PDF document
- 1 -
                Userid: CPM                 Schema: tipx         Leadpct: 100% Pt. size: 8   Draft                Ok to Print
AH XSL/XML      Fileid: … ons/P901/201609/B/XML/Cycle01/source                             (Init. & Date) _______

Page 1 of 34                                                                               10:19 ­ 12­Oct­2016

The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

            Publication 901
            (Rev. September 2016)                                              Contents
            Cat. No. 46849F                                                    Reminders . . . . . . . . . . . . . . . . . . . 1
Department 
of the                                                                         Introduction . . . . . . . . . . . . . . . . . . 1
Treasury
Internal    U.S. Tax                                                           Application of Treaties   . . . . . . . . . . . 2
Revenue 
Service                                                                        Tax Exemptions Provided by 
            Treaties                                                           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



- 2 -
Page 2 of 34           Fileid: … ons/P901/201609/B/XML/Cycle01/source                                                     10:19 ­ 12­Oct­2016

The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

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                                                              alties,  or  to  a  reduced  rate  of  tax  on  pay  re­
                                                        Publication
!        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 
For more detailed information on treaty ben­              597 Information on the United States–
efits, you should consult the text of the applica­            Canada Income Tax Treaty                         and the Form 8833 instructions.
                                                                                                               If you fail to file Form 8833, you may have to 
ble  treaty.  The  treaties  are  available  at         Form (and Instructions)                                pay a $1,000 penalty. Corporations are subject 
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                  7701(b)                                          Tax Exemptions
your comments about this publication and your 
suggestions for future editions.                        See How To Get Tax Help near the end of this           Provided by Treaties
You  can  send  us  comments  from     www/             publication  for  information  about  getting  these 
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:                                                                                          the  tax  treaties  on  the  following  types  of  in­
                                                        Application of Treaties                                come.
      Internal Revenue Service                                                                                 Pay for certain personal services per­
      Business Forms and Publications Branch            The  United  States  has  income  tax  treaties        formed in the United States.
      SE:W:CAR:MP:T:B                                   with a number of foreign countries. Under these        Pay of a professor, teacher, or researcher 
      1111 Constitution Ave. NW, IR­6526                treaties,  residents  (not  necessarily  citizens)  of who teaches or performs research in the 
      Washington, DC 20224                              foreign countries are taxed at a reduced rate, or      United States for a limited time.
                                                        are exempt from U.S. income taxes on certain           Amounts received for maintenance and 
We  respond  to  many  letters  by  telephone.          items  of  income  they  receive  from  sources        studies by a foreign student or apprentice 
Therefore,  it  would  be  helpful  if  you  would  in­ within  the  United  States.  These  reduced  rates    who is here for study or experience.
clude  your  daytime  phone  number,  including         and exemptions vary among countries and spe­           Wages, salaries, and pensions paid by a 
the area code, in your correspondence.                  cific items of income.                                 foreign government.
Although we cannot respond individually to 
each comment received, we do appreciate your            If  there  is  no  treaty  between  your  country      Personal Services Income
feedback  and  will  consider  your  comments  as       and the United States, you must pay tax on the 
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                                                                    discussed below, if you are in the United States 
publications.  Otherwise,  you  can  go  to             Many  of  the  individual  states  of  the  United 
www.irs.gov/orderforms  to  order  current  and         States tax the income of their residents. There­       for  a  limited  number  of  days,  and  if  you  meet 
prior  year  forms  and  instructions.  Your  oder      fore,  you  should  consult  the  tax  authorities  of certain  other  conditions.  For  this  purpose,  the 
should arrive within 10 business days.                  the state in which you live to find out if that state  word  “day”  means  a  day  during  any  part  of 
                                                        taxes  the  income  of  individuals  and,  if  so,     which you are physically present in the United 
      Internal Revenue Service                          whether the tax applies to any of your income.         States.
      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   The terms fixed base and permanent estab­
complete  information  about  treaty  provisions        U.S.  citizen  or  resident  who  receives  income     lishment generally mean a fixed place of busi­
from  the  taxing  authority  in  the  country  from    from a treaty country may refer to the tables in       ness,  such  as  a  place  of  management,  a 
which you receive income or from the treaty it­         this publication to see if a tax treaty might affect   branch, an office, a factory, a warehouse, or a 
self.                                                   the tax to be paid to that foreign country. For­       mining site, through which an enterprise carries 
You can obtain the text of most of the trea­            eign taxing authorities sometimes require certifi­     on its business.
ties  at www.irs.gov/businesses/international.          cation from the U.S. Government that an appli­
You can also obtain the text of most of the trea­       cant filed an income tax return as a U.S. citizen      The term borne by generally means having 
ties at the following address:                          or resident, as part of the proof of entitlement to    ultimate  financial  accounting  responsibility  for, 
                                                        the treaty benefits. See Form 8802, Application        or providing the monetary resources for, an ex­
      Department of the Treasury                        for United States Residency Certification, to re­      penditure or payment, even if another entity in 
      Office of Public Correspondence                   quest a certification.                                 another location actually made the expenditure 
      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)



- 3 -
Page 3 of 34            Fileid: … ons/P901/201609/B/XML/Cycle01/source                                                 10:19 ­ 12­Oct­2016

The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

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 
If they have a fixed base available in the United                                                               contractors are not U.S. residents), and
States, they are taxed on the income attributa­         Income that residents of Bangladesh receive for         Do not have a regular base available in the 
ble to the fixed base.                                  performing  personal  services  as  independent         United States for performing the services.
                                                        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.           Belgium
empt from U.S. income tax if the residents meet 
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       Income that residents of Belgium receive for 
athletes)  from  Austria  who  earn  more  than         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%.                                 ployees  (dependent  personal  services)  is  ex­
expenses, from their entertainment activities in 
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



- 4 -
Page 4 of 34        Fileid: … ons/P901/201609/B/XML/Cycle01/source                                                           10:19 ­ 12­Oct­2016

