Contents
Reminders ................... 1
Introduction .................. 1
Application of Treaties ........... 2
Tax Exemptions Provided by
Treaties .................. 2
Personal Services Income ........ 2
Professors, Teachers, and
Researchers ............ 15
Students and Apprentices ....... 19
Wages and Pensions Paid by a
Foreign Government ........ 27
How To Get Tax Help ........... 33
Future Developments
For the latest information about developments
related to Publication 901, such as treaties
effective after it was published, go to
www.irs.gov/pub901.
What’s New
Tax treaty tables. The treaty tables previously
contained in this publication have been updated
and moved to IRS.gov. You can locate the ta
bles on IRS.gov by entering "Tax Treaty Table"
in the search box. Click on "Tax Treaty Tables."
You can also access the tables by going to
www.irs.gov/Individuals/International-
Taxpayers/Tax-Treaty-Tables.
Reminders
Disclosure of a treaty-based position that
reduces your tax. If you take the position that
any U.S. tax is overruled or otherwise reduced
by a U.S. treaty (a treatybased position), you
generally must disclose that position on your af
fected return. See Application of Treaties, later.
U.S.–U.S.S.R. income tax treaty. The U.S.–
U.S.S.R. income tax treaty remains in effect for
the following members of the Commonwealth of
Independent States: Armenia, Azerbaijan, Bela
rus, Georgia, Kyrgyzstan, Moldova, Tajikistan,
Turkmenistan, and Uzbekistan. That treaty will
remain in effect until new treaties with these in
dividual countries are negotiated and ratified.
Provisions of the U.S.–U.S.S.R. income tax
treaty are discussed in this publication under
Commonwealth of Independent States.
U.S.–China income tax treaty. The U.S.–
China income tax treaty does not apply to Hong
Kong.
Introduction
This publication will tell you whether a tax treaty
between the United States and a particular
country offers a reduced rate of, or possibly a
Department
of the
Treasury
Internal
Revenue
Service
Publication 901
(Rev. September 2016)
Cat. No. 46849F
U.S. Tax
Treaties
Get forms and other information faster and easier at:
• IRS.gov (English)
• IRS.gov/Spanish (Español)
•
IRS.gov/Chinese (中文)
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IRS.gov/Korean (한국어)
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complete exemption from, U.S. income tax for
residents of that particular country.
You should use this publication only for
quick reference. It is not a complete
guide to all provisions of every income
tax treaty.
For more detailed information on treaty ben
efits, you should consult the text of the applica
ble treaty. The treaties are available at
www.irs.gov/Individuals/International-
Taxpayers/Tax-Treaty-Tables.
Comments and suggestions. We welcome
your comments about this publication and your
suggestions for future editions.
You can send us comments from www/
irs.gov/formspubs. Click on “More information”
and then on “Give us feedback”.
Or, you can write to:
Internal Revenue Service
Business Forms and Publications Branch
SE:W:CAR:MP:T:B
1111 Constitution Ave. NW, IR6526
Washington, DC 20224
We respond to many letters by telephone.
Therefore, it would be helpful if you would in
clude your daytime phone number, including
the area code, in your correspondence.
Although we cannot respond individually to
each comment received, we do appreciate your
feedback and will consider your comments as
we revise our tax products.
Ordering forms and publications. Visit
www.irs.gov/formspubs to download forms and
publications. Otherwise, you can go to
www.irs.gov/orderforms to order current and
prior year forms and instructions. Your oder
should arrive within 10 business days.
Internal Revenue Service
1201 N. Mitsubishi Motorway
Bloomington, IL 617056613
Tax questions. If you have a tax question
not answered by this publication, check
IRS.gov and How To Get Tax Help at the end of
this publication.
Obtaining copies of treaties. You can get
complete information about treaty provisions
from the taxing authority in the country from
which you receive income or from the treaty it
self.
You can obtain the text of most of the trea
ties at www.irs.gov/businesses/international.
You can also obtain the text of most of the trea
ties at the following address:
Department of the Treasury
Office of Public Correspondence
1500 Pennsylvania Ave. NW — Rm. 3419
Washington, D.C. 20220
CAUTION
!
Useful Items
You may want to see:
Publication
U.S. Tax Guide for Aliens
Information on the United States–
Canada Income Tax Treaty
Form (and Instructions)
TreatyBased Return Position
Disclosure Under Section 6114 or
7701(b)
See How To Get Tax Help near the end of this
publication for information about getting these
publications and forms.
Application of Treaties
The United States has income tax treaties
with a number of foreign countries. Under these
treaties, residents (not necessarily citizens) of
foreign countries are taxed at a reduced rate, or
are exempt from U.S. income taxes on certain
items of income they receive from sources
within the United States. These reduced rates
and exemptions vary among countries and spe
cific items of income.
If there is no treaty between your country
and the United States, you must pay tax on the
income in the same way and at the same rates
shown in the instructions for Form 1040NR.
Also see Publication 519.
Many of the individual states of the United
States tax the income of their residents. There
fore, you should consult the tax authorities of
the state in which you live to find out if that state
taxes the income of individuals and, if so,
whether the tax applies to any of your income.
Tax treaties reduce the U.S. taxes of resi
dents of foreign countries. With certain excep
tions, they do not reduce the U.S. taxes of U.S.
citizens or residents. U.S. citizens and residents
are subject to U.S. income tax on their world
wide income.
Treaty provisions generally are reciprocal
(apply to both treaty countries); therefore, a
U.S. citizen or resident who receives income
from a treaty country may refer to the tables in
this publication to see if a tax treaty might affect
the tax to be paid to that foreign country. For
eign taxing authorities sometimes require certifi
cation from the U.S. Government that an appli
cant filed an income tax return as a U.S. citizen
or resident, as part of the proof of entitlement to
the treaty benefits. See Form 8802, Application
for United States Residency Certification, to re
quest a certification.
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 Form
8833 and attach it to your return. If you are not
required to file a return because of your
treatybased position, you must file a return
anyway to report your position. The filing of
519
597
8833
Form 8833 does not apply to a reduced rate of
withholding tax on noneffectively connected in
come, such as dividends, interest, rents or roy
alties, or to a reduced rate of tax on pay re
ceived for services performed as an employee,
including pensions, annuities, and social secur
ity. For more information, see Publication 519
and the Form 8833 instructions.
If you fail to file Form 8833, you may have to
pay a $1,000 penalty. Corporations are subject
to a $10,000 penalty for each failure.
Tax Exemptions
Provided by Treaties
This publication contains discussions of the ex
emptions from tax and certain other effects of
the tax treaties on the following types of in
come.
Pay for certain personal services per
formed in the United States.
Pay of a professor, teacher, or researcher
who teaches or performs research in the
United States for a limited time.
Amounts received for maintenance and
studies by a foreign student or apprentice
who is here for study or experience.
Wages, salaries, and pensions paid by a
foreign government.
Personal Services Income
Pay for certain personal services performed in
the United States is exempt from U.S. income
tax if you are a resident of one of the countries
discussed below, if you are in the United States
for a limited number of days, and if you meet
certain other conditions. For this purpose, the
word “day” means a day during any part of
which you are physically present in the United
States.
Terms defined. Several terms appear in many
of the discussions that follow. The exact mean
ings of the terms are determined by the particu
lar tax treaty under discussion; thus, the mean
ings vary among treaties. The definitions that
follow are, therefore, general definitions that
may not give the exact meaning intended by a
particular treaty.
The terms fixed base and permanent estab
lishment generally mean a fixed place of busi
ness, such as a place of management, a
branch, an office, a factory, a warehouse, or a
mining site, through which an enterprise carries
on its business.
The term borne by generally means having
ultimate financial accounting responsibility for,
or providing the monetary resources for, an ex
penditure or payment, even if another entity in
another location actually made the expenditure
or payment.
Australia
Income that residents of Australia receive for
performing personal services as independent
contractors or selfemployed individuals (inde
pendent personal services) in the United States
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during the tax year is exempt from U.S. income
tax if the residents:
Are in the United States for no more than
183 days during the tax year, and
Do not have a fixed base regularly availa
ble to them in the United States for the pur
pose of performing the services.
If they have a fixed base available in the United
States, they are taxed on the income attributa
ble to the fixed base.
Pay that residents of Australia receive for la
bor or personal services performed in the Uni
ted States as employees (dependent personal
services), including services as a director of a
company, is exempt from U.S. income tax if:
The residents are in the United States for
no more than 183 days during the tax year,
The pay is paid by, or on behalf of, an em
ployer or company that is not a resident of
the United States, and
The pay is not deductible in determining
the taxable income of the trade or business
of the employer (or company) in the United
States.
These exemptions do not apply to public en
tertainers (such as theater, motion picture, ra
dio, or television entertainers, musicians, and
athletes) from Australia who earn more than
$10,000 in gross receipts, including reimbursed
expenses, from their entertainment activities in
the United States during the tax year.
Austria
Income that residents of Austria receive for per
sonal services as independent contractors or
selfemployed individuals (independent per
sonal services) in the United States is exempt
from U.S. income tax if they do not have a fixed
base regularly available to them in the United
States for performing the services. If they have
a fixed base available in the United States, they
are taxed on the income attributable to the fixed
base.
Income that residents of Austria receive for
services performed in the United States as em
ployees (dependent personal services) is ex
empt from U.S. income tax if the residents meet
the following requirements.
They are in the United States for no more
than 183 days in any 12month period be
ginning or ending in the tax year.
Their income is paid by, or on behalf of, an
employer who is not a U.S. resident.
Their income is not borne by a permanent
establishment or a fixed base that the em
ployer has in the United States.
These exemptions do not apply to public en
tertainers (such as theater, motion picture, ra
dio, or television entertainers, musicians, and
athletes) from Austria who earn more than
$20,000 in gross receipts, including reimbursed
expenses, from their entertainment activities in
the United States during the tax year.
Income received by a resident of Austria for
services performed as an employee and mem
ber of the regular complement of a ship or air
craft operated in international traffic is exempt
from U.S. income tax.
Bangladesh
Income that residents of Bangladesh receive for
performing personal services as independent
contractors or selfemployed individuals (inde
pendent personal services) in the United States
during the tax year is exempt from U.S. income
tax if the residents:
Are in the United States for no more than
183 days in any 12month period begin
ning or ending in the tax year, or
Do not have a fixed base regularly availa
ble to them in the United States for the pur
pose of performing the services.
If they have a fixed base available in the United
States, they are taxed on the income attributa
ble to the fixed base.
Income that residents of Bangladesh re
ceive for services performed in the United
States as employees (dependent personal
services) is exempt from U.S. income tax if the
residents meet the following requirements.
They are in the United States for no more
than 183 days in any 12month period be
ginning or ending in the tax year.
Their income is paid by, or on behalf of, an
employer who is not a U.S. resident.
Their income is not borne by a permanent
establishment or a fixed base that the em
ployer has in the United States.
These exemptions do not apply to pubic en
tertainers (such as theater, motion picture, ra
dio, or television entertainers, musicians, and
athletes) from Bangladesh who earn more than
$10,000 in gross receipts, including reimbursed
expenses, from their entertainment activities in
the United States during the tax year. Regard
less of these limits, income of Bangladesh en
tertainers is exempt from U.S. income tax if their
visit to the United States is wholly or mainly
supported by public funds of Bangladesh, its
political subdivisions, or local authorities.
Income received from employment as a
member of the regular complement of a ship or
an aircraft operated by a Bangladesh enterprise
in international traffic is exempt from U.S. tax. If
the ship or aircraft is operated by a U.S. enter
prise, the income is subject to U.S. tax.
If the resident of Bangladesh is a share
holder in a U.S. corporation, these exemptions
do not apply to directors' fees received as a
member of the board of directors of the U.S.
corporation. The amount received by the share
holder that is more than the amount paid to a di
rector that is not a shareholder is subject to U.S.
tax at the rate of 15%.
Barbados
Income that residents of Barbados receive for
performing personal services as independent
contractors or selfemployed individuals (inde
pendent personal services) in the United States
during the tax year is exempt from U.S. income
tax if the residents:
Are in the United States for no more than
89 days during the tax year,
Earn net income for independent services
provided to U.S. residents that is not more
than $5,000 (there is no dollar limit if the
contractors are not U.S. residents), and
Do not have a regular base available in the
United States for performing the services.
If they have a regular base available in the Uni
ted States but otherwise meet the conditions for
exemption, they are taxed only on the income
attributable to the regular base.
Income that residents of Barbados receive
for personal services performed in the United
States as employees (dependent personal
services) is exempt from U.S. tax if the resi
dents meet four requirements.
They are in the United States for no more
than 183 days during the calendar year.
The income earned in the calendar year in
the United States is not more than $5,000.
Their income is paid by or for an employer
who is not a U.S. resident.
The income is not borne by a permanent
establishment or regular base of the em
ployer in the United States.
Income of a Barbadian resident from em
ployment as a member of the regular comple
ment of a ship or aircraft operated in interna
tional traffic is exempt from U.S. tax.
These exemptions do not apply to Barba
dian resident public entertainers (such as thea
ter, motion picture, radio, or television artists,
musicians, or athletes) who receive gross re
ceipts of more than $250 per day or $4,000 in
the tax year, not including reimbursed expen
ses, from their entertainment activities in the
United States. However, the exemptions do ap
ply regardless of these limits on gross receipts if
the entertainer's visit to the United States is
substantially supported by Barbadian public
funds or if the entertainer's services are provi
ded to a nonprofit organization.
Belgium
Income that residents of Belgium receive for
personal services as independent contractors
or selfemployed individuals are subject to the
provisions of Article 7 (Business Profits) of the
treaty. Under that provision, business profits are
exempt from U.S. income tax unless the individ
ual has a permanent establishment in the Uni
ted States. If they have a permanent establish
ment in the United States, they are taxed on the
profit attributable to the permanent establish
ment.
