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 |
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) |
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 |
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) |
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 |
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) |
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 |
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) |
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 |
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) |
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 |
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) |
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 |
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) |
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 |
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) |
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 |
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) |
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 |
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) |
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 |
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) |
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 |
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) |
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 |
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) |
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 |
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) |
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 |
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) |
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 |
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) |
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 |
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) |