The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

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           Income that residents of Canada receive for              agreed upon by the U.S. and Chinese govern­
aircraft  operated  in  international  traffic  is  ex­ personal services performed as employees (de­            ments is exempt from U.S. tax.
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.
United States.                                          Income that residents of the People's Republic 
                                                        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'              als  (independent  personal  services)  that  they       services  performed  as  employees  (dependent 
fees  and  similar  payments  received  by  a  resi­    perform during the tax year in the United States         personal services), including services as an offi­
dent of Bulgaria as a member of the board of di­        is exempt from U.S. income tax if the residents:         cer  of  a  corporation,  is  exempt  from  U.S.  in­
rectors of a U.S. company.                              Are present in the United States for no                  come tax if:
                                                        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)



- 5 -
Page 5 of 34           Fileid: … ons/P901/201609/B/XML/Cycle01/source                                                  10:19 ­ 12­Oct­2016

The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

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 
Directors' fees received by residents of Cy­             or  self­employed  individuals  (independent  per­     traffic by a resident of the United States.
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'            If  they  have  a  fixed  base  available,  they  are 
taxed  only  on  income  attributable  to  the  fixed    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



- 6 -
Page 6 of 34            Fileid: … ons/P901/201609/B/XML/Cycle01/source                                                    10:19 ­ 12­Oct­2016

The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

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
residents meet three requirements.                      rectors  of  a  company  that  is  a  resident  of  the Hungary
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 
France                                                  The income is paid by, or on behalf of, an              employer who is not a resident of the Uni­
                                                        employer who is not a resident of the Uni­              ted States.
Income that residents of France receive for per­        ted States.                                             Their income is not borne by a permanent 
forming personal services as independent con­           The income is not borne by a permanent                  establishment or a fixed base that the em­
tractors or self­employed individuals (independ­        establishment that the employer has in the              ployer has in the United States.
ent  personal  services)  in  the  United  States  is   United States.
exempt  from  U.S.  income  tax  if  they  do  not                                                              Pay  received  by  an  employee  who  is  a 
have a fixed base regularly available to them in        Pay  received  by  a  resident  of  Germany  for        member of the regular complement of a ship or 
the United States for performing the services. If       services performed as an employee and mem­              aircraft  operated  by  a  Hungarian  enterprise  in 
they  have  a  fixed  base  available  in  the  United  ber of the regular complement of a ship or air­         international  traffic  is  exempt  from  U.S.  tax.  If 
States, they are taxed on the income attributa­         craft  operated  in  international  traffic  is  exempt the ship or aircraft is operated by a U.S. enter­
ble to the fixed base.                                  from U.S. tax.                                          prise, the pay is subject to U.S. tax.

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)



- 7 -
Page 7 of 34           Fileid: … ons/P901/201609/B/XML/Cycle01/source                                                   10:19 ­ 12­Oct­2016

The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

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.                                   If they have a fixed base available, they are             attending meetings in Ireland are not subject to 
                                                        taxed  only  on  the  income  attributable  to  the       U.S. income tax.
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



- 8 -
Page 8 of 34              Fileid: … ons/P901/201609/B/XML/Cycle01/source                                                   10:19 ­ 12­Oct­2016

The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

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 
These exemptions do not apply to directors'              ses)  from  the  services  are  more  than  $400  a    are taxed only on the income attributable to the 
fees  and  similar  payments  received  by  a  resi­     day or $5,000 for the tax year.                        fixed base.

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
a company that is a U.S. resident.                       maica  for  services  performed  in  the  United       for  employment  in  the  United  States  (depend­
                                                         States  as  members  of  boards  of  directors  of     ent  personal  services)  is  exempt  from  U.S.  in­
                                                         U.S.  corporations  are  exempt  from  U.S.  tax  if   come tax if the following three requirements are 
Pay received for employment regularly exer­              the  fees  (excluding  reimbursed  expenses)  are      met.
cised  aboard  a  ship  or  aircraft  operated  by  a    not more than $400 per day for each day the di­            The resident is in the United States for no 
U.S. enterprise is subject to U.S. tax.                  rectors are present in the United States to per­           more than 183 days in any 12­month pe­
                                                         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.
                                                                                                                    The income is not borne by a permanent 
sion  artists,  musicians,  or  athletes)  if  they  are Income that residents of Japan receive for per­            establishment or a fixed base that the em­
present  in  the  United  States  for  more  than  90    sonal  services  as  independent  contractors  or          ployer has in the United States.
days during the tax year or their gross receipts,        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         Under  that  provision,  business  profits  are  ex­   Income derived by a resident of Kazakhstan 
ment activities in the United States.                    empt from U.S. income tax unless the individual        from  employment  as  a  member  of  the  regular 
                                                         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)



- 9 -
Page 9 of 34               Fileid: … ons/P901/201609/B/XML/Cycle01/source                                              10:19 ­ 12­Oct­2016

The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

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



- 10 -
Page 10 of 34             Fileid: … ons/P901/201609/B/XML/Cycle01/source                                             10:19 ­ 12­Oct­2016

The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

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 
                                                       for labor or personal services performed in the       resident of the United States.
                                                       United  States  as  employees  (dependent  per­       These  exemptions  do  not  apply  to  income 
Mexico                                                 sonal services) is exempt from U.S. income tax        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 
Are in the United States for no more than              resident of a country other than Morocco if 
182 days in a 12­month period, and                     the permanent establishment is located in             New Zealand
Do not have a fixed base that they regu­               Morocco.
larly use for performing the services.                 Their income is not borne by a permanent              Income that residents of New Zealand receive 
                                                       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'            musicians, and athletes, unless the services are      employer that is not a resident of the Uni­
fees  and  similar  payments  received  by  a  resi­   performed by, or for the account of, a Moroccan       ted States.
dent  of  Mexico  for  services  performed  outside    nonprofit organization.                               Their income is not borne by a permanent 
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          Income  that  residents  of  the  Netherlands  re­    The exemption does not apply to public en­
residents of Mexico receive as public entertain­       ceive for performing personal services as inde­       tertainers (artists, athletes, etc.) from New Zea­
ers  (such  as  theater,  motion  picture,  radio,  or pendent  contractors  or  self­employed  individu­    land who earn more than $10,000 in gross re­
television artists, or musicians) or athletes if the   als  (independent  personal  services)  in  the       ceipts,  including  reimbursed  expenses,  from 
income,  including  reimbursed  expenses,  is          United States is exempt from U.S. income tax if       their  entertainment  activities  in  the  United 
more  than  $3,000  during  the  tax  year  for  their the income is not attributable to a fixed base in     States during the tax year.
entertainment  activities  in  the  United  States.    the United States that is regularly available for     Pay received by a New Zealand resident as 
This includes income from activities performed         performing the services.                              an employee and member of the regular com­
in the United States relating to the entertainer or 
athlete's  reputation,  such  as  endorsements  of     Income that residents of the Netherlands re­          plement of a ship or aircraft operated in interna­
commercial  products.  Regardless  of  this  limit,    ceive for employment in the United States (de­        tional traffic is exempt from U.S. tax.
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)