Income that residents of Belgium receive for
services performed in the United States as em
ployees (dependent personal services) is ex
empt from U.S. income tax if the residents meet
the following requirements.
They are in the United States for no more
than 183 days in any 12month period be
ginning or ending in the tax year.
Their income is paid by, or on behalf of, an
employer who is not a U.S. resident.
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Publication 901 (September 2016) Page 3
Their income is not borne by a permanent
establishment that the employer has in the
United States.
The exemption does not apply to directors'
fees and similar payments received by a resi
dent of Belgium for services performed in the
United States as a member of the board of di
rectors of a company that is a resident of the
United States.
Public entertainers (such as theater, motion
picture, radio, or television artists, musicians, or
athletes) from Belgium who earn more than
$20,000 in gross receipts, including reimbursed
expenses, from their entertainment activities in
the United States during the tax year are sub
ject to U.S. tax.
Income received by a resident of Belgium
for services performed as an employee and
member of the regular complement of a ship or
aircraft operated in international traffic is ex
empt from U.S. income tax.
Bulgaria
Income that residents of Bulgaria receive for
personal services as independent contractors
or selfemployed individuals is subject to the
provisions of Article 7 (Business Profits) of the
treaty. Under that provision, business profits are
exempt from U.S. income tax unless the individ
ual has a permanent establishment in the Uni
ted States. If they have a permanent establish
ment in the United States, they are taxed on the
profit attributable to the permanent establish
ment. Under Article 5 (Permanent Establish
ment), you may be considered to provide serv
ices through a permanent establishment in the
United States even if you do not have a fixed
place of business.
Income that residents of Bulgaria receive for
services performed in the United States as em
ployees (dependent personal services) is ex
empt from U.S. income tax if the residents meet
the following requirements.
They are in the United States for no more
than 183 days in any 12month period be
ginning or ending in the tax year.
Their income is paid by, or on behalf of, an
employer who is not a U.S. resident.
Their income is not borne by a permanent
establishment that the employer has in the
United States.
The exemption does not apply to directors'
fees and similar payments received by a resi
dent of Bulgaria as a member of the board of di
rectors of a U.S. company.
Public entertainers (such as theater, motion
picture, radio, or television artists, musicians, or
athletes) from Bulgaria who earn more than
$15,000 in gross receipts, including reimbursed
expenses, from their entertainment activities in
the United States during the tax year are sub
ject to U.S. tax.
Income received by a resident of Bulgaria
for services performed as an employee and
member of the regular complement of a ship or
aircraft operated in international traffic is
exempt from U.S. income tax.
Canada
Income that residents of Canada receive for
personal services as independent contractors
or selfemployed individuals is subject to the
provisions of Article VII (Business Profits) of the
treaty. Under that provision, business profits are
exempt from U.S. income tax unless the individ
ual has a permanent establishment in the Uni
ted States. If they have a permanent establish
ment in the United States, they are taxed on the
profit attributable to the permanent establish
ment. Under Article V (Permanent Establish
ment), you may be considered to provide serv
ices through a permanent establishment in the
United States even if you do not have a fixed
place of business.
Income that residents of Canada receive for
personal services performed as employees (de
pendent personal services) in the United States
is exempt from U.S. tax if it is not more than
$10,000 for the year. If the income is more than
$10,000 for the year, it is exempt only if:
The residents are present in the United
States for no more than 183 days in any
12month period beginning or ending in the
tax year, and
The income is not paid by, or on behalf of,
a U.S. resident, and is not borne by a per
manent establishment in the United States.
Public entertainers (such as theater, motion
picture, radio, or television artists, musicians, or
athletes) from Canada who derive more than
$15,000 in gross receipts, including reimbursed
expenses, from their entertainment activities in
the United States during the calendar year are
subject to U.S. tax. However, this article does
not apply to athletes participating in team sports
in leagues with regularly scheduled games in
both Canada and the United States.
Pay received by a resident of Canada for
employment regularly done in more than one
country on a ship, aircraft, motor vehicle, or
train operated by a Canadian resident is ex
empt from U.S. tax.
China, People's Republic of
Income that residents of the People's Republic
of China receive for personal services as inde
pendent contractors or selfemployed individu
als (independent personal services) that they
perform during the tax year in the United States
is exempt from U.S. income tax if the residents:
Are present in the United States for no
more than 183 days in the calendar year,
and
Do not have a fixed base regularly availa
ble in the United States for performing the
services.
If they have a fixed base available in the United
States, they are taxable on the income attributa
ble to the fixed base.
Pay received by residents of the People's
Republic of China for services performed as
employees (dependent personal services) in
the United States is exempt from U.S. tax if:
The residents are present in the United
States for no more than 183 days in the
calendar year,
The pay is paid by or for an employer who
is not a U.S. resident, and
The pay is not borne by a permanent es
tablishment or fixed base that the em
ployer has in the United States.
These exemptions do not apply to directors'
fees for service on the board of directors of a
U.S. corporation.
These exemptions generally do not apply to
income received as a public entertainer (such
as a theater, motion picture, radio, or television
artist, musician, or athlete). However, income of
athletes or public entertainers from China par
ticipating in a cultural exchange program
agreed upon by the U.S. and Chinese govern
ments is exempt from U.S. tax.
Commonwealth of
Independent States
Income that residents of a C.I.S. member re
ceive for performing personal services in the
United States is exempt from U.S. income tax if
those residents are in the United States for no
more than 183 days during the tax year.
Pay received by an employee who is a
member of the regular complement of a ship or
aircraft operated in international traffic by a
C.I.S. member or a resident of a C.I.S. member
is exempt from U.S. tax.
Cyprus
Income that residents of Cyprus receive for per
forming personal services as independent con
tractors or selfemployed individuals (independ
ent personal services) in the United States
during the tax year is exempt from U.S. income
tax if the residents:
Are present in the United States for less
than 183 days in the tax year, and
Do not have a fixed base regularly availa
ble to them in the United States for per
forming the services.
If they have a fixed base available in the United
States, they are taxable on the income attributa
ble to the fixed base.
Pay received by residents of Cyprus from
services performed as employees (dependent
personal services), including services as an offi
cer of a corporation, is exempt from U.S. in
come tax if:
The residents are in the United States for
less than 183 days during the tax year,
The pay is paid by or for an employer who
is not a U.S. resident, and
The pay is not borne by a permanent es
tablishment, fixed base, or trade or busi
ness that the employer has in the United
States.
Pay received by a Cyprus resident for per
forming personal services as an employee and
member of the regular complement of a ship or
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Page 4 Publication 901 (September 2016)
aircraft operated in international traffic by a resi
dent of Cyprus is exempt from U.S. tax.
These exemptions do not apply to Cyprus
resident public entertainers (theater, motion pic
ture, radio, or television artists, musicians, or
athletes) who receive gross receipts of more
than $500 per day or $5,000 for the tax year,
not including reimbursed expenses, from their
entertainment activities in the United States.
Directors' fees received by residents of Cy
prus for service on the board of directors of a
U.S. corporation are exempt from U.S. income
tax to the extent of a reasonable fixed amount
payable to all directors for each day of attend
ance at directors' meetings held in the United
States.
Czech Republic
Income that residents of the Czech Republic re
ceive for performing personal services as inde
pendent contractors or selfemployed individu
als (independent personal services) in the
United States is exempt from U.S. income tax if
the residents:
Are present in the United States for no
more than 183 days in any 12month pe
riod, and
Do not have a fixed base regularly availa
ble to them in the United States for per
forming the services.
If they have a fixed base available, they are
taxed only on income attributable to the fixed
base.
Income that residents of the Czech Republic
receive for employment in the United States
(dependent personal services) is exempt from
U.S. income tax if the following three require
ments are met.
The resident is present in the United
States for no more than 183 days in any
12month period.
The income is paid by, or on behalf of, an
employer who is not a U.S. resident.
The income is not borne by a permanent
establishment or a fixed base that the em
ployer has in the United States.
These exemptions do not apply to income
residents of the Czech Republic receive as pub
lic entertainers (such as theater, motion picture,
radio, or television artists, or musicians) or
sportsmen if their gross receipts, including re
imbursed expenses, are more than $20,000
during the tax year. Regardless of these limits,
income of Czech entertainers and sportsmen is
exempt from U.S. income tax if their visit to the
United States is substantially supported by pub
lic funds of the Czech Republic, its political sub
divisions, or local authorities, or the visit is
made pursuant to a specific arrangement be
tween the United States and the Czech Repub
lic.
These exemptions do not apply to directors'
fees and similar payments received by a resi
dent of the Czech Republic as a member of the
board of directors of a company that is a resi
dent of the United States.
Income from employment as a member of
the regular complement of a ship or aircraft op
erated by a Czech enterprise in international
traffic is exempt from U.S. income tax. If the
ship or aircraft is operated by a U.S. enterprise,
the income is subject to U.S. tax.
Denmark
Income that residents of Denmark receive for
personal services as independent contractors
or selfemployed individuals (independent per
sonal services) in the United States is exempt
from U.S. income tax if they do not have a fixed
base regularly available to them in the United
States for performing the services. If they have
a fixed base available in the United States, they
are taxed on the income attributable to the fixed
base.
Income that residents of Denmark receive
for services performed in the United States as
employees (dependent personal services) is
exempt from U.S. income tax if the residents
meet the following requirements.
They are in the United States for no more
than 183 days in any 12month period be
ginning or ending in the tax year.
Their income is paid by, or on behalf of, an
employer who is not a U.S. resident.
Their income is not borne by a permanent
establishment or a fixed base that the em
ployer has in the United States.
These exemptions do not apply to directors'
fees and similar payments received by a resi
dent of Denmark as a member of the board of
directors of a company that is a resident of the
United States.
These exemptions do not apply to public en
tertainers (such as theater, motion picture, ra
dio, or television artists, musicians, and ath
letes) from Denmark who earn more than
$20,000 in gross receipts, including reimbursed
expenses, from their entertainment activities in
the United States during the tax year.
Income received by a resident of Denmark
for services performed as an employee and
member of the regular complement of a ship or
aircraft operated in international traffic is ex
empt from U.S. income tax.
Egypt
Income that residents of Egypt receive for per
forming personal services as independent con
tractors or as selfemployed individuals (inde
pendent personal services) in the United States
during the tax year is exempt from U.S. income
tax if they are in the United States for no more
than 89 days during the tax year.
Income that residents of Egypt receive for
labor or personal services performed in the Uni
ted States as employees (dependent personal
services), including income for services per
formed by an officer of a corporation or com
pany, is exempt from U.S. income tax if the resi
dents meet four requirements.
They are in the United States for no more
than 89 days during the tax year.
They are employees of a resident of, or a
permanent establishment in, Egypt.
Their income is not borne by a permanent
establishment that the employer has in the
United States.
Their income is subject to Egyptian tax.
This exemption does not apply to pay re
ceived by a resident of Egypt who is an em
ployee and member of the regular complement
of a ship or an aircraft operated in international
traffic by a resident of the United States.
These exemptions do not apply to Egyptian
resident public entertainers (theater, motion pic
ture, radio, or television artists, musicians, or
athletes), who earn income for services as pub
lic entertainers if the gross amount of the in
come is more than $400 for each day they are
in the United States performing the services.
Estonia
Income that residents of Estonia receive for per
forming personal services as independent con
tractors or selfemployed individuals (independ
ent personal services) in the United States is
exempt from U.S. income tax if the residents:
Are in the United States for no more than
183 days in any 12month period begin
ning or ending in the tax year, and
Do not have a fixed base regularly availa
ble to them in the United States for per
forming the services.
If they have a fixed base available, they are
taxed on the income attributable to the fixed
base.
Income that residents of Estonia receive for
services performed in the United States as em
ployees (dependent personal services) is ex
empt from U.S. income tax if the following re
quirements are met.
The resident is in the United States for no
more than 183 days in any 12month pe
riod beginning or ending in the tax year.
The income is paid by, or on behalf of, an
employer who is not a U.S. resident.
The income is not borne by a permanent
establishment or a fixed base that the em
ployer has in the United States.
These exemptions do not apply to directors'
fees and similar payments received by a resi
dent of Estonia as a member of the board of di
rectors or similar body of a company that is a
U.S. resident.
Pay received for employment as a member
of the regular complement of a ship or an air
craft operated in international traffic by a United
States enterprise is subject to U.S. tax.
These exemptions do not apply to income
residents of Estonia receive as public entertain
ers (such as theater, motion picture, radio, or
television artists, or musicians) or sportsmen if
their gross receipts, including reimbursed ex
penses, are more than $20,000 for their per
sonal activities in the United States during the
tax year. Regardless of these limits, income of
Estonian entertainers or athletes is exempt from
U.S. income tax if their visit to the United States
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Publication 901 (September 2016) Page 5
is wholly or mainly supported by public funds of
Estonia, its political subdivisions, or local au
thorities.
Finland
Income that residents of Finland receive for per
forming personal services as independent con
tractors or selfemployed individuals (independ
ent personal services) in the United States is
exempt from U.S. income tax if they do not
have a fixed base regularly available to them in
the United States for performing the services. If
they have a fixed base available in the United
States, they are taxed on the income attributa
ble to the fixed base.
Income that residents of Finland receive for
labor or personal services performed in the Uni
ted States as employees (dependent personal
services) is exempt from U.S. income tax if the
residents meet three requirements.
They are in the United States for no more
than 183 days during any 12month period.
Their income is paid by, or on behalf of, an
employer who is not a resident of the Uni
ted States.
Their income is not borne by a permanent
establishment, fixed base, or trade or busi
ness that the employer has in the United
States.
The exemption does not apply to pay re
ceived by a resident of Finland who is an em
ployee and member of the regular complement
of a ship or aircraft operated in international traf
fic by a resident of the United States.
These exemptions do not apply to income
residents of Finland receive as public entertain
ers or sportsmen if the gross income, including
reimbursed expenses, is more than $20,000 for
their personal activities in the United States dur
ing the calendar year.
