the United States and Sweden sponsored by the U.S. government for the pri­
who is temporarily in the United States primarily mary purpose of training, research, or study is
to study at a U.S. university or other accredited A student, apprentice, or business trainee who exempt from U.S. income tax on up to $10,000
educational institution, to obtain training to be­ is a resident of Sweden immediately before vis­ of income from personal services for that train­
come qualified to practice a profession or pro­ iting the United States and is in the United ing, research, or study.
fessional specialty, or to study or do research States for the purpose of full­time education or

Page 26 Publication 901 (September 2016)


Trinidad and Tobago Turkey The grant, allowance, or award.
Income from personal services performed
An individual who is a resident of Trinidad and A student, apprentice, or business trainee who in the United States of up to $5,000 for
Tobago on the date of arrival in the United is a resident of Turkey immediately before visit­ each tax year.
States and who is temporarily in the United ing the United States and is in the United States
States primarily to study at a university or other for the purpose of full­time education or training An individual is generally entitled to the ben­
accredited educational institution in the United is exempt from U.S. income tax on amounts re­ efit of this exemption for a maximum of 5 years
States, obtain professional training, or study or ceived from sources outside the United States from the date of arrival in the United States.
do research as a recipient of a grant, allowance, for the individual's maintenance, education, or This exemption will also apply to any additional
or award from a governmental, religious, chari­ training. period of time that a full­time student needs to
table, scientific, literary, or educational organi­ complete the educational requirements as a
zation is exempt from U.S. income tax on the Ukraine candidate for a postgraduate or professional
following amounts. degree from a recognized educational institu­
Gifts from abroad for maintenance, educa­ An individual who is a resident of Ukraine at the tion.
tion, study, research, or training. beginning of his or her visit to the United States
The grant, allowance, or award. is exempt from U.S. tax on payments from An individual who is a resident of Venezuela
Income from personal services performed abroad for maintenance, education, study, re­ on the date of arrival in the United States and
in the United States of up to $2,000 each search, or training and on any grant, allowance, who is in the United States as an employee of,
tax year, or, if the individual is obtaining or other similar payments. To be entitled to the or under contract with, a resident of Venezuela
training required to qualify to practice a exemption, the individual must be temporarily is exempt from U.S. income tax for a period of
profession or a professional specialty, a present in the United States primarily to: 12 months on up to $8,000 received for per­
maximum of $5,000 for any tax year. Study at a university or other accredited sonal services if the individual is in the United
educational institution, States primarily to:
An individual is entitled to the benefit of this Obtain training required to qualify him or Acquire technical, professional, or busi­
exemption for a maximum period of 5 tax years. her to practice a profession or professional ness experience from a person other than
specialty, or that resident of Venezuela, or
An individual who is a resident of Trinidad Study or do research as a recipient of a Study at an educational institution.
and Tobago on the date of arrival in the United grant, allowance, or other similar payments
States and who is in the United States as an These provisions do not apply to income
from a governmental, religious, charitable,
employee of, or under contract with, a resident from research carried on mainly for the private
scientific, literary, or educational organiza­
or corporation of Trinidad and Tobago is ex­ benefit of any person rather than in the public
tion.
empt from U.S. income tax for 1 tax year on up interest.
to $5,000 received for personal services if the
The individual is entitled to this exemption
individual is in the United States primarily to:
Study at an educational institution, or
only for a period of time necessary to complete Wages and Pensions
Acquire technical, professional, or busi­
the study, training, or research, but the exemp­ Paid by a Foreign
tion for training or research may not extend for a
ness experience from a person other than
period exceeding 5 years.
Government
that resident or corporation of Trinidad and
Tobago. Wages, salaries, pensions, and annuities paid
These exemptions do not apply to income by the governments of the following countries to
Also exempt is a resident of Trinidad and from research if it is undertaken primarily for the their residents who are present in the United
Tobago who is present in the United States for private benefit of a specific person or persons. States as nonresident aliens generally are ex­
not longer than 1 year as a participant in a pro­ empt from U.S. income tax. The conditions un­
gram sponsored by the U.S. Government pri­ United Kingdom der which the income is exempt are stated for
marily to train, research, or study. The individual each of the countries listed.
is exempt from tax on income from personal A student or business apprentice who is a resi­
services performed in the United States and re­ dent of the United Kingdom immediately before Exemption under U.S. tax law. Employees of
ceived for the training, research, or study for up visiting the United States and is in the United foreign countries who do not qualify under a tax
to a maximum of $10,000. States for the purpose of full­time education at a treaty provision and employees of international
recognized educational institution or full­time organizations should see if they can qualify for
training is exempt from U.S. income tax on exemption under U.S. tax law.
Tunisia
amounts received from abroad for the individu­ If you work for a foreign government in the
An individual who is a resident of Tunisia imme­ al's maintenance, education, or training. United States, your foreign government salary
diately before visiting the United States and is exempt from U.S. tax if you perform services
who is in the United States for full­time study or Apprentices and business trainees are enti­ similar to those performed by U.S. government
training is exempt from U.S. income tax on the tled to the benefit of this exemption for a maxi­ employees in that foreign country and that for­
following amounts. mum period of 1 year. eign government grants an equivalent exemp­
Payments from abroad for full­time study tion. If you work for an international organization
or training. Venezuela in the United States, your salary from that
A grant, allowance, or award from a gov­ source is exempt from U.S. tax. See chapter 10
ernmental, religious, charitable, scientific, An individual who is a resident of Venezuela on of Publication 519 for more information.
literary, or educational organization to the date of arrival in the United States and who
study or engage in research. is temporarily in the United States primarily to Australia
Income from personal services performed study at a university or other recognized educa­
in the United States of up to $4,000 in any tional institution in the United States, obtain pro­ Salaries, wages, and similar income, including
tax year. fessional training, or study or do research as a pensions, paid by Australia, its political subdivi­
recipient of a grant, allowance, or award from a sions, agencies, or authorities to its citizens
The individual is entitled to this exemption governmental, religious, charitable, scientific, (other than U.S. citizens) for performing govern­
for a maximum of 5 years. literary, or educational organization is exempt mental functions as an employee of any of the
from U.S. income tax on the following amounts. above entities are exempt from U.S. income
Payments from abroad, other than com­ tax.
pensation for personal services, for main­
tenance, education, study, research, or
training.