- 11 -
Page 11 of 34             Fileid: … ons/P901/201609/B/XML/Cycle01/source                                                 10:19 ­ 12­Oct­2016

The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

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         If they have a fixed base available in the United     national traffic is exempt from U.S. tax.
contractors  or  self­employed  individuals  (inde­     States, they are taxed only on the income attrib­
pendent personal services) in the United States         utable to the fixed base. There is no dollar limit    Portugal
during the tax year is exempt from U.S. income          for condition (2) if the contractor is a resident of 
tax if the residents:                                   a country other than the United States.               Income  that  residents  of  Portugal  receive  for 
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                                                                employment  in  the  United  States  (dependent 
pay for services as public entertainers is more         Pay received by an employee of a resident 
than $10,000 during the tax year.                       of  the  Philippines  for  personal  services  per­   personal services) is exempt from U.S. income 
                                                        formed as a member of the regular complement          tax if the following three requirements are met.
Income that residents of Norway receive for             of a ship or an aircraft operated in international    The resident is in the United States for no 
labor or personal services performed in the Uni­        traffic by a resident of the Philippines is exempt    more than 183 days in any 12­month pe­
ted  States  as  employees  (dependent  personal        from U.S. tax.                                        riod.
                                                                                                              The income is paid by, or on behalf of, an 
services) is exempt from U.S. income tax if the                                                               employer who is not a U.S. resident.
residents meet three requirements.                      These  exemptions  do  not  apply  to  income 
They are in the United States less than 183             residents of the Philippines receive for perform­     The income is not borne by a permanent 
days during the tax year.                               ing services (both independent and dependent          establishment or fixed base that the em­
They are employees of a resident of Nor­                personal  services)  in  the  United  States  as  en­ ployer has in the United States.
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
ject to Pakistani tax.                                  ing services performed by an officer of a corpo­
                                                        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 
                                                        They are in the United States for no more             performing  personal  services  as  independent 
Income that residents of the Philippines receive        than 182 days during the tax year.                    contractors  or  self­employed  individuals  (inde­
for  performing  personal  services  as  independ­      Their income is paid by or on behalf of an            pendent personal services) in the United States 
ent contractors or as self­employed individuals         employer who is not a U.S. resident.                  during the tax year is exempt from U.S. income 
(independent  personal  services)  in  the  United      Their income is not borne by a permanent              tax if the residents:
States during the tax year is exempt from U.S.          establishment that the employer has in the            Are present in the United States for no 
income tax if the residents:                            United States.                                        more than 182 days during the tax year, 
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



- 12 -
Page 12 of 34   Fileid: … ons/P901/201609/B/XML/Cycle01/source                                                              10:19 ­ 12­Oct­2016

The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

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.                     Income from technical services directly con­               the income is subject to U.S. income tax.
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.                                         the use of the right or property.                          Income  that  residents  of  Slovenia  receive  for 
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 
These exemptions do not apply to entertain­            dent of Russia as a member of the board of di­             from U.S. income tax if they do not have a fixed 
ers,  such  as  theater,  motion  picture,  radio,  or rectors  or  similar  body  of  a  company  that  is  a    base  regularly  available  to  them  in  the  United 
television  artists,  musicians,  or  athletes,  who   resident of the United States.                             States for performing the services. If they have 
                                                                                                                  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
Pay received by employees who are mem­                      Do not have a fixed base regularly availa­            Their income is paid by, or on behalf of, an 
bers of the regular complement of a ship or air­            ble to them in the United States for per­             employer who is not a U.S. resident.
craft operated by a resident of Romania in inter­           forming the activities.                               Their income is not borne by a permanent 
                                                                                                                  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           South Africa
ted States.                                            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)



- 13 -
Page 13 of 34           Fileid: … ons/P901/201609/B/XML/Cycle01/source                                                   10:19 ­ 12­Oct­2016

The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

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.
If  they  have  a  fixed  base  available,  they  are    ated in international traffic by a U.S. enterprise.
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    for services performed in the United States as           These  exemptions  do  not  apply  to  income 
the United States is wholly or mainly supported          employees  (dependent  personal  services)  is           residents  of  Sweden  receive  as  public  enter­
by public funds of South Africa, its political sub­      exempt  from  U.S.  income  tax  if  the  residents      tainers  (such  as  theater,  motion  picture,  radio, 
divisions, or local authorities.                         meet the following requirements.                         or television artists, or musicians) or athletes if 
                                                         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



- 14 -
Page 14 of 34              Fileid: … ons/P901/201609/B/XML/Cycle01/source                                                   10:19 ­ 12­Oct­2016