France
Income that residents of France receive for per
forming personal services as independent con
tractors or selfemployed individuals (independ
ent personal services) in the United States is
exempt from U.S. income tax if they do not
have a fixed base regularly available to them in
the United States for performing the services. If
they have a fixed base available in the United
States, they are taxed on the income attributa
ble to the fixed base.
Income that residents of France receive for
labor or personal services performed in the Uni
ted States as employees (dependent personal
services) is exempt from U.S. income tax if the
residents meet three requirements.
They are in the United States for no more
than 183 days in any 12month period.
Their income is paid by, or on behalf of, an
employer who is not a resident of the Uni
ted States.
Their income is not borne by a permanent
establishment or a fixed base that the em
ployer has in the United States.
Income for services performed by a resident
of France as an employee and member of the
regular complement of a ship or an aircraft op
erated in international traffic is exempt from tax
in the United States.
These exemptions do not apply to public en
tertainers (such as theater, motion picture, ra
dio, or television artists, or musicians), or
sportsmen from France who earn more than
$10,000 in gross receipts, including reimbursed
expenses, from their entertainment activities in
the United States during the tax year. Regard
less of these limits, income of French entertain
ers or sportsmen is exempt from U.S. tax if their
visit is principally supported by public funds of
France.
These exemptions do not apply to directors'
fees and similar payments received by a resi
dent of France as a member of the board of di
rectors of a company that is a resident of the
United States.
Germany
Income that residents of Germany receive for
personal services as independent contractors
or selfemployed individuals are subject to the
provisions of Article 7 (Business Profits) of the
treaty. Under that provision, business profits are
exempt from U.S. income tax unless the individ
ual has a permanent establishment in the Uni
ted States. If they have a permanent establish
ment in the United States, they are taxed on the
profit attributable to the permanent establish
ment.
Income that residents of Germany receive
for labor or personal services performed in the
United States as employees (dependent per
sonal services) is exempt from U.S. tax if the
residents meet three requirements.
They are in the United States for no more
than 183 days during the calendar year.
The income is paid by, or on behalf of, an
employer who is not a resident of the Uni
ted States.
The income is not borne by a permanent
establishment that the employer has in the
United States.
Pay received by a resident of Germany for
services performed as an employee and mem
ber of the regular complement of a ship or air
craft operated in international traffic is exempt
from U.S. tax.
The exemption does not apply to directors'
fees and other similar payments received by a
resident of Germany for services performed in
the United States as a member of the board of
directors of a company resident in the United
States.
Income residents of Germany receive as
public entertainers (such as theater, motion pic
ture, radio, or television artists, or musicians) or
athletes is subject to U.S. tax if their gross re
ceipts, including reimbursed expenses, from
their entertainment activities in the United
States are more than $20,000 during the calen
dar year. Income of German entertainers or ath
letes is exempt from U.S. tax if their visit to the
United States is substantially supported by pub
lic funds of Germany, its political subdivisions,
or local authorities.
Greece
Income that residents of Greece receive for la
bor or personal services (including practicing
liberal and artistic professions) is exempt from
U.S. income tax if they are in the United States
for no more than 183 days during the tax year
and the pay is not more than $10,000. The pay,
regardless of amount, is exempt from U.S. in
come tax if it is for labor or personal services
performed as employees of, or under contract
with, a resident of Greece or a Greek corpora
tion or other entity of Greece, and if the resi
dents are in the United States for no more than
183 days during the tax year.
Hungary
Income that residents of Hungary receive for
performing personal services as independent
contractors or selfemployed individuals (inde
pendent personal services) in the United States
during the tax year is exempt from U.S. tax if the
residents:
Are in the United States for no more than
183 days during the tax year, and
Do not have a fixed base regularly availa
ble in the United States.
If they have a fixed base available in the United
States, they are taxed on the income attributa
ble to the fixed base.
Income that residents of Hungary receive for
labor or personal services performed in the Uni
ted States as employees (dependent personal
services) is exempt from U.S. income tax if the
residents meet three requirements.
They are in the United States for no more
than 183 days during the tax year.
Their income is paid by or on behalf of an
employer who is not a resident of the Uni
ted States.
Their income is not borne by a permanent
establishment or a fixed base that the em
ployer has in the United States.
Pay received by an employee who is a
member of the regular complement of a ship or
aircraft operated by a Hungarian enterprise in
international traffic is exempt from U.S. tax. If
the ship or aircraft is operated by a U.S. enter
prise, the pay is subject to U.S. tax.
Iceland
Income that residents of Iceland receive for per
sonal services as independent contractors or
selfemployed individuals is subject to the provi
sions of Article 7 (Business Profits) of the treaty.
Under that provision, business profits are ex
empt from U.S. income tax unless the individual
has a permanent establishment in the United
States. If they have a permanent establishment
in the United States, they are taxed on the profit
attributable to the permanent establishment.
Income that residents of Iceland receive for
services performed in the United States as em
ployees (dependent personal services) is
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Page 6 Publication 901 (September 2016)
exempt from U.S. income tax if the residents
meet the following requirements.
They are in the United States for no more
than 183 days in any 12month period be
ginning or ending in the tax year.
Their income is paid by, or on behalf of, an
employer who is not a U.S. resident.
Their income is not borne by a permanent
establishment that the employer has in the
United States.
The exemption does not apply to directors'
fees and similar payments received by a resi
dent of Iceland as a member of the board of di
rectors of a U.S. company.
Public entertainers (such as theater, motion
picture, radio, or television artists, musicians, or
athletes) from Iceland who earn more than
$20,000 in gross receipts, including reimbursed
expenses, from their entertainment activities in
the United States during the tax year are sub
ject to U.S. tax.
Income received by a resident of Iceland for
services performed as an employee and mem
ber of the regular complement of a ship or air
craft operated in international traffic is exempt
from U.S. income tax.
India
Income that residents of India receive for per
forming personal services in the United States
during the tax year as independent contractors
or selfemployed individuals (independent per
sonal services) is exempt from U.S. income tax
if the residents:
Are present in the United States for no
more than 89 days during the tax year, and
Do not have a fixed base regularly availa
ble to them in the United States for per
forming the services.
If they have a fixed base available, they are
taxed only on income attributable to the fixed
base.
Income that residents of India receive for
personal services performed in the United
States as employees (dependent personal
services) is exempt from U.S. income tax if the
residents meet three requirements.
They are present in the United States for
no more than 183 days during the tax year.
The income is paid by, or on behalf of, an
employer who is not a resident of the Uni
ted States.
The income is not borne by a permanent
establishment, fixed base, or trade or busi
ness the employer has in the United
States.
The exemption does not apply to pay re
ceived by a resident of India for services per
formed as an employee aboard a ship or aircraft
operated in international traffic by a U.S. enter
prise.
These exemptions do not apply to directors'
fees and similar payments received by an In
dian resident as a member of the board of di
rectors of a company that is a U.S. resident.
These exemptions do not apply to income
residents of India receive as public entertainers
(such as theater, motion picture, radio, or televi
sion artists, or musicians) or athletes if their net
income is more than $1,500 during the tax year
for their entertainment activities in the United
States. Regardless of this limit, the income of
Indian entertainers and athletes is exempt from
U.S. tax if their visit to the United States is
wholly or substantially supported from the pub
lic funds of the Indian Government, its political
subdivisions, or local authorities.
Indonesia
Income that residents of Indonesia receive for
performing personal services as individual con
tractors or selfemployed individuals (independ
ent personal services) in the United States dur
ing the tax year is exempt from U.S. income tax
if the residents:
Are present in the United States for no
more than 119 days during any consecu
tive 12month period, and
Do not have a fixed base regularly availa
ble to them in the United States for per
forming the services.
If they have a fixed base available, they are
taxed only on the income attributable to the
fixed base.
Income that residents of Indonesia receive
for personal services performed in the United
States as employees (dependent personal
services) is exempt from U.S. income tax if the
residents meet three requirements.
They are present in the United States no
more than 119 days during any consecu
tive 12month period.
The income is paid by, or on behalf of, an
employer who is not a resident of the Uni
ted States.
The income is not borne or reimbursed by
a permanent establishment the employer
has in the United States.
Pay received by an individual for services
performed as an employee aboard a ship or air
craft operated by an Indonesian resident in in
ternational traffic is exempt from U.S. tax if the
individual is a member of the regular comple
ment of the ship or aircraft.
These exemptions do not apply to income
residents of Indonesia receive as public enter
tainers (such as theater, motion picture, radio,
or television artists, or musicians) or athletes if
their gross receipts, including reimbursed ex
penses, are more than $2,000 during any con
secutive 12month period. Regardless of these
limits, income of Indonesian entertainers and
athletes is exempt from U.S. tax if their visit to
the United States is substantially supported or
sponsored by the Indonesian Government and
the Indonesian competent authority certifies
that the entertainers or athletes qualify for this
exemption.
Ireland
Income that residents of Ireland receive for per
sonal services as independent contractors or
selfemployed individuals (independent per
sonal services) in the United States is exempt
from U.S. income tax if they do not have a fixed
base regularly available to them in the United
States for performing the services. If they have
a fixed base available in the United States, they
are taxed on the income attributable to the fixed
base.
Income that residents of Ireland receive for
services performed in the United States as em
ployees (dependent personal services) is ex
empt from U.S. income tax if the residents meet
the following requirements.
They are in the United States for no more
than 183 days in any 12month period be
ginning or ending in the tax year.
Their income is paid by, or on behalf of, an
employer who is not a U.S. resident.
Their income is not borne by a permanent
establishment or a fixed base that the em
ployer has in the United States.
These exemptions do not apply to directors'
fees and similar payments received by a resi
dent of Ireland as a member of the board of di
rectors of a company that is a resident of the
United States. However, amounts received for
attending meetings in Ireland are not subject to
U.S. income tax.
Income received by a resident of Ireland for
services performed as an employee and mem
ber of the regular complement of a ship or air
craft operated in international traffic is exempt
from U.S. income tax.
These exemptions do not apply to public en
tertainers (such as theater, motion picture, ra
dio, or television entertainers, musicians, and
athletes) from Ireland who earn more than
$20,000 in gross receipts, including reimbursed
expenses, from their entertainment activities in
the United States during the tax year.
Israel
Income that residents of Israel receive for per
forming personal services as independent con
tractors or as selfemployed individuals (inde
pendent personal services) in the United States
during the tax year is exempt from U.S. income
tax if they are in the United States for no more
than 182 days during the tax year.
Income that residents of Israel receive for la
bor or personal services performed in the Uni
ted States as employees (dependent personal
services), including income for services per
formed by an officer of a corporation or com
pany, is exempt from U.S. income tax if the resi
dents meet four requirements.
They are in the United States for no more
than 182 days during the tax year.
They are employees of a resident of, or a
permanent establishment in, Israel.
Their income is not borne by a permanent
establishment that the employer has in the
United States.
Their income is subject to Israeli tax.
The exemption does not apply to pay re
ceived by an employee for labor or personal
services performed as a member of the regular
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Publication 901 (September 2016) Page 7
complement of a ship or an aircraft operated in
international traffic by a U.S. resident.
These exemptions do not apply to income
that residents of Israel receive as public enter
tainers (such as theater, motion picture, radio,
or television artists, musicians, or athletes), if
the gross amount of the income is more than
$400 for each day they are in the United States
performing the services.
Italy
Income that residents of Italy receive for per
sonal services as independent contractors or
selfemployed individuals (independent per
sonal services) in the United States is exempt
from U.S. income tax if they do not have a fixed
base regularly available to them in the United
States for performing the services. If they have
a fixed base available in the United States, they
are taxed on the income attributable to the fixed
base.
Income that residents of Italy receive for la
bor or personal services performed in the Uni
ted States as employees (dependent personal
services) is exempt from U.S. income tax if the
following requirements are met.
The residents are in the United States for
no more than 183 days during the tax year.
The income is paid by, or on behalf of, an
employer who is not a resident of the Uni
ted States.
The income is not borne by a permanent
establishment or a fixed base that the em
ployer has in the United States.
These exemptions do not apply to directors'
fees and similar payments received by a resi
dent of Italy for services performed in the United
States as a member of the board of directors of
a company that is a U.S. resident.
Pay received for employment regularly exer
cised aboard a ship or aircraft operated by a
U.S. enterprise is subject to U.S. tax.
These exemptions do not apply to income
residents of Italy receive as public entertainers
(such as theater, motion picture, radio, or televi
sion artists, musicians, or athletes) if they are
present in the United States for more than 90
days during the tax year or their gross receipts,
including reimbursed expenses, are more than
$20,000 during the tax year for their entertain
ment activities in the United States.
Jamaica
Income that residents of Jamaica receive for
the performance of personal services as inde
pendent contractors or selfemployed individu
als (independent personal services) in the Uni
ted States during the tax year is exempt from
U.S. income tax if the residents:
Are in the United States for no more than
89 days during the tax year,
Do not have a fixed base regularly availa
ble to them in the United States for per
forming their services, and
Earn net income for those services that is
not more than $5,000 during the tax year if
the income is from a U.S. contractor.
If they have a fixed base available in the United
States, they are taxed only on the income that is
attributable to the fixed base. There is no dollar
limit for condition (3) if the contractor is from a
country other than the United States.
Income that residents of Jamaica receive for
personal services performed in the United
States as employees (dependent personal
services) is exempt from U.S. income tax if the
residents meet four requirements.
They are in the United States for no more
than 183 days during the tax year.
Their income is paid by or for an employer
who is not a resident of the United States.
Their income is not borne by a permanent
establishment or a fixed base that the em
ployer has in the United States.
Their net income received for the services
is not more than $5,000 during the tax
year.