Publication 901 (September 2016) Page 27


Austria an individual for services performed for the pay­ These exemptions do not apply to income or
ing governmental body are exempt from U.S. in­ pensions for services performed in connection
Wages, salaries, similar income, and pensions come tax unless the recipient is both a resident with a business carried on by the People's Re­
and annuities paid from public funds of Austria, and national of the United States. public of China or its subdivisions or local au­
its political subdivisions, or its local authorities, thorities.
to citizens of Austria for performing governmen­ However, these exemptions do not apply to
tal functions as an employee are exempt from payments for services performed in connection Commonwealth of
U.S. tax. with a business carried on by Belgium, its politi­ Independent States (C.I.S.)
cal subdivisions, or local authorities.
However, this exemption does not apply to Wages, salaries, and similar income paid by the
payments for services performed in connection C.I.S. or a member of the C.I.S. to its citizens
with a trade or business carried on by Austria or
Bulgaria
for personal services performed as an em­
its political subdivisions or local authorities. ployee of a governmental agency or institution
Wages, salaries, and similar income, other than
a pension, paid by Bulgaria, its political subdivi­ of the C.I.S. or a member of the C.I.S. (exclud­
Bangladesh sions, or local authorities to an individual for ing local government employees) in the dis­
services performed for the paying governmental charge of governmental functions are exempt
Income, other than a pension, paid by Bangla­ body are exempt from U.S. income tax. How­ from U.S. income tax. For this purpose, persons
desh, its political subdivisions, or local authori­ ever, the exemption does not apply if the serv­ engaged in commercial activities are not con­
ties to an individual for services performed for ices are performed in the United States by a sidered engaged in the discharge of govern­
the paying governmental body is exempt from resident of the United States who either: mental functions.
U.S. income tax. However, the exemption does Is a U.S. national, or
not apply if the services are performed in the Did not become a U.S. resident only to Cyprus
United States by a resident of the United States perform the services.
who either: Wages, salaries, and similar income, including
Is a U.S. citizen, or pensions, annuities, and similar benefits, paid
Pensions paid by, or out of funds created
Did not become a U.S. resident only to from public funds of Cyprus to a citizen of Cy­
by, Bulgaria, its political subdivisions, or local
perform the services. prus for labor or personal services performed
authorities for services performed for Bulgaria,
its political subdivisions, or local authorities to as an employee of Cyprus in the discharge of
Pensions paid from the public funds of Ban­ an individual for services performed for the pay­ governmental functions are exempt from U.S.
gladesh, its political subdivisions, or local au­ ing governmental body are exempt from U.S. in­ income tax.
thorities for services performed for Bangladesh, come tax unless the recipient is both a resident
its political subdivisions, or local authorities to
an individual for services performed for the pay­
and national of the United States. Czech Republic
ing governmental body are exempt from U.S. in­
However, these exemptions do not apply to Income, including a pension, paid from the pub­
come tax unless the recipient is both a resident
payments for services performed in connection lic funds of the Czech Republic, its political sub­
and citizen of the United States.
with a business carried on by Bulgaria, its politi­ divisions, or local authorities to a Czech citizen
cal subdivisions, or local authorities. for services performed in the discharge of gov­
This exemption does not apply to income or ernmental functions is exempt from U.S. in­
pensions for services performed in connection come tax. This exemption does not apply to in­
with a business carried on by Bangladesh, its Canada come paid for services performed in connection
political subdivisions, or local authorities. with a business carried on by the Czech Repub­
Wages, salaries, and similar income (other than
lic, its political subdivisions, or local authorities.
pensions) paid by Canada or by a Canadian po­
Barbados litical subdivision or local authority to a citizen of
Canada for performing governmental functions Denmark
Income, including a pension, paid from the pub­
lic funds of Barbados, or its political subdivi­ are exempt from U.S. income tax. This exemp­
tion does not apply, however, to payments for Income, other than a pension, paid from public
sions or local authorities, to a citizen of Barba­ funds of Denmark, its political subdivisions, or
dos for performing governmental functions is services performed in connection with a trade
or business carried on by Canada or its political local authorities to an individual for services
exempt from U.S. income tax. performed for the paying governmental body in
subdivisions or local authorities.
the discharge of governmental functions is ex­
However, this exemption does not apply to empt from U.S. income tax. However, the ex­
payments for services in connection with a busi­ Also see Publication 597, Information on the
emption does not apply if the services are per­
ness carried on by Barbados or its political sub­ United States–Canada Income Tax Treaty.
formed in the United States by a resident of the
divisions or local authorities. United States who either:
China, People's Republic of Is a U.S. national, or
Belgium Did not become a U.S. resident only to
Income, other than a pension, paid by the Peo­ perform the services.
Wages, salaries, and similar income, other than ple's Republic of China or its political subdivi­
a pension, paid by Belgium, its political subdivi­ sions or local authorities to an individual for Pensions paid from the public funds of Den­
sions, or local authorities to an individual for services performed for the paying governmental mark, its political subdivisions, or local authori­
services performed for the paying governmental body is exempt from U.S. income tax. However, ties for services performed for Denmark are ex­
body is exempt from U.S. income tax. However, the exemption does not apply to payments for empt from U.S. income tax unless the recipient
the exemption does not apply if the services are services performed in the United States by a is a resident and a national of the United States.
performed in the United States by a resident of resident of the United States who either:
the United States who either: Is a U.S. citizen, or These exemptions do not apply to income or
Is a U.S. national, or Did not become a U.S. resident only to pensions for services performed in connection
Did not become a U.S. resident only to perform the services. with a trade or business carried on by Denmark,
perform the services. its political subdivisions, or local authorities.
Pensions paid by the People's Republic of
Pensions paid by, or out of funds created China for services performed for China are ex­
by, Belgium, its political subdivisions, or local empt from U.S. income tax unless the recipient
authorities for services performed for Belgium, is both a citizen and a resident of the United
its political subdivisions, or local authorities to States.