The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

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 
                                                                                                                  residents of Tunisia receive as public entertain­
expenses, from their entertainment activities in         Income (including reimbursed travel expenses)            ers  (such  as  theater,  motion  picture,  radio,  or 
the United States during the tax year.                   that  residents  of  Trinidad  and  Tobago  receive      television  artists,  and  musicians)  or  athletes  if 
                                                         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.          penses,  are  more  than  $7,500  during  the  tax 
land  for  services  performed  as  an  employee         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:                                         These  exemptions  do  not  apply  to  fees  re­
exempt from U.S. income tax.                             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
                                                                                                                  forming personal services as independent con­
Are in the United States for no more than                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      ent  personal  services)  in  the  United  States  is 
Do not have a fixed base regularly availa­               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              Are in the United States for purposes of 
forming their services.                                  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.                          If  they  have  a  fixed  base  available,  they  are 
pendent  personal  services  and  that  income  is 
                                                                                                                  taxed  only  on  income  attributable  to  the  fixed 
paid  by  a  U.S.  resident  or  borne  by  a  perma­    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.                                                                                  This exemption does not apply to a resident 
                                                         If  they  do  not  meet  condition  (2),  they  are 
These exemptions do not apply to directors'              taxed  on  the  income  that  is  attributable  to  the  of Turkey who performs services as a member 
fees  and  similar  payments  received  by  a  resi­     fixed base.                                              of  the  regular  complement  of  a  ship  or  an  air­
                                                                                                                  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)



- 15 -
Page 15 of 34        Fileid: … ons/P901/201609/B/XML/Cycle01/source                                                         10:19 ­ 12­Oct­2016

The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

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                                                                Professors, Teachers,
performing  personal  services  as  independent             The exemption does not apply to directors' 
contractors  or  self­employed  individuals  (inde­         fees  and  similar  payments  received  by  a  resi­  and Researchers
pendent personal services) in the United States             dent  of  the  United  Kingdom  for  services  per­
is exempt from U.S. income tax if the income is             formed in the United States as a member of the        Pay  of  professors  and  teachers  who  are  resi­
not  attributable  to  a  fixed  base  in  the  United      board of directors of a company resident in the       dents of the following countries is generally ex­
States that is regularly available for performing           United States.                                        empt  from  U.S.  income  tax  for  2  or  3  years  if 
                                                                                                                  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                athletes)  from  the  United  Kingdom  who  earn      ing  the  applicable  period.  For  most  of  the  fol­
employment  in  the  United  States  (dependent             more than $20,000 in gross receipts, including        lowing  countries,  the  applicable  period  begins 
personal services) is exempt from U.S. income               reimbursed expenses, from their entertainment         on the date of arrival in the United States for the 
tax if the following three requirements are met.            activities  in  the  United  States  during  the  tax purpose  of  teaching  or  engaging  in  research. 
The resident is in the United States for no                 year are subject to U.S. tax.                         Furthermore, for most of the following countries, 
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 exemption generally applies to pay re­
The income is not borne by a permanent                      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.                   both  are  completed  within  the  specified  time, 
ployer has in the United States.
                                                                                                                  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 
dent of Ukraine for services performed outside              Income that residents of Venezuela receive for        listed, the conditions are stated under which the 
of Ukraine as a member of the board of direc­               personal  services  as  independent  contractors      pay of a professor or teacher from that country 
tors of a company that is a resident of the Uni­            or  self­employed  individuals  (independent  per­    is exempt from U.S. income tax.
ted States.                                                 sonal  services) in the United States is exempt 
                                                            from U.S. income tax if they do not have a fixed      If you do not meet the requirements for ex­
                                                            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                  States for performing the services. If they have      a  treaty  country  that  does  not  have  a  special 
income  received  as  a  public  entertainer  (such         a fixed base available, they are taxed on the in­     provision for teachers, you may qualify under a 
as a theater, motion picture, radio, or television          come attributable to the fixed base.                  personal  services  income  provision  discussed 
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           for services performed in the United States as        Bangladesh
States  is  substantially  supported  by  public            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



- 16 -
Page 16 of 34           Fileid: … ons/P901/201609/B/XML/Cycle01/source                                                    10:19 ­ 12­Oct­2016

The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

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            tion is exempt from U.S. income tax on income           Hungary
from research carried on mainly for the private          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          An individual who is a resident of France on the        Iceland
terprise of the United States or a foreign trade         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)



- 17 -
Page 17 of 34            Fileid: … ons/P901/201609/B/XML/Cycle01/source                                                    10:19 ­ 12­Oct­2016

The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

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 
An individual who is a resident of Israel on the        benefit  of  any  person  rather  than  in  the  public  public interest. Nor does the exemption apply if 
date of arrival in the United States and who is         interest.                                                the resident claimed during the immediate pre­
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



- 18 -
Page 18 of 34           Fileid: … ons/P901/201609/B/XML/Cycle01/source                                                      10:19 ­ 12­Oct­2016

The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

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
Poland                                                  diately before visiting the United States,              This  exemption  does  not  apply  to  income 
                                                        and                                                     from research carried on mainly for the private 
An individual who is a resident of Poland on the        Is in the United States primarily to teach or           benefit  of  any  person  rather  than  in  the  public 
date of arrival in the United States and who is         conduct research at a university, college,              interest.  Nor  does  the  exemption  apply  to  in­
temporarily in the United States at the invitation      school, or other accredited educational or              come if an agreement exists between the Gov­
of  the  U.S.  Government,  a  university,  or  other   research institution.                                   ernments of Trinidad and Tobago and the Uni­
recognized educational institution in the United                                                                ted  States  for  providing  the  services  of  these 
States primarily to teach or engage in research,        A Slovak resident is entitled to these bene­            individuals.
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 
The exemption does not apply if the resident            primarily for the private benefit of a specific         years for the purpose of teaching or engaging in 
claimed, during the immediately preceding pe­           person or persons.                                      scientific research is exempt from U.S. income 
riod,  the  benefits  described  later  under Stu-                                                              tax on payments received from outside the Uni­
dents and Apprentices.                                  Slovenia                                                ted States for teaching or research.