Pay received from employment as a mem
ber of the regular complement of a ship or an
aircraft operated in international traffic by a Ja
maican enterprise is exempt from U.S. tax. If
the ship or aircraft is operated by a U.S. enter
prise, the pay is subject to U.S. tax.
These exemptions do not apply to income
that residents of Jamaica receive for performing
services in the United States as entertainers,
such as theater, motion picture, radio, or televi
sion artists, musicians, or athletes, if the gross
receipts (excluding reimbursements for expen
ses) from the services are more than $400 a
day or $5,000 for the tax year.
Directors' fees received by residents of Ja
maica for services performed in the United
States as members of boards of directors of
U.S. corporations are exempt from U.S. tax if
the fees (excluding reimbursed expenses) are
not more than $400 per day for each day the di
rectors are present in the United States to per
form the services.
Japan
Income that residents of Japan receive for per
sonal services as independent contractors or
selfemployed individuals is subject to the provi
sions of Article 7 (business profits) of the treaty.
Under that provision, business profits are ex
empt from U.S. income tax unless the individual
has a permanent establishment in the United
States. If they have a permanent establishment
in the United States, they are taxed on the prof
its attributable to the permanent establishment.
Income that residents of Japan receive for
services performed in the United States as em
ployees (dependent personal services) is ex
empt from U.S. income tax if the residents meet
the following requirements.
They are in the United States for no more
than 183 days in any 12month period be
ginning or ending in the tax year.
Their income is paid by, or on behalf of, an
employer who is not a U.S. resident.
Their income is not borne by a permanent
establishment that the employer has in the
United States.
The exemption does not apply to directors'
fees and similar payments received by a resi
dent of Japan for services performed as a mem
ber of the board of directors of a company that
is a resident of the United States.
The exemption does not apply to a resident
of Japan who performs services as an em
ployee aboard a ship or an aircraft operated in
international traffic by a U.S. resident.
Public entertainers (such as theater, motion
picture, radio, or television artists, musicians, or
athletes) from Japan who earn more than
$10,000 in gross receipts, including reimbursed
expenses, from their entertainment activities in
the United States during the tax year are sub
ject to U.S. tax.
Kazakhstan
Income that residents of Kazakhstan receive for
performing personal services as independent
contractors or selfemployed individuals (inde
pendent personal services) in the United States
is exempt from U.S. income tax if:
The residents are in the United States for
no more than 183 days in any consecutive
12month period, and
The income is not attributable to a fixed
base in the United States which is regularly
available to the residents.
If the residents have a fixed base available, they
are taxed only on the income attributable to the
fixed base.
Income that residents of Kazakhstan receive
for employment in the United States (depend
ent personal services) is exempt from U.S. in
come tax if the following three requirements are
met.
The resident is in the United States for no
more than 183 days in any 12month pe
riod.
The income is paid by, or on behalf of, an
employer who is not a resident of the Uni
ted States.
The income is not borne by a permanent
establishment or a fixed base that the em
ployer has in the United States.
Income derived by a resident of Kazakhstan
from employment as a member of the regular
complement of a ship or aircraft operated in in
ternational traffic is exempt from U.S. tax.
These exemptions do not apply to directors'
fees and similar payments received by a resi
dent of Kazakhstan as a member of the board
of directors or similar body of a company that is
a U.S. resident.
Korea, South
Income that residents of South Korea receive
for performing personal services as independ
ent contractors or selfemployed individuals (in
dependent personal services) in the United
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Page 8 Publication 901 (September 2016)
States during the tax year is exempt from U.S.
tax if the residents:
Are in the United States for no more than
182 days during the tax year,
Earn income for those services that is not
more than $3,000 during the tax year, and
Do not maintain a fixed base in the United
States for more than 182 days during the
tax year.
If they maintain a fixed base in the United
States for more than 182 days, they are taxed
on the income attributable to the fixed base.
Income that residents of Korea receive for
labor or personal services performed in the Uni
ted States as employees (dependent personal
services), including pay for services performed
as an officer of a corporation, is exempt from
U.S. tax if the residents meet four requirements.
They are in the United States for no more
than 182 days during the tax year.
They are employees of a resident of Korea
or of a permanent establishment main
tained in Korea.
Their compensation is not borne by a per
manent establishment that the employer
has in the United States.
Their income for those services is not more
than $3,000.
Pay received by employees who are mem
bers of the regular complement of a ship or air
craft operated by a resident of Korea in interna
tional traffic is exempt.
Latvia
Income that residents of Latvia receive for per
forming personal services as independent con
tractors or selfemployed individuals (independ
ent personal services) in the United States is
exempt from U.S. income tax if the residents:
Are in the United States for no more than
183 days in any 12month period begin
ning or ending in the tax year, and
Do not have a fixed base regularly availa
ble to them in the United States for per
forming the services.
If they have a fixed base available, they are
taxed only on the income attributable to the
fixed base.
Income that residents of Latvia receive for
services performed in the United States as em
ployees (dependent personal services) is ex
empt from U.S. income tax if the following re
quirements are met.
The resident is in the United States for no
more than 183 days in any 12month pe
riod beginning or ending in the tax year.
The income is paid by, or on behalf of, an
employer who is not a U.S. resident.
The income is not borne by a permanent
establishment or a fixed base that the em
ployer has in the United States.
The exemption does not apply to pay re
ceived for employment as a member of the reg
ular complement of a ship or an aircraft oper
ated in international traffic by a U.S. enterprise.
The exemptions do not apply to directors'
fees and similar payments received by a
resident of Latvia as a member of the board of
directors or similar body of a company that is a
U.S. resident.
The exemptions do not apply to income resi
dents of Latvia receive as public entertainers
(such as theater, motion picture, radio, or televi
sion artists, or musicians) or sportsmen if their
gross receipts, including reimbursed expenses,
are more than $20,000 for their personal activi
ties in the United States during the tax year. Re
gardless of these limits, income of Latvian en
tertainers or athletes is exempt from U.S.
income tax if their visit to the United States is
wholly or mainly supported by public funds of
Latvia, its political subdivisions, or local authori
ties.
Lithuania
Income that residents of Lithuania receive for
performing personal services as independent
contractors or selfemployed individuals (inde
pendent personal services) in the United States
is exempt from U.S. income tax if the residents:
Are in the United States for no more than
183 days in any 12month period begin
ning or ending in the tax year, and
Do not have a fixed base regularly availa
ble to them in the United States for per
forming the services.
If they have a fixed base available, they are
taxed only on the income attributable to the
fixed base.
Income that residents of Lithuania receive
for services performed in the United States as
employees (dependent personal services) is
exempt from U.S. income tax if the following re
quirements are met.
The resident is in the United States for no
more than 183 days in any 12month pe
riod beginning or ending in the tax year.
The income is paid by, or on behalf of, an
employer who is not a U.S. resident.
The income is not borne by a permanent
establishment or a fixed base that the em
ployer has in the United States.
The exemption does not apply to pay re
ceived for employment as a member of the reg
ular complement of a ship or an aircraft oper
ated in international traffic by a U.S. enterprise.
The exemptions do not apply to directors'
fees and similar payments received by a resi
dent of Lithuania as a member of the board of
directors or similar body of a company that is a
U.S. resident.
The exemptions do not apply to income resi
dents of Lithuania receive as public entertainers
(such as theater, motion picture, radio, or televi
sion artists, or musicians) or sportsmen if their
gross receipts, including reimbursed expenses,
are more than $20,000 for their personal activi
ties in the United States during the tax year. Re
gardless of these limits, income of Lithuanian
entertainers or athletes is exempt from U.S. in
come tax if their visit to the United States is
wholly or mainly supported by public funds of
Lithuania, its political subdivisions, or local au
thorities.
Luxembourg
Income that residents of Luxembourg receive
for personal services as independent contrac
tors or selfemployed individuals (independent
personal services) in the United States is ex
empt from U.S. income tax if they do not have a
fixed base regularly available to them in the Uni
ted States for performing the services. If they
have a fixed base available in the United
States, they are taxed on the income attributa
ble to the fixed base.
Income that residents of Luxembourg re
ceive for services performed in the United
States as employees (dependent personal
services) is exempt from U.S. income tax if the
residents meet the following requirements.
They are in the United States for no more
than 183 days in any 12month period be
ginning or ending in the tax year.
Their income is paid by, or on behalf of, an
employer who is not a U.S. resident.
Their income is not borne by a permanent
establishment or a fixed base that the em
ployer has in the United States.
The exemption does not apply to pay re
ceived for employment exercised continuously
or predominantly aboard a ship or aircraft oper
ated in international traffic by a U.S. enterprise.
The exemptions do not apply to directors'
fees and similar payments received by a resi
dent of Luxembourg for services performed in
the United States as a member of the board of
directors of a company that is a resident of the
United States.
The exemptions do not apply to public en
tertainers (such as theater, motion picture, ra
dio, or television artists, musicians, or athletes)
from Luxembourg who earn more than $10,000
in gross receipts, including reimbursed expen
ses, from their entertainment activities in the
United States during the tax year.
Malta
Income that residents of Malta receive for per
sonal services as independent contractors or
selfemployed individuals is subject to the provi
sions of Article 7 (Business Profits) of the treaty.
Under that provision, business profits are ex
empt from U.S. income tax unless the individual
has a permanent establishment in the United
States. If they have a permanent establishment
in the United States, they are taxed on the prof
its attributable to the permanent establishment.
Income that residents of Malta receive for
services performed in the United States as em
ployees (dependent personal services) is ex
empt from U.S. income tax if the residents meet
the following requirements.
They are in the United States for no more
than 183 days in any 12month period be
ginning or ending in the tax year.
Their income is paid by, or on behalf of, an
employer who is not a U.S. resident.
Their income is not borne by a permanent
establishment that the employer has in the
United States.
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Publication 901 (September 2016) Page 9
The exemption does not apply to directors'
fees and similar payments received by a resi
dent of Malta for services performed in the Uni
ted States as a member of the board of direc
tors of a company that is a resident of the
United States.
Public entertainers (such as theater, motion
picture, radio, or television artists, musicians, or
athletes) from Malta who earn more than
$20,000 in gross receipts, including reimbursed
expenses, from their entertainment activities in
the United States during the tax year are sub
ject to U.S. tax.
Income received by a resident of Malta for
employment aboard a ship or an aircraft oper
ated in international traffic is exempt from U.S.
income tax if the individual is a member of the
regular complement of the ship or aircraft.
Mexico
Income that residents of Mexico receive for per
forming personal services as independent con
tractors or selfemployed individuals (independ
ent personal services) in the United States is
exempt from U.S. income tax if the residents:
Are in the United States for no more than
182 days in a 12month period, and
Do not have a fixed base that they regu
larly use for performing the services.
If they have a fixed base available, they are
taxed only on income attributable to the fixed
base.
Income that residents of Mexico receive for
employment in the United States (dependent
personal services) is exempt from U.S. tax if the
following three requirements are met.
The resident is present in the United
States for no more than 183 days in a
12month period.
The income is paid by, or on behalf of, an
employer who is not a resident of the Uni
ted States.
The income is not borne by a permanent
establishment or fixed base that the em
ployer has in the United States.
These exemptions do not apply to directors'
fees and similar payments received by a resi
dent of Mexico for services performed outside
Mexico as a director or overseer of a company
that is a U.S. resident.
These exemptions do not apply to income
residents of Mexico receive as public entertain
ers (such as theater, motion picture, radio, or
television artists, or musicians) or athletes if the
income, including reimbursed expenses, is
more than $3,000 during the tax year for their
entertainment activities in the United States.
This includes income from activities performed
in the United States relating to the entertainer or
athlete's reputation, such as endorsements of
commercial products. Regardless of this limit,
the income of Mexican entertainers and ath
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.
Morocco
Income that residents of Morocco receive for
performing personal services as independent
contractors or as selfemployed persons (inde
pendent personal services) in the United States
during the tax year is exempt from U.S. income
tax if the residents:
Are in the United States for no more than
182 days during the tax year,
Do not maintain a fixed base in the United
States for more than 89 days during the tax
year, and
Earn total income for those services that is
not more than $5,000.
If they have a fixed base in the United States for
more than 89 days, they are taxed only on the
income attributable to the fixed base.
Income that residents of Morocco receive
for labor or personal services performed in the
United States as employees (dependent per
sonal services) is exempt from U.S. income tax
if the residents meet three requirements.
They are in the United States for less than
183 days during the tax year.
They are employees of a resident of Mo
rocco or of a permanent establishment of a
resident of a country other than Morocco if
the permanent establishment is located in
Morocco.
Their income is not borne by a permanent
establishment that the employer has in the
United States.
Compensation received for services per
formed by a member of the board of directors of
a corporation does not qualify for this exemp
tion.
Income received by an individual for per
forming labor or personal services as an em
ployee aboard a ship or an aircraft operated in
international traffic by a Moroccan resident is
exempt from U.S. income tax if the individual is
a member of the regular complement of the ship
or aircraft.
These exemptions do not apply to income
received for services performed in the United
States by professional entertainers, including
theater, film, radio, and television performers,
musicians, and athletes, unless the services are
performed by, or for the account of, a Moroccan
nonprofit organization.
Netherlands
Income that residents of the Netherlands re
ceive for performing personal services as inde
pendent contractors or selfemployed individu
als (independent personal services) in the
United States is exempt from U.S. income tax if
the income is not attributable to a fixed base in
the United States that is regularly available for
performing the services.
Income that residents of the Netherlands re
ceive for employment in the United States (de
pendent personal services) is exempt from U.S.
income tax if the following three requirements
are met.
The resident is in the United States for no
more than 183 days during the tax year.
The income is paid by, or on behalf of, an
employer who is not a U.S. resident.
The income is not borne by a permanent
establishment or fixed base the employer
has in the United States.
Income received by a Netherlands resident
for employment as a member of the regular
complement of a ship or aircraft operated in in
ternational traffic is exempt from U.S. tax.