Page 28 Publication 901 (September 2016)


Egypt to an individual in the United States for services These exemptions do not apply to income or
performed for France (or for a local authority of pensions for services performed in connection
Wages, salaries, and similar income, including France) in the discharge of governmental func­ with a trade or business carried on by Hungary
pensions, annuities, and similar benefits, paid tions is exempt from U.S. tax. This exemption or its subdivisions.
from public funds of the Arab Republic of Egypt does not apply to a person who is both a resi­
to a citizen of Egypt (or to a citizen of another dent and citizen of the United States or a green Iceland
country who comes to the United States specifi­ card holder.
cally to work for the Government of Egypt) for Wages, salaries, and similar income, other than
labor or personal services performed as an em­ This exemption does not apply to any in­ a pension, paid by Iceland, its political subdivi­
ployee of the national Government of Egypt, or come paid because of services (or past serv­ sions, or local authorities to an individual for
any of its agencies, in the discharge of govern­ ices) performed in connection with a business services performed for the paying governmental
mental functions are exempt from U.S. income carried on by the French Government (or a local body are exempt from U.S. income tax. How­
tax. authority thereof). ever, the exemption does not apply if the serv­
ices are performed in the United States by a
This exemption does not apply to U.S. citi­ resident of the United States who either:
zens or to alien residents of the United States.
Germany
Is a U.S. national, or
The exemption also does not apply to payments Did not become a U.S. resident only to
Wages, salaries, and similar income, other than
for services performed in connection with a perform the services.
a pension, paid by Germany, its political subdi­
trade or business carried on by Egypt or any of
visions, local authorities, or instrumentalities to
its agencies.
an individual for services performed for the pay­ Pensions paid by, or out of funds created
ing governmental body is exempt from U.S. in­ by, Iceland, its political subdivisions, or local au­
Estonia come tax. However, the exemption does not thorities for services performed for Iceland, its
apply if the services are performed in the United political subdivisions, or local authorities to an
Income, other than a pension, paid by or from States by a resident of the United States who individual for services performed for the paying
public funds of Estonia, its political subdivi­ either: governmental body are exempt from U.S. in­
sions, or local authorities to an individual for Is a U.S. national, or come tax unless the recipient is both a resident
services performed as an employee for the pay­ Did not become a U.S. resident only to and national of the United States.
ing governmental body in the discharge of gov­ perform the services.
ernmental functions is exempt from U.S. in­
However, these exemptions do not apply to
come tax. However, the exemption does not
Pensions paid by, or out of funds created payments for services performed in connection
apply if the services are performed in the United
by, Germany, its political subdivisions, local au­ with a business carried on by Iceland, its politi­
States by a resident of the United States who
thorities, or instrumentalities for services per­ cal subdivisions, or local authorities.
either:
formed for the paying governmental body are
Is a U.S. citizen, or
exempt from U.S. income tax unless the recipi­ India
Did not become a U.S. resident only to
ent is both a resident and a national of the Uni­
perform the services.
ted States. Income, other than a pension, paid by India, its
Pensions paid by or from the public funds of political subdivisions, or local authorities to an
Estonia, its political subdivisions, or local au­ This exemption does not apply to income or individual for services performed for the paying
thorities for services performed for Estonia are pensions for services performed in connection governmental body is exempt from U.S. income
exempt from U.S. income tax unless the recipi­ with a business carried on by Germany, its polit­ tax. However, the exemption does not apply if
ent is both a resident and citizen of the United ical subdivisions, local authorities, or instrumen­ the services are performed in the United States
States. talities. by a U.S. resident who either:
Is a U.S. citizen, or
Greece Did not become a U.S. resident only to
Finland perform the services.
Income, other than a pension, paid by Finland, Wages, salaries, and similar income and pen­
its political subdivisions, statutory bodies, or lo­ sions paid by Greece or its subdivisions to indi­ Pensions paid by India for services per­
cal authorities to an individual for services per­ viduals living in the United States for services formed for India are exempt from U.S. tax un­
formed for the paying governmental body is ex­ rendered to Greece or its subdivisions are ex­ less the individual is both a resident and citizen
empt from U.S. income tax. However, the empt from U.S. income tax. This exemption of the United States.
exemption does not apply to payments for serv­ does not apply to citizens of the United States
ices performed in the United States by a U.S. or alien residents of the United States. These exemptions do not apply to income or
resident who either: pensions for services performed in connection
Is a U.S. citizen, or Hungary with a business carried on by India, its subdivi­
Did not become a U.S. resident only to sions, or local authorities.
perform the services. Income (other than a pension) paid by the Re­
public of Hungary or its political subdivisions for Indonesia
Pensions paid by Finland for services per­ labor or personal services performed for the
formed for Finland are exempt from U.S. in­ paying governmental body is exempt from U.S. Income, other than a pension, paid by Indone­
come tax unless the recipient is a resident and tax. However, the exemption does not apply to sia, its political subdivisions, or local authorities
citizen of the United States. payments for services performed in the United to an individual for services performed for the
States by a resident of the United States who paying governmental body is exempt from U.S.
These exemptions do not apply to income or either: income tax. However, the exemption does not
pensions for services performed in connection Is a U.S. citizen, or apply if the services are performed in the United
with a trade or business carried on by Finland or Did not become a resident of the United States by a U.S. resident who either:
its political subdivisions, statutory bodies, or lo­ States only to perform the services. Is a U.S. citizen, or
cal authorities. Did not become a U.S. resident only to
Pensions paid by Hungary for services per­ perform the services.
France formed for Hungary are exempt from U.S. in­
come tax unless the recipient is both a citizen Pensions paid by Indonesia for services per­
Income, other than a pension, paid by the and a resident of the United States. formed for Indonesia are exempt from U.S. tax.
French Government or a local authority thereof