This  exemption  does  not  apply  to  income           An  individual  who  is  a  resident  of  Slovenia  on  United Kingdom
from research carried on mainly for the private         the date of arrival in the United States and who 
benefit  of  any  person  rather  than  in  the  public temporarily visits the United States to teach or        A professor or teacher who is a resident of the 
interest.                                               engage in research at a recognized educational          United Kingdom on the date of arrival in the Uni­
                                                        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
is entitled to these benefits only once. However,       the date of arrival in the United States and who 
these benefits, and the benefits described later        is  in  the  United  States  for  not  longer  than  2  An individual who is a resident of Venezuela on 
under Students  and  Apprentices   cannot  be           years primarily to teach or engage in research          the date of arrival in the United States and who 
claimed either simultaneously or consecutively.         at a university, college, school, or other recog­       temporarily visits the United States to teach or 
                                                        nized  educational  institution  is  exempt  from       engage in research at a recognized educational 
Page 18                                                                                                                  Publication 901 (September 2016)



- 19 -
Page 19 of 34           Fileid: … ons/P901/201609/B/XML/Cycle01/source                                                      10:19 ­ 12­Oct­2016

The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

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          1. Studying at a university, college, school,           A student or business trainee who is a resident 
the  date  of  arrival  in  the  United  States.  This  or other recognized educational institution             of Bulgaria immediately before visiting the Uni­
benefit  can  be  claimed  for  no  more  than  5       in the United States,                                   ted  States  and  is  in  the  United  States  for  the 
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         3. Studying or doing research as a recipient            empt  from  U.S.  income  tax  on  the  following 
benefit  of  any  person  rather  than  in  the  public of a grant, allowance, or award from a                  amounts.
interest.                                               governmental, religious, charitable, or ed­             Payments received from abroad for main­
                                                        ucational organization                                  tenance, education, or training.
                                                                                                                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
This exemption does not apply to the salary             for the tax year.                                       dividual who is temporarily in the United States:
                                                                                                                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
try  who  is  temporarily  in  the  United  States  to  emption  from  tax  applies  for  not  more  than  2    As an employee of, or under contract with, 
study a particular industry for an employer. That       years from the date the individual first arrived in     a resident of Bulgaria, for the primary pur­
amount is a continuation of salary and is not re­       the United States.                                      pose of acquiring technical, professional, 
                                                                                                                or business experience from a person 
ceived to study or acquire experience.                                                                          other than that resident of Bulgaria or other 
                                                        Barbados
For each country listed there is a statement                                                                    than a person related to that resident.
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.       Nevertheless, an individual who qualifies for           tax on amounts received from sources outside 
Amounts  received  from  NIH  under  the  Visiting      this  exemption  may  instead  choose  to  be           the  United  States  for  maintenance,  education, 
Associate  Program  and  Visiting  Scientist  Pro­      treated as a resident alien of the United States        or training.
gram are not exempt from U.S. tax as a grant,           for  all  U.S.  income  tax  purposes.  Once  made,     Apprentices and business trainees are enti­
allowance, or award.                                    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 
Australia                                               may  not  be  revoked  without  the  permission  of     mum period of 1 year.
                                                        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         A student, business apprentice, or trainee who 
ted  States  for  the  individual's  maintenance  or    ted  States  and  is  in  the  United  States  for  the is a resident of the People's Republic of China 
education.                                              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                 perience is exempt from U.S. income tax on the 
A student, apprentice, or business trainee who          tenance, education, or training.                        following amounts.
is a resident of Austria immediately before visit­      Income from personal services of up to                  Payments received from abroad for main­
ing the United States and is in the United States       $9,000 for each tax year.                               tenance, education, study, research, or 
for the purpose of full­time education at a recog­
                                                                                                                training.
nized educational institution or full­time 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       entific, educational, or other tax­exempt or­
ceived from sources outside the United States           mum period of 2 years.                                  ganization.
for  the  individual's  maintenance,  education,  or 
                                                                                                                Income from personal services performed 
training.                                               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



- 20 -
Page 20 of 34        Fileid: … ons/P901/201609/B/XML/Cycle01/source                                                     10:19 ­ 12­Oct­2016

The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

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
                                                                                                                 mum period of 3 years.
amounts  received  from  that  resident.  Also  ex­       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              Studying at a university or other accredited           An individual who is a resident of Egypt on the 
United States under an exchange program pro­              educational institution in the United States,          date of arrival in the United States and who is 
vided  for  by  an  agreement  between  govern­           Obtaining training required to qualify him or          temporarily  in  the  United  States  primarily  to 
ments  on  cooperation  in  various  fields  of  sci­     her to practice a profession or professional           study at a university or other recognized educa­
ence  and  technology  is  exempt  from  U.S.             specialty, or                                          tional institution in the United States, obtain pro­
income  tax  on  all  income  received  in  connec­       Studying or doing research as a recipient              fessional training, or study or do research as a 
tion with the exchange program for a period not           of a grant, allowance, or award from a gov­            recipient of a grant, allowance, or award from a 
longer than 1 year.                                       ernmental, religious, charitable, scientific,          governmental,  religious,  charitable,  scientific, 
                                                          literary, or educational organization.                 literary,  or  educational  organization  is  exempt 
Cyprus                                                    If  the  individual  meets  any  of  these  require­   from U.S. income tax on the following amounts.
An individual who is a resident of Cyprus on the          ments, the following amounts are exempt from           Gifts from abroad for maintenance, educa­
date of arrival in the United States and who is           U.S. tax.                                              tion, study, research, or training.
temporarily here primarily to study at a univer­          The payments from abroad, other than                   The grant, allowance, or award.
sity  or  other  recognized  educational  institution     compensation for personal services, for                Income from personal services performed 
in  the  United  States,  obtain  professional  train­    the purpose of maintenance, education,                 in the United States of up to $3,000 each 
ing, or study or do research as a recipient of a          study, research, or training.                          tax year.
grant, allowance, or award from a governmen­              The grant, allowance, or award.
tal,  religious,  charitable,  scientific,  literary,  or The income from personal services per­                 An individual is entitled to the benefit of this 
educational  organization  is  exempt  from  U.S.         formed in the United States of up to $5,000            exemption for a maximum of 5 tax years and for 
income tax on the following amounts.                      for the tax year.                                      any  additional  period  of  time  needed  to  com­
                                                                                                                 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 
The grant, allowance, or award.                           beginning of the visit to the United States and        or professional degree from a recognized edu­
Income from personal services performed                   who is temporarily present in the United States        cational institution.
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)