These exemptions do not apply to directors'
fees and other similar payments received by a
resident of the Netherlands for services per
formed outside the Netherlands as a member of
the board of directors of a company that is a
resident of the United States.
These exemptions do not apply to income
residents of the Netherlands receive as public
entertainers (such as theater, motion picture,
radio, or television artists, or musicians) or ath
letes if the gross income, including reimbursed
expenses, is more than $10,000.
New Zealand
Income that residents of New Zealand receive
for performing personal services as independ
ent contractors or selfemployed individuals is
subject to the provisions of Article 7 (Business
Profits) of the treaty. Under that provision, busi
ness profits are exempt from U.S. income tax
unless the individual has a permanent estab
lishment in the United States. If they have a per
manent establishment in the United States, they
are taxed on the profits attributable to the per
manent establishment.
Income that residents of New Zealand re
ceive for labor or personal services performed
in the United States as employees (dependent
personal services) is exempt from U.S. income
tax if the residents meet these requirements.
They are present in the United States for
no more than 183 days in any consecutive
12month period.
Their income is paid by or on behalf of an
employer that is not a resident of the Uni
ted States.
Their income is not borne by a permanent
establishment that the employer has in the
United States.
The exemption does not apply to public en
tertainers (artists, athletes, etc.) from New Zea
land who earn more than $10,000 in gross re
ceipts, including reimbursed expenses, from
their entertainment activities in the United
States during the tax year.
Pay received by a New Zealand resident as
an employee and member of the regular com
plement of a ship or aircraft operated in interna
tional traffic is exempt from U.S. tax.
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Page 10 Publication 901 (September 2016)
Norway
Income that residents of Norway receive for
performing personal services as independent
contractors or selfemployed individuals (inde
pendent personal services) in the United States
during the tax year is exempt from U.S. income
tax if the residents:
Are present in the United States for no
more than 182 days during the tax year,
and
Do not maintain a fixed base in the United
States for more than 182 days during the
tax year.
If they do not meet requirement (2), they are
taxed only on the income attributable to the
fixed base.
This exemption does not apply to residents
of Norway who are public entertainers (theater,
motion picture, or television artists, musicians,
or athletes) if they are in the United States for
more than 90 days during the tax year or their
pay for services as public entertainers is more
than $10,000 during the tax year.
Income that residents of Norway receive for
labor or personal services performed in the Uni
ted States as employees (dependent personal
services) is exempt from U.S. income tax if the
residents meet three requirements.
They are in the United States less than 183
days during the tax year.
They are employees of a resident of Nor
way or of a permanent establishment of a
resident of a state other than Norway if the
permanent establishment is situated in
Norway.
Their income is not borne by a permanent
establishment that the employer has in the
United States.
The exemption does not apply to a resident
of Norway who performs services as an em
ployee aboard a ship or an aircraft operated by
a United States resident in international traffic
or in fishing on the high seas if the resident of
Norway is a member of the regular complement
of the ship or aircraft.
Pakistan
Residents of Pakistan who perform personal
services (including professional services) for or
on behalf of a resident of Pakistan while in the
United States for no more than 183 days during
the tax year are exempt from U.S. income tax
on the income from the services if they are sub
ject to Pakistani tax.
Philippines
Income that residents of the Philippines receive
for performing personal services as independ
ent contractors or as selfemployed individuals
(independent personal services) in the United
States during the tax year is exempt from U.S.
income tax if the residents:
Are in the United States for no more than
89 days during the tax year,
Earn gross income for those services that
is not more than $10,000 for the tax year if
the income is from U.S. contractors, and
Do not have a fixed base regularly availa
ble to them in the United States for per
forming their services.
If they have a fixed base available in the United
States, they are taxed only on the income attrib
utable to the fixed base. There is no dollar limit
for condition (2) if the contractor is a resident of
a country other than the United States.
Income that residents of the Philippines re
ceive for personal services performed in the
United States as employees (dependent per
sonal services) is exempt from U.S. income tax
if the residents meet three requirements.
They are in the United States for no more
than 89 days during the tax year.
They are employees of a resident of the
Philippines or of a permanent establish
ment maintained in the Philippines.
Their income is not borne by a permanent
establishment that the employer has in the
United States.
Pay received by an employee of a resident
of the Philippines for personal services per
formed as a member of the regular complement
of a ship or an aircraft operated in international
traffic by a resident of the Philippines is exempt
from U.S. tax.
These exemptions do not apply to income
residents of the Philippines receive for perform
ing services (both independent and dependent
personal services) in the United States as en
tertainers, such as theater, motion picture, ra
dio, or television artists, musicians, or athletes,
if the income is more than $100 a day or $3,000
for the tax year. Regardless of these limits, in
come of Philippine entertainers is exempt from
U.S. tax if their visit to the United States is sub
stantially supported or sponsored by the Philip
pine Government and the entertainers are certi
fied as qualified for this exemption by the
Philippine competent authority.
Poland
Income that residents of Poland receive for per
forming personal services as independent con
tractors or selfemployed individuals (independ
ent personal services) in the United States is
exempt from U.S. income tax if they are in the
United States for no more than 182 days during
the tax year.
Income that residents of Poland receive for
labor or personal services performed as em
ployees (dependent personal services), includ
ing services performed by an officer of a corpo
ration or company, in the United States during
the tax year is exempt from U.S. income tax if
the residents meet three requirements.
They are in the United States for no more
than 182 days during the tax year.
Their income is paid by or on behalf of an
employer who is not a U.S. resident.
Their income is not borne by a permanent
establishment that the employer has in the
United States.
Pay received by employees who are mem
bers of the regular complement of a ship or air
craft operated by a resident of Poland in inter
national traffic is exempt from U.S. tax.
Portugal
Income that residents of Portugal receive for
performing personal services as independent
contractors or selfemployed individuals (inde
pendent personal services) in the United States
is exempt from U.S. income tax if the residents:
Are in the United States for no more than
182 days in any 12month period, and
Do not have a fixed base regularly availa
ble to them in the United States for per
forming the activities.
If they have a fixed base available, they are
taxed only on the income attributable to the
fixed base.
Income that residents of Portugal receive for
employment in the United States (dependent
personal services) is exempt from U.S. income
tax if the following three requirements are met.
The resident is in the United States for no
more than 183 days in any 12month pe
riod.
The income is paid by, or on behalf of, an
employer who is not a U.S. resident.
The income is not borne by a permanent
establishment or fixed base that the em
ployer has in the United States.
Income received by a resident of Portugal
for employment as a member of the regular
complement of a ship or aircraft operated in in
ternational traffic is exempt from U.S. tax.
These exemptions do not apply to income
residents of Portugal receive as public enter
tainers (such as theater, motion picture, radio,
or television artists, or musicians) or athletes if
that income, including reimbursed expenses, is
more than $10,000. The income of Portuguese
entertainers and athletes is exempt from U.S.
tax if their visit to the United States is substan
tially supported by public funds of Portugal or its
political or administrative subdivisions.
These exemptions do not apply to directors'
fees and similar payments received by a resi
dent of Portugal for services performed outside
of Portugal as a member of the board of direc
tors of a company that is a resident of the Uni
ted States.
Romania
Income that residents of Romania receive for
performing personal services as independent
contractors or selfemployed individuals (inde
pendent personal services) in the United States
during the tax year is exempt from U.S. income
tax if the residents:
Are present in the United States for no
more than 182 days during the tax year,
and
Do not maintain a permanent establish
ment in the United States with which the in
come is effectively connected.
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Publication 901 (September 2016) Page 11
Income that residents of Romania receive
for labor or personal services performed as em
ployees (dependent personal services), includ
ing services performed by an officer of a corpo
ration or company, in the United States during
the tax year is exempt from U.S. income tax if
the residents meet these requirements.
They are in the United States for no more
than 182 days during the tax year.
They are employees of a resident of Ro
mania or of a permanent establishment
maintained in Romania by a resident of the
United States.
Their income is not borne by a permanent
establishment that the employer has in the
United States.
These exemptions do not apply to entertain
ers, such as theater, motion picture, radio, or
television artists, musicians, or athletes, who
are present in the United States for more than
90 days during the tax year (90 days or more if
the entertainers are employees) or who earn
gross income as entertainers in the United
States of more than $3,000 during the tax year
($3,000 or more if they are employees). How
ever, the exemptions do apply, without regard
to the 90 day, $3,000 requirement, if the enter
tainers are present in the United States by spe
cific arrangements between the United States
and Romania.
Pay received by employees who are mem
bers of the regular complement of a ship or air
craft operated by a resident of Romania in inter
national traffic is exempt from U.S. tax.
Russia
Income that residents of Russia receive for per
forming personal services as independent con
tractors or selfemployed individuals (independ
ent personal services) in the United States is
exempt from U.S. income tax if:
The residents are in the United States for
no more than 183 days during the calendar
year, or
The income is not attributable to a fixed
base in the United States which is regularly
available to the residents.
If the residents have a fixed base available, they
are taxed only on the income attributable to the
fixed base.
Income that residents of Russia receive for
employment in the United States (dependent
personal services) is exempt from U.S. income
tax if the following three requirements are met.
The resident is in the United States for no
more than 183 days during the calendar
year.
The income is paid by, or on behalf of, an
employer who is not a resident of the Uni
ted States.
The income is not borne by a permanent
establishment or a fixed base that the em
ployer has in the United States.
However, income from employment directly
connected with a place of business that is not a
permanent establishment is exempt if the resi
dent is present in the United States not longer
than 12 consecutive months. For this purpose,
a place of business means a construction site,
assembly or installation project, or drilling oper
ation.
Income derived by a resident of Russia from
employment as a member of the regular com
plement of a ship or aircraft operated in interna
tional traffic is exempt from U.S. tax.
Income from technical services directly con
nected with the application of a right or property
giving rise to a royalty is exempt if those serv
ices are provided as part of a contract granting
the use of the right or property.
These exemptions do not apply to directors'
fees and similar payments received by a resi
dent of Russia as a member of the board of di
rectors or similar body of a company that is a
resident of the United States.
Slovak Republic
Income that residents of the Slovak Republic re
ceive for performing personal services as inde
pendent contractors or selfemployed individu
als (independent personal services) in the
United States is exempt from U.S. income tax if
the residents:
Are present in the United States for no
more than 183 days in any 12month pe
riod, and
Do not have a fixed base regularly availa
ble to them in the United States for per
forming the activities.
If they have a fixed base available, they are
taxed only on income attributable to the fixed
base.
Income that residents of the Slovak Repub
lic receive for employment in the United States
(dependent personal services) is exempt from
U.S. income tax if the following three require
ments are met.
The resident is present in the United
States for no more than 183 days in any
12month period.
The income is paid by, or on behalf of, an
employer who is not a U.S. resident.
The income is not borne by a permanent
establishment or a fixed base that the em
ployer has in the United States.
These exemptions do not apply to income
residents of the Slovak Republic receive as
public entertainers (such as theater, motion pic
ture, radio, or television artists, or musicians) or
sportsmen if their gross receipts, including re
imbursed expenses, are more than $20,000
during the tax year. Regardless of these limits,
income of Slovak entertainers and sportsmen is
exempt from U.S. income tax if their visit to the
United States is substantially supported by pub
lic funds of the Slovak Republic, its political
subdivisions, or local authorities, or the visit is
made pursuant to a specific arrangement be
tween the United States and the Slovak Repub
lic.
These exemptions do not apply to directors'
fees and similar payments received by a resi
dent of the Slovak Republic for services per
formed in the United States as a member of the
board of directors of a company that is a resi
dent of the United States.
Income from employment as a member of
the regular complement of a ship or aircraft op
erated by a Slovak enterprise in international
traffic is exempt from U.S. income tax. If the
ship or aircraft is operated by a U.S. enterprise,
the income is subject to U.S. income tax.
Slovenia
Income that residents of Slovenia receive for
personal services as independent contractors
or selfemployed individuals (independent per
sonal services) in the United States is exempt
from U.S. income tax if they do not have a fixed
base regularly available to them in the United
States for performing the services. If they have
a fixed base available in the United States, they
are taxed on the income attributable to the fixed
base.
Income that residents of Slovenia receive for
services performed in the United States as em
ployees (dependent personal services) is ex
empt from U.S. income tax if the residents meet
the following requirements.
They are in the United States for no more
than 183 days in any 12month period be
ginning or ending in the tax year.
Their income is paid by, or on behalf of, an
employer who is not a U.S. resident.
Their income is not borne by a permanent
establishment or a fixed base that the em
ployer has in the United States.
These exemptions do not apply to directors'
fees and similar payments received by a resi
dent of Slovenia for services performed in the
United States as a member of the board of di
rectors of a company that is a resident of the
United States.
Income received by a Slovenian resident for
employment as a member of the regular com
plement of a ship or aircraft operated in interna
tional traffic is exempt from U.S. tax.
These exemptions do not apply to income
residents of Slovenia receive as public enter
tainers (such as theater, motion picture, radio,
or television artists, or musicians) or athletes if
their gross receipts, including reimbursed ex
penses, are more than $15,000 during the tax
year. Regardless of these limits, income of
Slovenian entertainers or athletes is exempt
from U.S. tax if their visit to the United States is
wholly or mainly paid by public funds of either
the United States or Slovenia or their political
subdivisions, or local authorities.
South Africa
Income that residents of South Africa receive
for performing personal services as independ
ent contractors or selfemployed individuals (in
dependent personal services) in the United
States is exempt from U.S. income tax if the
residents:
Are in the United States for no more than
183 days in any 12month period begin
ning or ending in the tax year, and
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Page 12 Publication 901 (September 2016)
Do not have a fixed base regularly availa
ble to them in the United States for per
forming the services.
If they have a fixed base available, they are
taxed only on income attributable to the fixed
base.
Income that residents of South Africa re
ceive for services performed in the United
States as employees (dependent personal
services) is exempt from U.S. income tax if the
following requirements are met.