Publication 901 (September 2016) Page 29


These exemptions do not apply to income or Jamaica Korea, South
pensions for services performed in connection
with a trade or business carried on by Indone­ Income, other than a pension, paid by the Gov­ Wages, salaries, and similar income, including
sia, its subdivisions, or local authorities. ernment of Jamaica or its political subdivisions pensions and similar benefits, paid from public
or local authorities for personal services per­ funds of South Korea to a citizen of Korea
Ireland formed for the paying governmental body is ex­ (other than a U.S. citizen or an individual admit­
empt from U.S. income tax. ted to the United States for permanent resi­
Income, other than a pension, paid by Ireland or dence) for services performed as an employee
its political subdivisions or local authorities to an This exemption does not apply to payments of Korea discharging government functions are
individual for services performed for the paying for services performed in the United States by exempt from U.S. income tax.
governmental body is exempt from U.S. income an individual who is a citizen and resident of the
tax. However, the exemption does not apply to United States. Latvia
payments for services performed in the United
States by a resident of the United States who Pensions paid by Jamaica for services per­ Income, other than a pension, paid by or from
either: formed for Jamaica generally are exempt from public funds of Latvia, its political subdivisions,
Is a U.S. citizen, or U.S. income tax. However, if the recipient of the or local authorities to an individual for services
Did not become a U.S. resident only to pension is a citizen and resident of the United performed as an employee for the paying gov­
perform the services. States and was a U.S. citizen at the time the ernmental body in the discharge of governmen­
services were performed, the pension is taxable tal functions is exempt from U.S. income tax.
Pensions paid by Ireland for services per­ in the United States. However, the exemption does not apply if the
formed for Ireland are exempt from U.S. income services are performed in the United States by
tax unless the recipient is both a resident and a resident of the United States who either:
These exemptions do not apply to income or
citizen of the United States. Is a U.S. citizen, or
pensions for services performed in connection
Did not become a U.S. resident only to
These exemptions do not apply to income or with a trade or business carried on by Jamaica
perform the services.
pensions for services performed in connection or its subdivisions or local authorities.
with a business carried on by Ireland or its sub­ Pensions paid by or from the public funds of
divisions or local authorities. Japan Latvia, its political subdivisions, or local authori­
ties for services performed for Latvia are ex­
Income, other than a pension, paid by Japan, its
Israel empt from U.S. income tax unless the recipient
political subdivisions, or local authorities to an is both a resident and citizen of the United
Wages, salaries, and similar income, including individual for services performed for the paying States.
pensions and similar benefits, paid from public governmental body is exempt from U.S. income
funds by the national government of Israel or its tax. However, the exemption does not apply if
the services are performed in the United States Lithuania
agencies, for services performed in the dis­
charge of governmental functions, are exempt by a resident of the United States who either:
Income, other than a pension, paid by or from
from U.S. income tax. This exemption does not Is a U.S. citizen, or
public funds of Lithuania, its political subdivi­
apply to citizens of the United States or alien Did not become a U.S. resident only to
sions, or local authorities to an individual for
residents of the United States. perform the services.
services performed as an employee for the pay­
ing governmental body in the discharge of gov­
Pensions paid by, or out of funds to which
Italy ernmental functions is exempt from U.S. in­
contributions are made by, Japan, its political come tax. However, the exemption does not
Income, other than a pension, paid by Italy or by subdivisions, or local authorities for services apply if the services are performed in the United
an Italian political or administrative subdivision performed for Japan are exempt from U.S. in­ States by a resident of the United States who
or local authority to an individual for services come tax unless the recipient is a resident and either:
performed for the paying governmental body is citizen of the United States. Is a U.S. citizen, or
exempt from U.S. income tax. However, the ex­ Did not become a U.S. resident only to
emption does not apply to payments for serv­ These exemptions do not apply to income or perform the services.
ices performed in the United States by a resi­ pensions for services performed in connection
dent of the United States who either: with a business carried on by Japan, its political Pensions paid by or from the public funds of
Is a U.S. national and not a national of subdivisions, or local authorities. Lithuania, its political subdivisions, or local au­
Italy, or thorities for services performed for Lithuania are
Did not become a U.S. resident only to Kazakhstan exempt from U.S. income tax unless the recipi­
perform the services. ent is both a resident and citizen of the United
The spouse and dependent children of an indi­ Income, other than a pension, paid by Kazakh­ States.
vidual, however, are not subject to the second stan, or its subdivisions or local authorities to an
restriction if that individual is receiving exempt individual for government services is exempt Luxembourg
income for governmental services performed from U.S. tax. However, the exemption does
for Italy and that individual does not come under not apply if the services are performed in the Income, other than a pension, paid by Luxem­
either of the restrictions. United States by a U.S. resident who either: bourg, its political subdivisions, or local authori­
Is a U.S. citizen, or ties to an individual for services performed for
Pensions paid by Italy for services per­ Did not become a U.S. resident solely for the paying governmental body is exempt from
formed for Italy are exempt from U.S. income the purpose of performing the services. U.S. income tax. However, the exemption does
tax unless the recipient is both a citizen and a These exemptions do not apply to income for not apply if the services are performed in the
resident of the United States. services performed in connection with a busi­ United States by a resident of the United States
ness. who either:
These exemptions do not apply to income or Is a U.S. citizen, or
pensions for services performed in connection Did not become a U.S. resident only to
Pensions paid by Kazakhstan, or its subdivi­
with a trade or business carried on by Italy or its perform the services.
sions or local authorities for services performed
subdivisions or local authorities.
for Kazakhstan is exempt from U.S. tax unless
Pensions paid by Luxembourg, its political
the individual is both a resident and citizen of
subdivisions, or local authorities for services
the United States.
performed for Luxembourg are exempt from