- 21 -
Page 21 of 34                Fileid: … ons/P901/201609/B/XML/Cycle01/source                                                10:19 ­ 12­Oct­2016

The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

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, 
literary,  or  educational  organization  is  exempt      Teachers, and Researchers for a maximum of 5              A student or business apprentice who is a resi­
from U.S. income tax on the following amounts.            tax years.                                                dent of Greece and is temporarily in the United 
                                                                                                                    States only to study or acquire business experi­
Payments from abroad, other than com­                                                                               ence  is  exempt  from  U.S.  income  tax  on 
pensation for personal services, for main­                This  exemption  does  not  apply  to  income 
tenance, education, study, research, or                   from research carried on mainly for the private           amounts received from sources outside the Uni­
training.                                                 benefit  of  any  person  rather  than  in  the  public   ted States for maintenance or studies.
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
An individual who is a resident of Estonia on             for  personal  services  if  the  individual  is  in  the dividual's maintenance, education, or training.
the date of arrival in the United States and who          United States primarily to:
is in the United States as an employee of, or un­         Acquire technical, professional, or busi­                 The full­time student or trainee may instead 
der  contract  with,  a  resident  of  Estonia  is  ex­   ness experience from a person other than                  choose to be treated as a resident alien of the 
empt  from  U.S.  income  tax  for  a  period  of  12     that resident of France, or                               United  States  for  U.S.  income  tax  purposes. 
consecutive  months  on  up  to  $8,000  received         Study at an educational institution.                      Once  made,  the  choice  applies  for  the  entire 
for  personal  services  if  the  individual  is  in  the                                                           period  that  the  individual  remains  qualified  for 
United States primarily to:                               Germany                                                   exemption as a full­time student or trainee and 
Acquire technical, professional, or busi­                                                                           may  not  be  changed  unless  permission  is  ob­
ness experience from a person other than                  A student or business apprentice (including Vo­           tained from the U.S. competent authority.
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.
benefit  of  any  person  rather  than  in  the  public   Individuals  described  in  the  previous  two            The grant, allowance, or award.
interest.                                                 paragraphs  are  also  exempt  from  U.S.  tax  on        Income from personal services performed 
                                                          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



- 22 -
Page 22 of 34  Fileid: … ons/P901/201609/B/XML/Cycle01/source                                                            10:19 ­ 12­Oct­2016

The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

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)



- 23 -
Page 23 of 34              Fileid: … ons/P901/201609/B/XML/Cycle01/source                                                10:19 ­ 12­Oct­2016

The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

    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 
    These  exemptions  do  not  apply  to  income       exemption for a maximum of 5 years.                     primarily  to  train,  research,  or  study  is  exempt 
                                                                                                                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:
cational  institution  in  the  United  States,  obtain Acquire technical, professional, or busi­               Luxembourg
professional training, or study or do research as       ness experience from a person other than 
a recipient of a grant, allowance, or award from        that resident of Latvia, or                             A student, apprentice, or business trainee who 
a governmental, religious, charitable, scientific,      Study at an educational institution.                    is a resident of Luxembourg immediately before 
                                                                                                                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



- 24 -
Page 24 of 34         Fileid: … ons/P901/201609/B/XML/Cycle01/source                                                         10:19 ­ 12­Oct­2016

The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

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.                                               Also exempt is a resident of Norway who is                   An individual is entitled to the benefit of this 
                                                        present in the United States for not longer than          exemption for a maximum of 5 years.
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 
or incidental to, the study, research, or               grants,  allowances,  or  awards  from  religious,           An individual who is a resident of the Philip­
training.                                               charitable,  scientific,  or  educational  organiza­      pines on the date of arrival in the United States, 
                                                        tions of Pakistan primarily to study or research.         and who is temporarily in the United States (for 
                                                        The income exempt in these cases is any pay­              no more than 1 year as a participant in a pro­
An individual is not entitled to these exemp­           ment from abroad for maintenance, education,              gram  sponsored  by  the  U.S.  Government)  pri­
tions  if,  during  the  immediately  preceding  pe­    or training, and any pay for personal services of         marily  to  train,  research,  or  study  is  exempt 
riod,  the  individual  claimed  the  exemption  dis­   not more than $5,000 for any tax year.                    from  U.S.  income  tax  on  income  received  for 
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          including  pay  from  the  enterprise  or  organiza­      An individual who is a resident of Poland on the 
was a resident of New Zealand immediately be­           tion of which they are employees or with which            date of arrival in the United States and who is 
fore  visiting  the  United  States  who  is  in  the                                                             temporarily  in  the  United  States  primarily  to 
Page 24                                                                                                                  Publication 901 (September 2016)



- 25 -
Page 25 of 34   Fileid: … ons/P901/201609/B/XML/Cycle01/source                                                             10:19 ­ 12­Oct­2016

The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

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   Slovak Republic
tax year.                                               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.                                                                              literary, or educational organization.
                                                        An individual who is a resident of Romania 
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



- 26 -
Page 26 of 34          Fileid: … ons/P901/201609/B/XML/Cycle01/source                                                         10:19 ­ 12­Oct­2016

The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

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.                                          An individual is entitled to the benefit of this ex­    ted States for the individual's maintenance, ed­
Payments from abroad (other than com­                    emption for a maximum of 5 years.                       ucation, or training.
pensation for personal services) for main­
tenance, education, study, research, or                  An  individual  who  is  a  resident  of  Spain  at     Thailand
training.                                                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 
Spain                                                    Study at a university or other recognized               the time he or she becomes temporarily present 
                                                         educational institution.                                in  the  United  States  and  who  is  temporarily 
                                                                                                                 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)



- 27 -
Page 27 of 34              Fileid: … ons/P901/201609/B/XML/Cycle01/source                                                 10:19 ­ 12­Oct­2016

The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

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    from a governmental, religious, charitable,             These  provisions  do  not  apply  to  income 
employee of, or under contract with, a resident          scientific, literary, or educational organiza­          from research carried on mainly for the private 
or  corporation  of  Trinidad  and  Tobago  is  ex­      tion.                                                   benefit  of  any  person  rather  than  in  the  public 
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:         only for a period of time necessary to complete         Wages and Pensions
Study at an educational institution, or                  the study, training, or research, but the exemp­        Paid by a Foreign
Acquire technical, professional, or busi­                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 
Tunisia                                                  training  is  exempt  from  U.S.  income  tax  on       exemption under U.S. tax law.
                                                         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