The resident is in the United States for no
more than 183 days in any 12month pe
riod beginning or ending in the tax year.
The income is paid by, or on behalf of, an
employer who is not a U.S. resident.
The income is not borne by a permanent
establishment or a fixed base that the em
ployer has in the United States.
These exemptions do not apply to directors'
fees and similar payments received by a resi
dent of South Africa for services performed in
the United States as a member of the board of
directors of a company resident in the United
States.
These exemptions do not apply to income
residents of South Africa receive as public en
tertainers (such as theater, motion picture, ra
dio, or television artists, or musicians) or ath
letes if their gross receipts, including
reimbursed expenses, are more than $7,500
during the tax year. Regardless of these limits,
income of South African entertainers or athletes
is exempt from U.S. income tax if their visit to
the United States is wholly or mainly supported
by public funds of South Africa, its political sub
divisions, or local authorities.
Income received by a resident of South Af
rica for services performed as an employee and
member of the complement of a ship or aircraft
operated in international traffic is exempt from
U.S. income tax.
Spain
Income that residents of Spain receive as inde
pendent contractors or selfemployed individu
als (independent personal services) in the Uni
ted States is exempt from U.S. income tax if the
residents do not have a fixed base available to
them in the United States for performing the
services. If they have a fixed base, they are
taxed only on the income attributable to the
fixed base.
Income that residents of Spain receive for
personal services performed in the United
States as employees (dependent personal
services) is exempt from U.S. income tax if:
The residents are present in the United
States no more than 183 days in any
12month period,
The income is paid by, or on behalf of, an
employer who is not a U.S. resident, and
The income is not borne by a permanent
establishment or fixed base the employer
has in the United States.
The exemption does not apply to pay re
ceived by employees who are members of a
regular complement of a ship or aircraft oper
ated in international traffic by a U.S. enterprise.
These exemptions do not apply to public en
tertainers (such as theater, motion picture, ra
dio, or television artists, or musicians) or ath
letes from Spain who earn more than $10,000 in
income, including reimbursed expenses, from
their entertainment activities in the United
States during the tax year. Regardless of these
limits, Spanish entertainers and athletes are ex
empt from U.S. tax if their visit to the United
States is substantially supported by public
funds of Spain, a political subdivision, or local
authority.
Sri Lanka
Income that residents of Sri Lanka receive for
performing personal services as independent
contractors or selfemployed individuals (inde
pendent personal services) in the United States
during the tax year is exempt from U.S. income
tax if the residents:
Are in the United States for no more than
183 days in any 12month period, or
Do not have a fixed base regularly availa
ble to them in the United States for the pur
pose of performing the services.
If they have a fixed base available in the
United States, they are taxed on the income at
tributable to the fixed base.
Income that residents of Sri Lanka receive
for services performed in the United States as
employees (dependent personal services) is
exempt from U.S. income tax if the residents
meet the following requirements.
They are in the United States for no more
than 183 days in any 12month period.
Their income is paid by, or on behalf of, an
employer who is not a U.S. resident.
Their income is not borne by a permanent
establishment or a fixed base that the em
ployer has in the United States.
Income received from employment as a
member of the regular complement of a ship or
an aircraft operated in international traffic by a
Sri Lanka enterprise is exempt from U.S. tax. If
the ship or aircraft is operated by a U.S. enter
prise, the income is subject to U.S. tax.
These exemptions do not apply to public en
tertainers (such as theater, motion picture, ra
dio, or television entertainers, musicians, and
athletes) from Sri Lanka who earn more than
$6,000 in gross receipts, including reimbursed
expenses, from their entertainment activities in
the United States during the tax year. Regard
less of these limits, income of Sri Lanka enter
tainers is exempt from U.S. income tax if their
visit to the United States is directly or indirectly
supported wholly or substantially by public
funds of Sri Lanka or the United States, their
political subdivisions, or local authorities.
These exemptions do not apply to directors'
fees and other compensation received by a res
ident of Sri Lanka for services performed in the
United States as a member of the board of di
rectors of a company resident in the United
States.
Sweden
Income that residents of Sweden receive for
performing personal services as independent
contractors or selfemployed individuals (inde
pendent personal services) in the United States
during the tax year is exempt from U.S. income
tax if they do not have a fixed base regularly
available to them in the United States for per
forming the services. If they have a fixed base
available in the United States, they are taxed on
the income attributable to the fixed base.
Income that residents of Sweden receive for
labor or personal services performed in the Uni
ted States as employees (dependent personal
services) is exempt from U.S. income tax if the
residents meet three requirements.
They are in the United States for no more
than 183 days during any consecutive
12month period.
Their income is paid by, or on behalf of, an
employer who is not a resident of the Uni
ted States.
Their income is not borne by a permanent
establishment or a fixed base that the em
ployer has in the United States.
Income received by a resident of Sweden
for employment as a member of the regular
complement of a ship or aircraft operated in in
ternational traffic is exempt from U.S. tax.
These exemptions do not apply to income
residents of Sweden receive as public enter
tainers (such as theater, motion picture, radio,
or television artists, or musicians) or athletes if
the gross income, including reimbursed expen
ses, is more than $6,000 for any 12month pe
riod.
These exemptions do not apply to directors'
fees received by a resident of Sweden for serv
ices performed outside of Sweden as a member
of the board of directors of a company that is a
resident of the United States.
Switzerland
Income that residents of Switzerland receive for
personal services as independent contractors
or selfemployed individuals (independent per
sonal services) that they perform during the tax
year in the United States is exempt from U.S.
income tax if they do not have a fixed base reg
ularly available to them in the United States for
performing the services. If they have a fixed
base available in the United States, they are
taxed on the income attributable to the fixed
base.
Income that residents of Switzerland receive
for services performed in the United States as
employees (dependent personal services) is
exempt from U.S. income tax if the residents
meet the following requirements.
They are in the United States for no more
than 183 days in any 12month period be
ginning or ending in the tax year.
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Publication 901 (September 2016) Page 13
Their income is paid by, or on behalf of, an
employer who is not a U.S. resident.
Their income is not borne by a permanent
establishment or a fixed base that the em
ployer has in the United States.
These exemptions do not apply to directors'
fees and similar payments received by a resi
dent of Switzerland as a member of the board
of directors of a company that is a resident of
the United States.
These exemptions do not apply to public en
tertainers (such as theater, motion picture, ra
dio, or television entertainers, musicians, and
athletes) from Switzerland who earn more than
$10,000 in gross receipts, including reimbursed
expenses, from their entertainment activities in
the United States during the tax year.
Income received by a resident of Switzer
land for services performed as an employee
and member of the regular complement of a
ship or aircraft operated in international traffic is
exempt from U.S. income tax.
Thailand
Income that residents of Thailand receive for
performing personal services as independent
contractors or as selfemployed individuals (in
dependent personal services) in the United
States during the tax year is exempt from U.S.
income tax if the residents:
Are in the United States for no more than
89 days during the tax year, and
Do not have a fixed base regularly availa
ble to them in the United States for per
forming their services.
If they have a fixed base available in the United
States, they are taxed only on the income attrib
utable to the fixed base.
This exemption does not apply if a resident
of Thailand earns more than $10,000 for inde
pendent personal services and that income is
paid by a U.S. resident or borne by a perma
nent establishment or fixed base in the United
States.
Income that residents of Thailand receive for
services performed in the United States as em
ployees (dependent personal services) is ex
empt from U.S. income tax if the following re
quirements are met.
The resident is in the United States for no
more than 183 days in any 12month pe
riod beginning or ending in the tax year.
The income is paid by, or on behalf of, an
employer who is not a U.S. resident.
The income is not borne by a permanent
establishment or a fixed base that the em
ployer has in the United States.
These exemptions do not apply to directors'
fees and similar payments received by a resi
dent of Thailand for services performed outside
of Thailand as a member of the board of direc
tors of a company that is a resident of the Uni
ted States.
These exemptions do not apply to income
residents of Thailand receive for performing
services in the United States as entertainers
(such as theater, motion picture, radio, or televi
sion artists, or musicians) and athletes, if the in
come is more than $100 a day or $3,000 for the
tax year. Regardless of these limits, income of
Thai entertainers is exempt from U.S. tax if their
visit to the United States is substantially suppor
ted by public funds of Thailand or its political
subdivisions or local authorities.
The exemption does not apply to pay re
ceived by employees who are members of the
regular complement of a ship or aircraft oper
ated in international traffic by a U.S. enterprise.
Trinidad and Tobago
Income (including reimbursed travel expenses)
that residents of Trinidad and Tobago receive
during the tax year for personal services per
formed in the United States is exempt from U.S.
income tax if the individuals are in the United
States for no more than 183 days during the tax
year and either:
The residents are employees of a resident
of a country other than the United States or
are employees of a permanent establish
ment of a U.S. resident outside the United
States and the income is not deducted in
figuring the profits of a permanent estab
lishment in the United States, or
The income is not more than $3,000 (ex
cluding reimbursed travel expenses).
These exemptions do not apply to the pro
fessional earnings of public entertainers such
as actors, musicians, and professional athletes
or to any person providing their services if the
pay is more than $100 per day (excluding reim
bursed travel expenses).
Pay received by members of the regular
complement of a ship or aircraft operated in in
ternational traffic by a resident of Trinidad and
Tobago is exempt from U.S. tax.
Tunisia
Income that residents of Tunisia receive for per
forming personal services as independent con
tractors or selfemployed individuals (independ
ent personal services) in the United States are
exempt from U.S. income tax if:
They are in the United States for no more
than 183 days during the tax year,
They do not have a fixed base regularly
available in the United States for perform
ing the services, and
The gross income for the tax year from
U.S. residents for services performed in
the United States is no more than $7,500.
If they do not meet condition (2), they are
taxed on the income that is attributable to the
fixed base.
Income that residents of Tunisia receive for
personal services performed in the United
States as employees (dependent personal
services) is exempt from U.S. income tax if:
The residents are in the U.S. for no more
than 183 days during the tax year,
Their income is paid by, or on behalf of, an
employer who is not a resident of the Uni
ted States, and
Their income is not borne by a permanent
establishment or fixed base the employer
has in the United States.
Pay received by employees who are mem
bers of the regular complement of a ship or air
craft operated by an enterprise in international
traffic is exempt from U.S. tax if the place of
management of the enterprise is in Tunisia.
However, if the enterprise is created under the
laws of the United States (or a U.S. state), the
pay is subject to U.S. tax.
These exemptions do not apply to income
residents of Tunisia receive as public entertain
ers (such as theater, motion picture, radio, or
television artists, and musicians) or athletes if
their gross receipts, including reimbursed ex
penses, are more than $7,500 during the tax
year.
These exemptions do not apply to fees re
ceived by a resident of Tunisia for services per
formed as a director of a U.S. corporation if the
fees are treated as a distribution of profits and
cannot be taken as a deduction by the corpora
tion.
Turkey
Income that residents of Turkey receive for per
forming personal services as independent con
tractors or selfemployed individuals (independ
ent personal services) in the United States is
exempt from U.S. income tax if the residents:
Are in the United States for purposes of
performing the services or activities for no
more than 183 days in any 12month pe
riod, and
Do not have a fixed base regularly availa
ble to them in the United States for per
forming the services.
If they have a fixed base available, they are
taxed only on income attributable to the fixed
base.
Income that residents of Turkey receive for
services performed in the United States as em
ployees (dependent personal services) is ex
empt from U.S. income tax if the following re
quirements are met.
The resident is in the United States for no
more than 183 days in any 12month pe
riod.
The income is paid by, or on behalf of, an
employer who is not a U.S. resident.
The income is not borne by a permanent
establishment or a fixed base that the em
ployer has in the United States.
This exemption does not apply to a resident
of Turkey who performs services as a member
of the regular complement of a ship or an air
craft operated by a U.S. resident in international
traffic.
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Page 14 Publication 901 (September 2016)
These exemptions do not apply to directors'
fees and similar payments received by a resi
dent of Turkey for services provided in the Uni
ted States as a member of the board of direc
tors of a company that is a resident of the
United States.
These exemptions do not apply to income
residents of Turkey receive as public entertain
ers (such as theater, motion picture, radio, or
television artists, or musicians) or athletes if
their gross receipts are more than $3,000 dur
ing the tax year for their entertainment activities
in the United States. If their visit to the United
States is substantially supported by a Turkish
nonprofit organization or from the public funds
of Turkey, its political subdivisions, or local au
thorities, the income is taxed as independent
personal services or dependent personal serv
ices.
Ukraine
Income that residents of Ukraine receive for
performing personal services as independent
contractors or selfemployed individuals (inde
pendent personal services) in the United States
is exempt from U.S. income tax if the income is
not attributable to a fixed base in the United
States that is regularly available for performing
the services.
Income that residents of Ukraine receive for
employment in the United States (dependent
personal services) is exempt from U.S. income
tax if the following three requirements are met.
The resident is in the United States for no
more than 183 days during the tax year.
The income is paid by, or on behalf of, an
employer who is not a resident of the Uni
ted States.
The income is not borne by a permanent
establishment or a fixed base that the em
ployer has in the United States.
These exemptions do not apply to directors'
fees and similar payments received by a resi
dent of Ukraine for services performed outside
of Ukraine as a member of the board of direc
tors of a company that is a resident of the Uni
ted States.
These exemptions generally do not apply to
income received as a public entertainer (such
as a theater, motion picture, radio, or television
artist, musician, or athlete). However, income of
Ukrainian entertainers and sportsmen is exempt
from U.S. income tax if their visit to the United
States is substantially supported by public
funds of Ukraine, its political subdivisions, or lo
cal authorities, or the visit is made pursuant to a
specific arrangement between the United
States and Ukraine.
Income derived by a resident of Ukraine
from employment as a member of the regular
complement of a ship or aircraft operated in in
ternational traffic is exempt from U.S. tax.