Page 30 Publication 901 (September 2016)


U.S. income tax unless the recipient is both a Netherlands does not apply to payments for services per­
resident and citizen of the United States. formed in connection with any trade or business
Income, other than a pension, paid by the Neth­ carried on for profit.
These exemptions do not apply to income or erlands, its political subdivisions, or local au­
pensions for services performed in connection thorities to an individual for services performed Philippines
with a trade or business carried on by Luxem­ for the paying governmental body is exempt
bourg, its political subdivisions, or local authori­ from U.S. income tax. However, the exemption Wages, salaries, and similar income, including
ties. does not apply if the services are rendered in pensions, annuities, and similar benefits, paid
the United States and the individual is a U.S. from public funds of the Republic of the Philip­
Malta resident who either: pines to a citizen of the Philippines (or to a citi­
Is a U.S. national, or zen of another country other than the United
Income, other than a pension, paid by Malta, its Did not become a U.S. resident solely for States who comes to the United States specifi­
political subdivisions, or local authorities to an the purpose of performing the services. cally to work for the Government of the Philip­
individual for services performed for the paying pines) for labor or personal services performed
governmental body is exempt from U.S. income Pensions paid by the Netherlands for serv­ as an employee of the national Government of
tax. However, the exemption does not apply if ices performed for the Netherlands are exempt the Philippines or any of its agencies in the dis­
the services are performed in the United States from U.S. income tax unless the individual is charge of governmental functions are exempt
by a U.S. resident who either: both a resident and national of the United from U.S. income tax.
Is a U.S. national, or States.
Did not become a resident of the United Poland
States solely for purposes of performing These exemptions do not apply to income or
the services. pensions for services performed in connection Wages, salaries, and similar income, including
with a business carried on by the Netherlands, pensions, annuities, and similar benefits, paid
Pensions paid by Malta, its political subdivi­ its political subdivisions, or local authorities. from public funds of Poland to a citizen of Po­
sions, or local authorities for services performed land (other than a U.S. citizen or one admitted
for the paying governmental body are exempt to the United States for permanent residence)
from U.S. income tax unless the individual is
New Zealand
for labor or personal services performed as an
both a resident and national of the United Income (other than pensions) paid by the Gov­ employee of the national Government of Poland
States. ernment of New Zealand, its political subdivi­ in the discharge of governmental functions are
sions, or local authorities for services performed exempt from U.S. income tax.
These exemptions do not apply to income or in the discharge of governmental functions is
pensions for services performed in connection exempt from U.S. income tax. However, the in­ Portugal
with a business carried on by Malta, its political come is not exempt if the services are per­
subdivisions, or local authorities. 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 resi­ cal authorities to an individual for services per­
dent only to perform the services. formed for the paying governmental body is ex­
Income, other than a pension, paid by Mexico, empt from U.S. income tax. However, the
its political subdivisions, or local authorities to Pensions paid by New Zealand in consider­ exemption does not apply to payments for serv­
an individual for services performed for the pay­ ation for past governmental services are ex­ ices performed in the United States by a U.S.
ing governmental body is exempt from U.S. in­ empt from U.S. income tax unless paid to U.S. resident who either:
come tax. However, the exemption does not citizens resident in the United States. Is a U.S. national, or
apply if the services are performed in the United Did not become a U.S. resident only to
States by a U.S. resident who either: perform the services.
Is a U.S. national, or These exemptions do not apply to payments
Did not become a resident of the United for services performed in connection with a
business carried on by New Zealand, its politi­ Pensions paid by Portugal for services per­
States solely for purposes of performing formed for Portugal are exempt from U.S. in­
the services. cal subdivisions, or local authorities.
come tax unless the recipient is a resident and
national of the United States.
Pensions paid by Mexico, its political subdi­ Norway
visions, or local authorities for services per­
Wages, salaries, and similar income, including These exemptions do not apply to income or
formed for the paying governmental body are
pensions and similar benefits paid by or from pensions for services performed in connection
exempt from U.S. income tax unless the individ­
public funds of Norway or its political subdivi­ with a business carried on by Portugal or its po­
ual is both a resident and national of the United
sions or local authorities to a citizen of Norway litical or administrative subdivisions, or local au­
States.
for labor or personal services performed for thorities.
These exemptions do not apply to income or Norway or any of its political subdivisions or lo­
pensions connected with commercial or indus­ cal authorities in the discharge of governmental Romania
trial activities carried on by Mexico, its political functions are exempt from U.S. income tax.
subdivisions, or local authorities. Wages, salaries, and similar income, including
Pakistan pensions, annuities, and similar benefits, paid
from public funds of Romania to a citizen of Ro­
Morocco mania (other than a U.S. citizen or one admitted
Income, including pensions and annuities, paid
to certain individuals by or on behalf of the Gov­ to the United States for permanent residence)
Wages, salaries, and similar income, including
ernment of Pakistan or the Government of a for labor or personal services performed as an
pensions and similar benefits, paid from public
Province in Pakistan or one of its local authori­ employee of the national Government of Roma­
funds of the Kingdom of Morocco to a citizen of
ties for services performed in the discharge of nia in the discharge of governmental functions
Morocco (other than a U.S. citizen or an individ­
functions of that Government or local authority are exempt from U.S. income tax.
ual admitted to the United States for permanent
residence) for labor or personal services per­ is exempt from U.S. income tax. To be exempt
formed for Morocco or for any of its political from tax, these payments must be made to citi­ Russia
subdivisions or local authorities in the discharge zens of Pakistan who do not have immigrant
of governmental functions are exempt from U.S. status in the United States. This exemption Income, other than a pension, paid by Russia,
income tax. its republics, or local authorities to an individual