- 28 -
Page 28 of 34           Fileid: … ons/P901/201609/B/XML/Cycle01/source                                                         10:19 ­ 12­Oct­2016

The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

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.          Wages, salaries, and similar income, other than           ployee of a governmental agency or institution 
                                                          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  paid  by,  or  out  of  funds  created          pensions,  annuities,  and  similar  benefits,  paid 
Did not become a U.S. resident only to                    by,  Bulgaria,  its  political  subdivisions,  or  local  from public funds of Cyprus to a citizen of Cy­
perform the services.                                     authorities for services performed for Bulgaria,          prus  for  labor  or  personal  services  performed 
                                                          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 and national of the United States.                        Czech Republic
an individual for services performed for the pay­
ing governmental body are exempt from U.S. in­                                                                      Income, including a pension, paid from the pub­
come tax unless the recipient is both a resident          However, these exemptions do not apply to 
and citizen of the United States.                         payments for services performed in connection             lic funds of the Czech Republic, its political sub­
                                                          with a business carried on by Bulgaria, its politi­       divisions, or local authorities to a Czech citizen 
This exemption does not apply to income or                cal subdivisions, or local authorities.                   for services performed in the discharge of gov­
                                                                                                                    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 
                                                          pensions) paid by Canada or by a Canadian po­             lic, its political subdivisions, or local authorities.
Barbados                                                  litical subdivision or local authority to a citizen of 
Income, including a pension, paid from the pub­           Canada for performing governmental functions              Denmark
lic  funds  of  Barbados,  or  its  political  subdivi­   are exempt from U.S. income tax. This exemp­
sions or local authorities, to a citizen of Barba­        tion  does  not  apply,  however,  to  payments  for      Income, other than a pension, paid from public 
dos  for  performing  governmental  functions  is         services  performed  in  connection  with  a  trade       funds  of  Denmark,  its  political  subdivisions,  or 
exempt from U.S. income tax.                              or business carried on by Canada or its political         local  authorities  to  an  individual  for  services 
                                                          subdivisions or local authorities.                        performed for the paying governmental body in 
                                                                                                                    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 
ness carried on by Barbados or its political sub­         United States–Canada Income Tax Treaty.                   emption does not apply if the services are per­
                                                                                                                    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)



- 29 -
Page 29 of 34               Fileid: … ons/P901/201609/B/XML/Cycle01/source                                             10:19 ­ 12­Oct­2016

The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

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           Wages, salaries, and similar income, other than         Did not become a U.S. resident only to 
for  services  performed  in  connection  with  a       a pension, paid by Germany, its political subdi­        perform the services.
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
Finland                                                 Greece                                                  Did not become a U.S. resident only to 
                                                                                                                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



- 30 -
Page 30 of 34                Fileid: … ons/P901/201609/B/XML/Cycle01/source                                                 10:19 ­ 12­Oct­2016

The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

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:
citizen of the United States.                           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 
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
Israel                                                  Income, other than a pension, paid by Japan, its         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 
agencies,  for  services  performed  in  the  dis­      the services are performed in the United States          Lithuania
charge  of  governmental  functions,  are  exempt       by a resident of the United States who either:
from U.S. income tax. This exemption does not           Is a U.S. citizen, or                                    Income, other than a pension, paid by or from 
apply  to  citizens  of  the  United  States  or  alien Did not become a U.S. resident only to                   public  funds  of  Lithuania,  its  political  subdivi­
residents of the United States.                         perform the services.                                    sions,  or  local  authorities  to  an  individual  for 
                                                                                                                 services performed as an employee for the pay­
                                                                                                                 ing governmental body in the discharge of gov­
Italy                                                   Pensions  paid  by,  or  out  of  funds  to  which       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 
with a trade or business carried on by Italy or its     Pensions paid by Kazakhstan, or its subdivi­             perform the services.
subdivisions or local authorities.                      sions or local authorities for services performed 
                                                        for Kazakhstan is exempt from U.S. tax unless 
                                                        the  individual  is  both  a  resident  and  citizen  of Pensions  paid  by  Luxembourg,  its  political 
                                                        the United States.                                       subdivisions,  or  local  authorities  for  services 
                                                                                                                 performed  for  Luxembourg  are  exempt  from 
Page 30                                                                                                                 Publication 901 (September 2016)



- 31 -
Page 31 of 34           Fileid: … ons/P901/201609/B/XML/Cycle01/source                                                      10:19 ­ 12­Oct­2016

The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

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 
States solely for purposes of performing                  business carried on by New Zealand, its politi­         Pensions paid by Portugal for services per­
the services.                                             cal subdivisions, or local authorities.                 formed  for  Portugal  are  exempt  from  U.S.  in­
                                                                                                                  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
formed  for  the  paying  governmental  body  are         Wages, salaries, and similar income, including          These exemptions do not apply to income or 
exempt from U.S. income tax unless the individ­           pensions  and  similar  benefits  paid  by  or  from    pensions  for  services  performed  in  connection 
ual is both a resident and national of the United         public  funds  of  Norway  or  its  political  subdivi­ with a business carried on by Portugal or its po­
States.                                                   sions or local authorities to a citizen of Norway       litical or administrative subdivisions, or local au­
                                                          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 
Wages, salaries, and similar income, including            to certain individuals by or on behalf of the Gov­      to  the  United  States  for  permanent  residence) 
pensions and similar benefits, paid from public           ernment  of  Pakistan  or  the  Government  of  a       for labor or personal services performed as an 
funds of the Kingdom of Morocco to a citizen of           Province in Pakistan or one of its local authori­       employee of the national Government of Roma­
Morocco (other than a U.S. citizen or an individ­         ties for services performed in the discharge of         nia in the discharge of governmental functions 
ual admitted to the United States for permanent           functions of that Government or local authority         are exempt from U.S. income tax.
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