United Kingdom
Income that residents of the United Kingdom re
ceive for personal services as independent
contractors or selfemployed individuals are
subject to the provisions of Article 7 (Business
Profits) of the treaty. Under that provision, busi
ness profits are exempt from U.S. income tax
unless the individual has a permanent estab
lishment in the United States. If they have a per
manent establishment in the United States, they
are taxed on the profits attributable to the per
manent establishment.
Income that residents of the United King
dom receive for services performed in the Uni
ted States as employees (dependent personal
services) is exempt from U.S. income tax if the
residents meet the following requirements.
They are in the United States for no more
than 183 days in any 12month period be
ginning or ending in the tax year.
Their income is paid by, or on behalf of, an
employer who is not a U.S. resident.
Their income is not borne by a permanent
establishment that the employer has in the
United States.
The exemption does not apply to directors'
fees and similar payments received by a resi
dent of the United Kingdom for services per
formed in the United States as a member of the
board of directors of a company resident in the
United States.
Public entertainers (such as theater, motion
picture, radio, or television artists, musicians, or
athletes) from the United Kingdom who earn
more than $20,000 in gross receipts, including
reimbursed expenses, from their entertainment
activities in the United States during the tax
year are subject to U.S. tax.
Income received by a resident of the United
Kingdom for services performed as an em
ployee and member of the regular complement
of a ship or aircraft operated in international traf
fic is exempt from U.S. income tax.
Venezuela
Income that residents of Venezuela receive for
personal services as independent contractors
or selfemployed individuals (independent per
sonal services) in the United States is exempt
from U.S. income tax if they do not have a fixed
base regularly available to them in the United
States for performing the services. If they have
a fixed base available, they are taxed on the in
come attributable to the fixed base.
Income that residents of Venezuela receive
for services performed in the United States as
employees (dependent personal services) is
exempt from U.S. income tax if the residents
meet the following requirements.
They are in the United States for no more
than 183 days in any 12month period be
ginning or ending in the tax year.
Their income is paid by, or on behalf of, an
employer who is not a U.S. resident.
The income is not borne by a permanent
establishment or a fixed base that the em
ployer has in the United States.
These exemptions do not apply to directors'
fees and similar payments received by a resi
dent of Venezuela for services performed in the
United States as a member of the board of di
rectors of a company resident in the United
States.
Pay received by a resident of Venezuela for
services performed as an employee of a ship or
an aircraft operated in international traffic is ex
empt from U.S. income tax.
These exemptions do not apply to income
residents of Venezuela receive as public enter
tainers (such as theater, motion picture, radio,
or television artists, or musicians) or sportsmen
if their gross income, including reimbursed ex
penses, is more than $6,000 for their personal
activities in the United States during the tax
year. Regardless of these limits, income of Ven
ezuelan entertainers or athletes is exempt from
U.S. income tax if their visit to the United States
is wholly or mainly supported by public funds of
Venezuela, its political subdivisions, or local au
thorities.
Professors, Teachers,
and Researchers
Pay of professors and teachers who are resi
dents of the following countries is generally ex
empt from U.S. income tax for 2 or 3 years if
they temporarily visit the United States to teach
or do research. The exemption applies to pay
earned by the visiting professor or teacher dur
ing the applicable period. For most of the fol
lowing countries, the applicable period begins
on the date of arrival in the United States for the
purpose of teaching or engaging in research.
Furthermore, for most of the following countries,
the exemption applies even if the stay in the
United States extends beyond the applicable
period.
The exemption generally applies to pay re
ceived during a second teaching assignment if
both are completed within the specified time,
even if the second assignment was not ar
ranged until after arrival in the United States on
the first assignment. For each of the countries
listed, the conditions are stated under which the
pay of a professor or teacher from that country
is exempt from U.S. income tax.
If you do not meet the requirements for ex
emption as a teacher or if you are a resident of
a treaty country that does not have a special
provision for teachers, you may qualify under a
personal services income provision discussed
earlier.
Bangladesh
An individual is exempt from U.S. income tax on
income from teaching or research for not more
than 2 years from the date of arrival for such
purposes if he or she:
Is a resident of Bangladesh immediately
before visiting the United States, and
Is in the United States to teach or engage
in research at a university, college, or other
recognized educational institution.
This exemption does not apply to income
from research carried on mainly for the private
benefit of any person rather than in the public
interest.
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Publication 901 (September 2016) Page 15
Belgium
An individual who is a resident of Belgium at the
beginning of the visit to the United States and
who is temporarily in the United States to teach
or carry on research at a school, college, uni
versity or other educational or research institu
tion is exempt from U.S. income tax for a period
not exceeding 2 years from the date of arrival in
the United States on income received for teach
ing or carrying on research.
This exemption does not apply to income
from research carried on mainly for the private
benefit of any person rather than in the public
interest.
Bulgaria
An individual who is a resident of Bulgaria at the
beginning of the visit to the United States and
who is temporarily in the United States to teach
or carry on research at a school, college, uni
versity or other recognized educational or re
search institution is exempt from U.S. income
tax for a period not exceeding 2 years from the
date of arrival in the United States on income
received for teaching or carrying on research.
This exemption does not apply to income
from research carried on mainly for the private
benefit of any person rather than in the public
interest.
China, People's Republic of
An individual who is a resident of the People's
Republic of China and who is temporarily in the
United States primarily to teach, lecture, or con
duct research at a university or other accredited
educational institution or scientific research in
stitution is exempt from U.S. income tax on in
come for the teaching, lecturing, or research for
a total of not more than 3 years.
This exemption does not apply to income
from research carried on mainly for the private
benefit of any person rather than in the public
interest.
Commonwealth of
Independent States (C.I.S.)
An individual who is a resident of a C.I.S. mem
ber on the date of arrival in the United States
and who is temporarily in the United States at
the invitation of the U.S. Government or an edu
cational or scientific research institution in the
United States primarily to teach, engage in re
search, or participate in scientific, technical, or
professional conferences is exempt from U.S.
income tax on income for teaching, research, or
participation in these conferences for a maxi
mum period of 2 years.
This exemption does not apply to income
from research carried on mainly for the benefit
of a private person, including a commercial en
terprise of the United States or a foreign trade
organization of a C.I.S. member.
The exemption does, however, apply if the
research is conducted through an
intergovernmental agreement on cooperation.
This exemption also applies to journalists
and correspondents who are temporarily in the
United States for periods not longer than 2
years and who receive their compensation from
abroad. It is not necessary that the journalists or
correspondents be invited by the U.S. Govern
ment or other appropriate institution, nor does it
matter that they are employed by a private per
son, including commercial enterprises and for
eign trade organizations.
Czech Republic
An individual is exempt from U.S. income tax on
income for teaching or research for up to 2
years if he or she:
Is a resident of the Czech Republic imme
diately before visiting the United States,
and
Is in the United States primarily to teach or
conduct research at a university, college,
school, or other accredited educational or
research institution.
A Czech resident is entitled to these benefits
only once. However, the exemption does not
apply if:
The resident claimed during the immediate
preceding period the benefits described
later under Students and Apprentices, or
The income is from research undertaken
primarily for the private benefit of a specific
person or persons.
Egypt
An individual who is a resident of Egypt on the
date of arrival in the United States and who is
temporarily in the United States primarily to
teach or engage in research, or both, at a uni
versity or other recognized educational institu
tion is exempt from U.S. income tax on income
from the teaching or research for a maximum of
2 years from the date of arrival in the United
States. The individual must have been invited to
the United States for a period not expected to
be longer than 2 years by the U.S. Government
or a state or local government, or by a university
or other recognized educational institution in the
United States.
The exemption does not apply if the resident
claimed, during the immediately preceding pe
riod, the benefits described later under Stu-
dents and Apprentices.
This exemption does not apply to income
from research carried on mainly for the private
benefit of any person rather than in the public
interest.
France
An individual who is a resident of France on the
date of arrival in the United States and who is
temporarily in the United States at the invitation
of the U.S. Government, a university, or other
recognized educational or research institution in
the United States primarily to teach or engage
in research, or both, at a university or other edu
cational or research institution is exempt from
U.S. income tax on income from teaching or re
search for a maximum of 2 years from the date
of arrival in the United States.
An individual may claim this benefit only
once. Also, this benefit and the benefits descri
bed later under Students and Apprentices can
be claimed for no more than 5 years.
This exemption does not apply to income
from research carried on mainly for the private
benefit of any person rather than in the public
interest.
Germany
A professor or teacher who is a resident of Ger
many and who is temporarily in the United
States to engage in advanced study or research
or teaching at an accredited educational institu
tion or institution engaged in research for the
public benefit is exempt from U.S. tax on in
come received for such study, research, or
teaching for a maximum of 2 years from the
date of arrival in the United States.
The exemption does not apply to income
from research carried on mainly for the private
benefit of any person rather than in the public
interest. The exemption does not apply if, dur
ing the preceding period, the benefit described
in paragraph (2), (3), or (4) of Article 20 of the
treaty, pertaining to students, was claimed.
Greece
A professor or teacher who is a resident of
Greece and who is temporarily in the United
States to teach at a university, college, or other
educational institution for a maximum of 3 years
is exempt from U.S. income tax on the income
received for teaching during that period.
Hungary
An individual who is a resident of Hungary on
the date of arrival in the United States and who
is temporarily in the United States primarily to
teach or engage in research, or both, at a uni
versity or other recognized educational institu
tion is exempt from U.S. income tax on income
for the teaching or research for a maximum of 2
years from the date of arrival in the United
States. The individual must have been invited to
the United States for a period not expected to
be longer than 2 years by the U.S. Government
or a state or local government, or by a university
or other recognized educational institution in the
United States.
The exemption does not apply to income
from research carried on mainly for the private
benefit of any person rather than in the public
interest.
Iceland
Although there is no provision to exempt in
come derived by teachers or researchers in the
treaty, an individual who was otherwise entitled
to treaty benefits under Article 21 (Teachers) of
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Page 16 Publication 901 (September 2016)
the treaty in effect before 2009 can continue to
apply those provisions.
India
An individual is exempt from U.S. tax on income
received for teaching or research if he or she:
Is a resident of India immediately before
visiting the United States, and
Is in the United States to teach or engage
in research at an accredited university or
other recognized educational institution in
the United States for a period not longer
than 2 years.
If the individual's visit to the United States
exceeds 2 years, the exemption is lost for the
entire visit.
This exemption does not apply to income
from research carried on mainly for the private
benefit of any person rather than in the public
interest.
Indonesia
An individual is exempt from U.S. tax on income
for teaching or research for a maximum of 2
years from the date of arrival in the United
States if he or she:
Is a resident of Indonesia immediately be
fore visiting the United States, and
Is in the United States at the invitation of a
university, school, or other recognized ed
ucational institution to teach or engage in
research, or both, at that educational insti
tution.
A resident of Indonesia is entitled to this ex
emption only once. But this exemption does not
apply to income from research carried on
mainly for the private benefit of any person.
Israel
An individual who is a resident of Israel on the
date of arrival in the United States and who is
temporarily in the United States primarily to
teach or engage in research, or both, at a uni
versity or other recognized educational institu
tion is exempt from U.S. income tax on income
from the teaching or research for a maximum of
2 years from the date of arrival in the United
States. The individual must have been invited to
the United States for a period not expected to
be longer than 2 years by the U.S. Government
or a state or local government, or by a university
or other recognized educational institution in the
United States.
This exemption does not apply to income
from research carried on mainly for the private
benefit of any person rather than in the public
interest. The exemption does not apply if, dur
ing the immediately preceding period, the bene
fits described in Article 24(1) of the treaty, per
taining to students, were claimed.
Italy
A professor or teacher who is a resident of Italy
immediately before the date of arrival in the Uni
ted States and whose visit to the United States
is expected to last no more than 2 years to
teach or conduct research at a university, col
lege, school, or other recognized educational
institution, or at a medical facility primarily fun
ded from government sources, is exempt from
U.S. income tax for up to 2 years on pay from
this teaching or research.
This exemption does not apply to income
from research carried on mainly for the private
benefit of any person rather than in the public
interest.
Jamaica
An individual who is a resident of Jamaica on
the date of arrival in the United States and who
temporarily visits the United States to teach or
engage in research at a university, college, or
other recognized educational institution for a
period not expected to exceed 2 years, is ex
empt from U.S. income tax on the income re
ceived for the teaching or research for not more
than 2 years from the date of arrival in the Uni
ted States. A resident of Jamaica is entitled to
this exemption only once.
This exemption does not apply to income
from research carried on mainly for the private
benefit of any person rather than in the public
interest.
Japan
An individual who is a resident of Japan and
who is temporarily in the United States primarily
to teach or engage in research at a university,
college, or other recognized educational institu
tion is exempt from U.S. income tax on income
for the teaching or research for a maximum of 2
years from the date of arrival in the United
States.
The exemption does not apply to income
from research carried on mainly for the private
benefit of any person rather than in the public
interest.
Korea, South
An individual who is a resident of South Korea
on the date of arrival in the United States and
who is temporarily in the United States primarily
to teach or engage in research, or both, at a
university or other recognized educational insti
tution is exempt from U.S. income tax on in
come for the teaching or research for a maxi
mum of 2 years from the date of arrival in the
United States. The individual must have been
invited to the United States for a period not ex
pected to be longer than 2 years by the U.S.
Government or a state or local government, or
by a university or other recognized educational
institution in the United States.
The exemption does not apply to income
from research carried on mainly for the private
benefit of any person rather than in the public
interest.
Luxembourg
A resident of Luxembourg who is temporarily in
the United States at the invitation of a U.S. uni
versity, college, school, or other recognized ed
ucational institution only to teach or engage in
research, or both, at that educational institution
is exempt from U.S. income tax on income for
the teaching or research for not more than 2
years from the date of arrival in the United
States.
If the individual's visit to the United States is
longer than 2 years, the exemption is lost for the
entire visit unless the competent authorities of
Luxembourg and the United States agree other
wise.