Publication 901 (September 2016) Page 31


for government services is exempt from U.S. These exemptions do not apply to income or U.S. income tax. However, the exemption does
tax. However, the exemption does not apply if pensions for services performed in connection not apply to payments for services performed in
the services are performed in the United States with a business carried on by South Africa or its the United States by a resident of the United
by a U.S. resident who either: subdivisions or local authorities. States who either:
Is a U.S. citizen, or Is a U.S. citizen, or
Did not become a U.S. resident solely for Spain Did not become a U.S. resident only to
the purpose of performing the services. perform the services.
Income, other than a pension, paid by Spain, its
Pensions paid by Russia, its republics, or lo­ political subdivisions, or local authorities to an Pensions paid by Switzerland for services
cal authorities for services performed for Russia individual for services performed for the paying performed for Switzerland are exempt from U.S.
are exempt from U.S. tax unless the individual governmental body is exempt from U.S. income income tax unless the recipient is both a resi­
is both a resident and citizen of the United tax. However, the exemption does not apply to dent and citizen of the United States.
States. payments for services performed in the United
States by a resident of the United States who These exemptions do not apply to income or
either: pensions for services performed in connection
These exemptions do not apply to income or with a business carried on by Switzerland or its
pensions for services performed in connection Is a U.S. citizen, or
Did not become a U.S. resident only to subdivisions or local authorities.
with a business.
perform the services.
Thailand
Slovak Republic Pensions paid by Spain, its political subdivi­
sions, or local authorities for services performed Income, other than a pension, paid by Thailand
Income, including a pension, paid from the pub­ or its political subdivisions or local authorities to
for Spain are exempt from U.S. tax unless the
lic funds of the Slovak Republic, its political an individual for services performed for the pay­
individual is both a citizen and resident of the
subdivisions, or local authorities to a Slovak citi­ ing governmental body is exempt from U.S. in­
United States.
zen for services performed in the discharge of come tax. However, the exemption does not
governmental functions is exempt from U.S. in­ apply to payments for services performed in the
These exemptions do not apply to income or
come tax. This exemption does not apply to in­ United States by a resident of the United States
pensions for services performed in connection
come paid for services performed in connection who either:
with a trade or business carried on by Spain, its
with a business carried on by the Slovak Re­ Is a U.S. citizen, or
subdivisions, or local authorities.
public, its political subdivisions, or local authori­ Did not become a U.S. resident only to
ties. perform the services.
Sri Lanka
Slovenia Income, including a pension, paid from the pub­
Pensions paid by Thailand for services per­
formed for Thailand are exempt from U.S. in­
lic funds of Sri Lanka, its political subdivisions,
Income, other than a pension, paid from public come tax unless the recipient is both a resident
or local authorities to a citizen or national of Sri
funds of Slovenia, its political subdivisions, or and citizen of the United States.
Lanka for services performed for Sri Lanka in
local authorities to an individual for services
the discharge of functions of a governmental
performed for the paying governmental body in These exemptions do not apply to income or
nature is exempt from U.S. income tax. This ex­
the discharge of governmental functions is ex­ pensions for services performed in connection
emption does not apply to income paid for serv­
empt from U.S. income tax. However, the ex­ with a business carried on by Thailand or its
ices performed in connection with a business
emption does not apply if the services are per­ subdivisions or local authorities.
carried on by Sri Lanka, its political subdivi­
formed in the United States by a resident of the
sions, or local authorities.
United States who either: Trinidad and Tobago
Is a U.S. citizen, or
Did not become a U.S. resident only to Sweden Wages, salaries, and similar income and pen­
perform the services. sions, annuities, and similar benefits paid by or
Income, other than a pension, paid by Sweden,
from the public funds of the Government of Tri­
its political subdivisions, or local authorities to
Pensions paid from the public funds of Slov­ nidad and Tobago to a national of that country
an individual for services performed for the pay­
enia, its political subdivisions, or local authori­ for services performed for Trinidad and Tobago
ing governmental body is exempt from U.S. in­
ties for services performed for Slovenia in the in the discharge of governmental functions are
come tax. However, the exemption does not
discharge of governmental functions are ex­ exempt from U.S. tax.
apply if the services are performed in the United
empt from U.S. income tax unless the recipient
States by a U.S. resident who either:
is both a resident and citizen of the United Tunisia
Is a U.S. citizen, or
States.
Did not become a U.S. resident solely for
the purpose of performing the services. Income, other than a pension, paid by Tunisia,
South Africa its political subdivisions, or local authorities to a
Pensions paid by Sweden, its political subdi­ Tunisian citizen for personal services per­
Income, other than a pension, paid by South Af­ visions, or local authorities for services per­ formed in the discharge of governmental func­
rica or its political subdivisions or local authori­ formed for Sweden are exempt from U.S. tax tions is exempt from U.S. income tax.
ties to an individual for services performed for unless the individual is both a resident and citi­
the paying governmental body is exempt from zen of the United States. Pensions paid by Tunisia, its political subdi­
U.S. income tax. However, the exemption does visions, or local authorities for services per­
not apply to payments for services performed in These exemptions do not apply to income or formed for Tunisia are exempt from U.S. in­
the United States by a resident of the United pensions for services performed in connection come tax unless the recipient is a U.S. citizen.
States who either: with a business carried on by Sweden, its politi­
Is a U.S. citizen, or cal subdivisions, or local authorities. These exemptions do not apply to income or
Did not become a U.S. resident only to pensions for services performed in connection
perform the services. with a trade or business carried on by Tunisia,
Switzerland its political subdivisions, or local authorities.
Pensions paid by South Africa for services Income, other than a pension, paid by Switzer­
performed for South Africa are exempt from land or its political subdivisions or local authori­
U.S. income tax unless the recipient is both a ties to an individual for services performed for
resident and citizen of the United States. the paying governmental body is exempt from

Page 32 Publication 901 (September 2016)