- 32 -
Page 32 of 34              Fileid: … ons/P901/201609/B/XML/Cycle01/source                                                      10:19 ­ 12­Oct­2016

The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

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 
These exemptions do not apply to income or                either:                                                   pensions  for  services  performed  in  connection 
pensions  for  services  performed  in  connection        Is a U.S. citizen, or                                     with a business carried on by Switzerland or its 
with a business.                                          Did not become a U.S. resident only to                    subdivisions or local authorities.
                                                          perform the services.
                                                                                                                    Thailand
Slovak Republic                                           Pensions paid by Spain, its political subdivi­
Income, including a pension, paid from the pub­           sions, or local authorities for services performed        Income, other than a pension, paid by Thailand 
lic  funds  of  the  Slovak  Republic,  its  political    for Spain are exempt from U.S. tax unless the             or its political subdivisions or local authorities to 
subdivisions, or local authorities to a Slovak citi­      individual  is  both  a  citizen  and  resident  of  the  an individual for services performed for the pay­
zen for services performed in the discharge of            United States.                                            ing governmental body is exempt from U.S. in­
                                                                                                                    come  tax.  However,  the  exemption  does  not 
governmental functions is exempt from U.S. in­            These exemptions do not apply to income or                apply to payments for services performed in the 
come tax. This exemption does not apply to in­            pensions  for  services  performed  in  connection        United States by a resident of the United States 
come paid for services performed in connection            with a trade or business carried on by Spain, its         who either:
with  a  business  carried  on  by  the  Slovak  Re­      subdivisions, or local authorities.                       Is a U.S. citizen, or
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
Income, other than a pension, paid from public            lic funds of Sri Lanka, its political subdivisions,       formed  for  Thailand  are  exempt  from  U.S.  in­
funds  of  Slovenia,  its  political  subdivisions,  or   or local authorities to a citizen or national of Sri      come tax unless the recipient is both a resident 
local  authorities  to  an  individual  for  services     Lanka  for  services  performed  for  Sri  Lanka  in      and citizen of the United States.
performed for the paying governmental body in             the  discharge  of  functions  of  a  governmental        These exemptions do not apply to income or 
the discharge of governmental functions is ex­            nature is exempt from U.S. income tax. This ex­           pensions  for  services  performed  in  connection 
empt  from  U.S.  income  tax.  However,  the  ex­        emption does not apply to income paid for serv­           with  a  business  carried  on  by  Thailand  or  its 
emption does not apply if the services are per­           ices  performed  in  connection  with  a  business        subdivisions or local authorities.
formed in the United States by a resident of the          carried  on  by  Sri  Lanka,  its  political  subdivi­
United States who either:                                 sions, or local authorities.
                                                                                                                    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, 
Pensions paid from the public funds of Slov­              its  political  subdivisions,  or  local  authorities  to from the public funds of the Government of Tri­
enia,  its  political  subdivisions,  or  local  authori­ an individual for services performed for the pay­         nidad and Tobago to a national of that country 
ties  for  services  performed  for  Slovenia  in  the    ing governmental body is exempt from U.S. in­             for services performed for Trinidad and Tobago 
discharge  of  governmental  functions  are  ex­          come  tax.  However,  the  exemption  does  not           in the discharge of governmental functions are 
empt from U.S. income tax unless the recipient            apply if the services are performed in the United         exempt from U.S. tax.
is  both  a  resident  and  citizen  of  the  United      States by a U.S. resident who either:
States.                                                   Is a U.S. citizen, or                                     Tunisia
                                                          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)



- 33 -
Page 33 of 34          Fileid: … ons/P901/201609/B/XML/Cycle01/source                                                      10:19 ­ 12­Oct­2016

The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

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 
Ukraine                                                 These exemptions do not apply to payments                   tax law information in your electronic filing 
                                                        or  pensions  for  services  performed  in  connec­         software.
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        Taxpayer Assistance                                      rect deposit to receive their refund. The majority 
exempt from U.S. income tax unless the recipi­                                                                   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      The  Volunteer  Income  Tax  Assistance                     ted PIN available.
cal  authorities  for  services  performed  for  the    (VITA)  program  offers  free  tax  help  to  people        The First Time Homebuyer Credit Account 
United Kingdom are exempt from U.S. income              who  generally  make  $54,000  or  less,  persons           Look-up tool provides information on your 
tax  unless  the  recipient  is  both  a  resident  and with  disabilities,  the  elderly,  and  limited­Eng­       repayments and account balance.
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



- 34 -
Page 34 of 34               Fileid: … ons/P901/201609/B/XML/Cycle01/source                                               10:19 ­ 12­Oct­2016

The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

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.
                                                                                                              TAS works to resolve large­scale problems that 
ments are safe and secure. You can make elec­         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                                                                 Low Income Taxpayer 
tions.                                                    c. Vietnamese.
                                                                                                              Clinics
IRS Direct Pay (for individual taxpayers                  d. Korean.
who have a checking or savings account).                                                                      Low Income Taxpayer Clinics (LITCs) serve in­
Debit or credit card (approved payment                    e. Russian.
                                                                                                              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).                                                                                               language.  To  find  a  clinic  near  you,  visit 
Check or money order.                                 The Taxpayer Advocate 
                                                                                                              www.irs.gov/litc  or  see  IRS  Publication  4134, 
IRS2Go provides access to mobile­friendly             Service Is Here To Help You                             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 
from your bank account. You can also                  Service?
                                                                                                              Taxpayer Assistance 
make debit or credit card payments                    The Taxpayer Advocate Service (TAS) is an    in­
through an approved payment processor.                dependent  organization  within  the  Internal          Outside the United 
Simply download IRS2Go from Google                    Revenue Service that helps taxpayers and pro­
Play, the Apple App Store, or the Amazon              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
What  if  I  can’t  pay  now? Click  on  the  “Pay    Taxpayer Bill of Rights.                                          lish­speaking only). This number is not 
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)






PDF file checksum: 1306244520

(Plugin #1/10.13/13.0)