Turkey with a business carried on by the United King­ 60 years of age and older. TCE volunteers spe­
dom, its political subdivisions, or local authori­ cialize in answering questions about pensions
Income, other than a pension, paid by Turkey or ties. and retirement­related issues unique to seniors.
its political subdivisions or local authorities to an
Getting answers to your tax law
individual for services performed for the paying Venezuela questions. On IRS.gov get answers to
governmental body is exempt from U.S. income
your tax questions anytime, anywhere.
tax. However, the exemption does not apply to Income, other than a pension, paid by Vene­
payments for services performed in the United zuela, its political subdivisions, or local authori­ Go to www.irs.gov/Help- &-Resources for a
States by a resident of the United States who ties to an individual for services performed for variety of tools that will help you with your
either: the paying governmental body is exempt from taxes.
Is a U.S. citizen, or U.S. income tax. However, the exemption does Enter “ITA” in the search box on IRS.gov
Did not become a U.S. resident only to not apply to payments for services performed in for the Interactive Tax Assistant, a tool that
perform the services. the United States by a resident of the United will ask you questions on a number of tax
States who either: law topics and provide answers. You can
Pensions paid by Turkey for services per­ Is a U.S. citizen, or print the entire interview and the final re­
formed for Turkey are exempt from U.S. income Did not become a U.S. resident only to sponse.
tax unless the recipient is both a resident and perform the services. Enter “Pub 17” in the search box on
citizen of the United States. IRS.gov to get Pub. 17, Your Federal In­
Pensions paid by Venezuela, its political come Tax for Individuals, which features
These exemptions do not apply to income or subdivisions, or local authorities for services details on tax­saving opportunities, 2015
pensions for services performed in connection performed for Venezuela are exempt from U.S. tax changes, and thousands of interactive
with a business carried on by Turkey or its sub­ income tax unless the recipient is both a resi­ links to help you find answers to your ques­
divisions or local authorities. dent and citizen of the United States. tions.
Additionally, you may be able to access
tax law information in your electronic filing
Ukraine These exemptions do not apply to payments
software.
or pensions for services performed in connec­
Income, other than a pension, paid from public tion with a business carried on by Venezuela,
funds of Ukraine, its political subdivisions, or lo­ its political subdivisions, or local authorities. Tax forms and publications. You can down­
cal authorities to an individual for services per­ load or print all of the forms and publications
formed in the discharge of governmental func­ you may need on www.irs.gov/formspubs. Oth­
tions is exempt from U.S. income tax. However, How To Get Tax Help erwise, you can go to www.irs.gov/orderforms
the exemption does not apply if the services are to place an order and have forms mailed to you.
performed in the United States by a resident of You can get help with unresolved tax issues, or­ You should receive your order within 10 busi­
the United States who either: der free publications and forms, ask tax ques­ ness days.
Is a U.S. citizen, or tions, and get information from the IRS in sev­
Did not become a U.S. resident only to eral ways. By selecting the method that is best Direct deposit. The fastest way to receive a
perform the services. for you, you will have quick and easy access to tax refund is by combining direct deposit and
tax help. IRS e-file. Direct deposit securely and electroni­
Pensions paid by, or by funds created by, cally transfers your refund directly into your fi­
Ukraine, its political subdivisions, or local au­ nancial account. Eight in 10 taxpayers use di­
thorities for services performed for Ukraine are
exempt from U.S. income tax unless the recipi­
Taxpayer Assistance rect deposit to receive their refund. The majority
of refunds are received within 21 days or less.
ent is both a resident and citizen of the United Inside the United States
States. Getting a transcript or copy of a return.
Preparing and filing your tax return. Find Go to IRS.gov and click on “Get Transcript
These exemptions do not apply to income or free options to prepare and file your return on of Your Tax Records” under “Tools.”
pensions for services performed in connection IRS.gov or in your local community if you qual­ Call the transcript toll­free line at
with a trade or business carried on by Ukraine, ify. 1­800­908­9946.
its political subdivisions, or local authorities. Go to IRS.gov and click on the Filing tab to Mail Form 4506­T or Form 4506T­EZ (both
see your options. available on IRS.gov).
United Kingdom Enter “Free File” in the search box to see
whether you can use brand­name software Using online tools to help prepare your re-
Income, other than a pension, paid from the to prepare and e-file your federal tax return turn. Go to IRS.gov and click on the Tools bar
public funds of the United Kingdom, its political for free. to use these and other self­service options.
subdivisions, or local authorities to an individual Enter “VITA” in the search box, download The Earned Income Tax Credit Assistant
for services performed for the paying govern­ the free IRS2Go app, or call determines if you are eligible for the EIC.
mental body is exempt from U.S. income tax. 1­800­906­9887 to find the nearest Volun­ The Online EIN Application helps you get
However, the exemption does not apply if the teer Income Tax Assistance or Tax Coun­ an employer identification number.
services are performed in the United States by seling for the Elderly (TCE) location for free The IRS Withholding Calculator estimates
a resident of the United States who either: tax preparation. the amount you should have withheld from
Is a U.S. citizen, or Enter “TCE” in the search box, download your paycheck for federal income tax pur­
Did not become a U.S. resident only to the free IRS2Go app, or call poses.
perform the services. 1­888­227­7669 to find the nearest Tax The Electronic Filing PIN Request helps to
Counseling for the Elderly location for free verify your identity when you do not have
Pensions paid by, or funds created by, the tax preparation. your prior year AGI or prior year self­selec­
United Kingdom, its political subdivisions, or lo­ ted PIN available.
The Volunteer Income Tax Assistance
cal authorities for services performed for the The First Time Homebuyer Credit Account
(VITA) program offers free tax help to people
United Kingdom are exempt from U.S. income Look-up tool provides information on your
who generally make $54,000 or less, persons
tax unless the recipient is both a resident and repayments and account balance.
with disabilities, the elderly, and limited­Eng­
citizen of the United States. lish­speaking taxpayers who need help prepar­ For help with the alternative minimum tax,
ing their own tax returns. The Tax Counseling go to IRS.gov/AMT.
These exemptions do not apply to income or for the Elderly (TCE) program offers free tax
pensions for services performed in connection help for all taxpayers, particularly those who are

Publication 901 (September 2016) Page 33


Understanding identity theft issues. on IRS.gov. Enter “office locator” in the search www.taxpayeradvocate.irs.gov. You can also
Go to www.irs.gov/uac/Identity-Protection box. Or choose the “Contact Us” option on the call us at 1­877­777­4778.
for information and videos. IRS2Go app and search Local Offices. Before
If your SSN has been lost or stolen or you you visit, use the Locator tool to check hours How Can You Learn About Your
suspect you are a victim of tax­related and services available. Taxpayer Rights?
identity theft, visit www.irs.gov/identitytheft
to learn what steps you should take. Watching IRS videos. The IRS Video portal The Taxpayer Bill of Rights describes ten basic
www.irsvideos.gov contains video and audio rights that all taxpayers have when dealing with
Checking on the status of a refund. presentations for individuals, small businesses, the IRS. Our Tax Toolkit at
Go to www.irs.gov/refunds. and tax professionals. You’ll find video clips of www.taxpayeradvocate.irs.gov can help you
Download the free IRS2Go app to your tax topics, archived versions of panel discus­ understand what these rights mean to you and
smart phone and use it to check your re­ sions and Webinars, and audio archives of tax how they apply. These are your rights. Know
fund status. practitioner phone forums. them. Use them.
Call the automated refund hotline at
1­800­829­1954. Getting tax information in other languages.
For taxpayers whose native language is not How Else Does the Taxpayer
Making a tax payment. The IRS uses the lat­ English, we have the following resources availa­ Advocate Service Help Taxpayers?
est encryption technology so electronic pay­ ble.
ments are safe and secure. You can make elec­ TAS works to resolve large­scale problems that
1. Taxpayers can find information on IRS.gov affect many taxpayers. If you know of one of
tronic payments online, by phone, or from a
in the following languages. these broad issues, please report it to us at
mobile device. Paying electronically is quick,
easy, and faster than mailing in a check or a. Spanish. www.irs.gov/sams.
money order. Go to www.irs.gov/payments to b. Chinese.
make a payment using any of the following op­
c. Vietnamese.
Low Income Taxpayer
tions.
IRS Direct Pay (for individual taxpayers
Clinics
d. Korean.
who have a checking or savings account).
e. Russian. Low Income Taxpayer Clinics (LITCs) serve in­
Debit or credit card (approved payment
dividuals whose income is below a certain level
processors online or by phone). 2. The IRS Taxpayer Assistance Centers and need to resolve tax problems such as au­
Electronic Funds Withdrawal (available provide over­the­phone interpreter service dits, appeals, and tax collection disputes. Some
during e-file). in over 170 languages, and the service is clinics can provide information about taxpayer
Electronic Federal Tax Payment Sys- available free to taxpayers. rights and responsibilities in different languages
tem (best option for businesses; enroll­
for individuals who speak English as a second
ment required).
Check or money order. The Taxpayer Advocate language. To find a clinic near you, visit
IRS2Go provides access to mobile­friendly Service Is Here To Help You www.irs.gov/litc or see IRS Publication 4134,
Low Income Taxpayer Clinic List.
payment options like IRS Direct Pay, offer­
What is the Taxpayer Advocate
ing you a free, secure way to pay directly
Service?
from your bank account. You can also
make debit or credit card payments Taxpayer Assistance
The Taxpayer Advocate Service (TAS) is an in­
through an approved payment processor.
Simply download IRS2Go from Google
dependent organization within the Internal Outside the United
Play, the Apple App Store, or the Amazon
Revenue Service that helps taxpayers and pro­
tects taxpayer rights. Our job is to ensure that
States
Appstore, and make your payments any­
every taxpayer is treated fairly and that you If you are outside the United States,
time, anywhere.
know and understand your rights under the you can call 267­941­1000 (Eng­
Taxpayer Bill of Rights. lish­speaking only). This number is not
What if I can’t pay now? Click on the “Pay
Your Tax Bill” icon on IRS.gov for more informa­ toll free.
tion about these additional options. What Can the Taxpayer Advocate
Apply for an online payment agreement to Service Do For You? If you wish to write instead of calling,
meet your tax obligation in monthly install­ please address your letter to:
ments if you cannot pay your taxes in full We can help you resolve problems that you
today. Once you complete the online proc­ can’t resolve with the IRS. And our service is
ess, you will receive immediate notification free. If you qualify for our assistance, you will be Internal Revenue Service
of whether your agreement has been ap­ assigned to one advocate who will work with International Accounts
proved. you throughout the process and will do every­ Philadelphia, PA 19255­0725
An offer in compromise allows you to settle thing possible to resolve your issue. TAS can U.S.A.
your tax debt for less than the full amount help you if:
you owe. Use the Offer in Compromise Your problem is causing financial difficulty
Pre-Qualifier to confirm your eligibility. for you, your family, or your business,
Additional contact information for taxpayers
You face (or your business is facing) an
who live outside the U.S. is available at
Checking the status of an amended return. immediate threat of adverse action, or
www.irs.gov/uac/Contact-My-Local-Office-
Go to IRS.gov and click on the Tools tab and You’ve tried repeatedly to contact the IRS
Internationally.
then Where’s My Amended Return? but no one has responded, or the IRS
hasn’t responded by the date promised. Taxpayer Advocate International. You can
Understanding an IRS notice or letter. Enter call the Taxpayer Advocate toll­free at
“Understanding your notice” in the search box How Can You Reach Us? 1­877­777­4778. For more information on the
on IRS.gov to find additional information about Taxpayer Advocate Service and contacts if you
your IRS notice or letter. We have offices in every state, the District of are outside of the United States go to
Columbia, and Puerto Rico. Your local advo­ www.irs.gov/Advocate/Local-Taxpayer-
Visiting the IRS. Locate the nearest Taxpayer cate’s number is in your local directory and at Advocate/Contact-Your-Local-Taxpayer-
Assistance Center using the Office Locator tool Advocate.

Page 34 Publication 901 (September 2016)

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