This exemption does not apply to pay for re
search carried on for the benefit of any person
other than the educational institution that exten
ded the invitation.
Netherlands
An individual is exempt from U.S. income tax on
income received for teaching or research for a
maximum of 2 years from the date of arrival if
he or she:
Is a resident of the Netherlands immedi
ately before visiting the United States, and
Is in the United States to teach or engage
in research at a university, college, or other
recognized educational institution for not
more than 2 years.
If the individual's visit to the United States is
longer than 2 years, the exemption is lost for the
entire visit unless the competent authorities of
the Netherlands and the United States agree
otherwise.
The exemption does not apply to income
from research carried on primarily for the pri
vate benefit of any person rather than in the
public interest. Nor does the exemption apply if
the resident claimed during the immediate pre
ceding period the benefits described later under
Students and Apprentices.
Norway
An individual who is a resident of Norway on the
date of arrival in the United States and who is
temporarily in the United States at the invitation
of the U.S. Government, a university, or other
recognized educational institution in the United
States primarily to teach or engage in research,
or both, at a university or other recognized edu
cational institution is exempt from U.S. income
tax on income for the teaching or research for a
maximum period of 2 years from the date of ar
rival in the United States.
This exemption does not apply to income
from research carried on mainly for the private
benefit of any person rather than in the public
interest.
Pakistan
A professor or teacher who is a resident of Paki
stan and who temporarily visits the United
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Publication 901 (September 2016) Page 17
States to teach at a university, college, school,
or other educational institution for not longer
than 2 years is exempt from U.S. income tax on
the income received for teaching for that period.
Philippines
An individual who is a resident of the Philip
pines on the date of arrival in the United States
and who is temporarily in the United States pri
marily to teach or engage in research, or both,
at a university or other recognized educational
institution is exempt from U.S. income tax on in
come from the teaching or research for not
more than 2 years from the date of arrival in the
United States. The individual must have been
invited to the United States for a period not ex
pected to be longer than 2 years by the U.S.
Government or a state or local government, or
by a university or other recognized educational
institution in the United States.
This exemption does not apply to income
from research carried on mainly for the private
benefit of any person rather than in the public
interest. The exemption does not apply if, dur
ing the immediately preceding period, the bene
fits described in Article 22(1) of the treaty, per
taining to students, were claimed.
Poland
An individual who is a resident of Poland on the
date of arrival in the United States and who is
temporarily in the United States at the invitation
of the U.S. Government, a university, or other
recognized educational institution in the United
States primarily to teach or engage in research,
or both, at a university or other recognized edu
cational institution is exempt from U.S. income
tax on income for the teaching or research for a
maximum of 2 years from the date of arrival in
the United States.
The exemption does not apply if the resident
claimed, during the immediately preceding pe
riod, the benefits described later under Stu-
dents and Apprentices.
This exemption does not apply to income
from research carried on mainly for the private
benefit of any person rather than in the public
interest.
Portugal
An individual who is a resident of Portugal on
the date of arrival in the United States and who
is temporarily in the United States at the invita
tion of the U.S. Government, a university, other
accredited educational institution, or recognized
research institution in the United States, or un
der an official cultural exchange program, only
to teach or engage in research, or both, at a
university or educational institution is exempt
from U.S. income tax on income from teaching
or research for a maximum of 2 years from the
date of arrival in the United States. An individual
is entitled to these benefits only once. However,
these benefits, and the benefits described later
under Students and Apprentices cannot be
claimed either simultaneously or consecutively.
This exemption does not apply to income
from research carried on mainly for the private
benefit of any person rather than in the public
interest.
Romania
An individual who is a resident of Romania on
the date of arrival in the United States and who
is temporarily in the United States at the invita
tion of the U.S. Government, a university, or
other recognized educational institution in the
United States primarily to teach or engage in re
search, or both, at a university or other recog
nized educational institution is exempt from
U.S. income tax on income for the teaching or
research for a maximum of 2 years from the
date of arrival in the United States.
This exemption does not apply to income
from research carried on mainly for the private
benefit of any person rather than in the public
interest.
Slovak Republic
An individual is exempt from U.S. income tax on
income for teaching or research for up to 2
years if he or she:
Is a resident of the Slovak Republic imme
diately before visiting the United States,
and
Is in the United States primarily to teach or
conduct research at a university, college,
school, or other accredited educational or
research institution.
A Slovak resident is entitled to these bene
fits only once. However, the exemption does
not apply if:
The resident claimed during the immediate
preceding period the benefits described
later under Students and Apprentices, or
The income is from research undertaken
primarily for the private benefit of a specific
person or persons.
Slovenia
An individual who is a resident of Slovenia on
the date of arrival in the United States and who
temporarily visits the United States to teach or
engage in research at a recognized educational
or research institution is exempt from U.S. in
come tax on the income received for the teach
ing or research for not more than 2 years from
the date of arrival in the United States. This
benefit can be claimed for no more than 5
years.
The exemption does not apply to income
from research carried on mainly for the private
benefit of any person rather than in the public
interest.
Thailand
An individual who is a resident of Thailand on
the date of arrival in the United States and who
is in the United States for not longer than 2
years primarily to teach or engage in research
at a university, college, school, or other recog
nized educational institution is exempt from
U.S. income tax on income for the teaching or
research. The exemption from tax applies only
if the visit does not exceed 2 years from the
date the individual first visits the United States
for the purpose of engaging in teaching or re
search.
This exemption does not apply to income
from research carried on mainly for the private
benefit of any person rather than in the public
interest. This exemption does not apply if, dur
ing the immediately preceding period, the bene
fits described in treaty Article 22(1), pertaining
to students, were claimed.
Trinidad and Tobago
An individual who is a resident of Trinidad and
Tobago on the date of arrival in the United
States and who is temporarily in the United
States at the invitation of the U.S. Government,
a university, or other accredited educational in
stitution in the United States primarily to teach
or engage in research, or both, at a university or
other accredited educational institution is ex
empt from U.S. income tax on the income re
ceived for the teaching or research for a maxi
mum of 2 years from the date of arrival in the
United States.
This exemption does not apply to income
from research carried on mainly for the private
benefit of any person rather than in the public
interest. Nor does the exemption apply to in
come if an agreement exists between the Gov
ernments of Trinidad and Tobago and the Uni
ted States for providing the services of these
individuals.
Turkey
An individual who was a resident of Turkey im
mediately before visiting the United States who
is in the United States for not longer than 2
years for the purpose of teaching or engaging in
scientific research is exempt from U.S. income
tax on payments received from outside the Uni
ted States for teaching or research.
United Kingdom
A professor or teacher who is a resident of the
United Kingdom on the date of arrival in the Uni
ted States and who is in the United States for
not longer than 2 years primarily to teach or en
gage in research at a university, college, or
other recognized educational institution is ex
empt from U.S. income tax on income for the
teaching or research. If the individual's 2year
period is exceeded, the exemption is lost for the
entire visit, including the 2year period.
The exemption does not apply to income
from research carried on mainly for the private
benefit of any person rather than in the public
interest.
Venezuela
An individual who is a resident of Venezuela on
the date of arrival in the United States and who
temporarily visits the United States to teach or
engage in research at a recognized educational
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Page 18 Publication 901 (September 2016)
or research institution is exempt from U.S. in
come tax on the income received for the teach
ing or research for not more than 2 years from
the date of arrival in the United States. This
benefit can be claimed for no more than 5
years.
The exemption does not apply to income
from research carried on mainly for the private
benefit of any person rather than in the public
interest.
Students and Apprentices
Residents of the following countries who are in
the United States to study or acquire technical
experience are exempt from U.S. income tax,
under certain conditions, on amounts received
from abroad for their maintenance and studies.
This exemption does not apply to the salary
paid by a foreign corporation to one of its exec
utives, a citizen and resident of a foreign coun
try who is temporarily in the United States to
study a particular industry for an employer. That
amount is a continuation of salary and is not re
ceived to study or acquire experience.
For each country listed there is a statement
of the conditions under which the exemption
applies to students and apprentices from that
country.
Amounts received from the National Insti
tutes of Health (NIH) under provisions of the
Visiting Fellows Program are generally treated
as a grant, allowance, or award for purposes of
whether an exemption is provided by treaty.
Amounts received from NIH under the Visiting
Associate Program and Visiting Scientist Pro
gram are not exempt from U.S. tax as a grant,
allowance, or award.
Australia
A resident of Australia or an individual who was
a resident of Australia immediately before visit
ing the United States who is temporarily here for
fulltime education is exempt from U.S. income
tax on payments received from outside the Uni
ted States for the individual's maintenance or
education.
Austria
A student, apprentice, or business trainee who
is a resident of Austria immediately before visit
ing the United States and is in the United States
for the purpose of fulltime education at a recog
nized educational institution or fulltime training
is exempt from U.S. income tax on amounts re
ceived from sources outside the United States
for the individual's maintenance, education, or
training.
Apprentices and business trainees are enti
tled to the benefit of this exemption for a maxi
mum period of 3 years.
Bangladesh
An individual who is a resident of Bangladesh
immediately before visiting the United States
and who is temporarily present in the United
States for the primary purpose of:
1. Studying at a university, college, school,
or other recognized educational institution
in the United States,
2. Securing training as a business or techni
cal apprentice, or
3. Studying or doing research as a recipient
of a grant, allowance, or award from a
governmental, religious, charitable, or ed
ucational organization
is exempt from U.S. tax on the following
amounts.
The payments from abroad for the purpose
of maintenance, education, or training.
The grant, allowance, or award.
The income from personal services per
formed in the United States of up to $8,000
for the tax year.
For an individual described in (2), the ex
emption from tax applies for not more than 2
years from the date the individual first arrived in
the United States.
Barbados
A student or business apprentice who is a resi
dent of Barbados on the date of arrival in the
United States and is here for fulltime education
or training is exempt from U.S. income tax on
payments received from outside the United
States for the individual's maintenance, educa
tion, or training.
Nevertheless, an individual who qualifies for
this exemption may instead choose to be
treated as a resident alien of the United States
for all U.S. income tax purposes. Once made,
this choice applies for the entire period that the
individual remains qualified for exemption and
may not be revoked without the permission of
the U.S. competent authority.
Belgium
A student or business trainee who is a resident
of Belgium immediately before visiting the Uni
ted States and is in the United States for the
purpose of fulltime education or training is ex
empt from U.S. income tax on the following
amounts.
Payments received from abroad for main
tenance, education, or training.
Income from personal services of up to
$9,000 for each tax year.
An apprentice or a business trainee is enti
tled to the benefit of this exemption for a maxi
mum period of 2 years.
For this purpose, a business trainee is an in
dividual who is temporarily in the United States:
To secure training to practice a profession
or professional specialty, or
As an employee of, or under contract with,
a resident of Belgium, for the primary pur
pose of acquiring technical, professional,
or business experience from a person
other than that resident of Belgium or other
than a person related to that resident.
Bulgaria
A student or business trainee who is a resident
of Bulgaria immediately before visiting the Uni
ted States and is in the United States for the
purpose of fulltime education at a college, uni
versity, or other recognized educational institu
tion of a similar nature, or fulltime training is ex
empt from U.S. income tax on the following
amounts.
Payments received from abroad for main
tenance, education, or training.
Income from personal services of up to
$9,000 for each tax year.
An apprentice or a business trainee is enti
tled to the benefit of this exemption for a maxi
mum period of 2 years.
For this purpose, a business trainee is an in
dividual who is temporarily in the United States:
To secure training to practice a profession
or professional specialty, or
As an employee of, or under contract with,
a resident of Bulgaria, for the primary pur
pose of acquiring technical, professional,
or business experience from a person
other than that resident of Bulgaria or other
than a person related to that resident.
Canada
A student, business trainee, or apprentice who
is or was a Canadian resident immediately be
fore visiting the United States, and is in the Uni
ted States for the purpose of fulltime education
or fulltime training, is exempt from U.S. income
tax on amounts received from sources outside
the United States for maintenance, education,
or training.
Apprentices and business trainees are enti
tled to the benefit of this exemption for a maxi
mum period of 1 year.
Also see Publication 597, Information on the
United States–Canada Income Tax Treaty.
China, People's Republic of
A student, business apprentice, or trainee who
is a resident of the People's Republic of China
on the date of arrival in the United States and
who is present in the United States solely to ob
tain training, education, or special technical ex
perience is exempt from U.S. income tax on the
following amounts.
Payments received from abroad for main
tenance, education, study, research, or
training.
Grants or awards from a government, sci
entific, educational, or other taxexempt or
ganization.
Income from personal services performed
in the United States of up to $5,000 for
each tax year.
An individual is entitled to this exemption
only for the time reasonably necessary to com
plete the education or training.
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Publication 901 (September 2016) Page 19
Commonwealth of
Independent States (C.I.S.)
An individual who is a resident of a C.I.S. mem
ber and who is temporarily in the United States
primarily to study at an educational or scientific
research institution or to obtain training for qual
ification in a profession or specialty is exempt
from U.S. income tax on amounts received as
stipends, scholarships, or other substitute al
lowances necessary to provide ordinary living
expenses. An individual is entitled to the benefit
of this exemption for a maximum of 5 years and
for less than $10,000 in each tax year.
An individual who is a resident of a C.I.S.
member and who is temporarily in the United
States primarily to acquire technical, professio
nal, or commercial experience or perform tech
nical services and who is an employee of, or
under contract with, a resident of a C.I.S. mem
ber is exempt from U.S. income tax on the
amounts received from that resident. Also ex
empt is an amount received from U.S. sources,
of not more than $10,000, that is necessary to
provide for ordinary living expenses. The ex
emption contained in this paragraph is limited to
1 year.
An individual who is a resident of a C.I.S.
member and who is temporarily present in the
United States under an exchange program pro
vided for by an agreement between govern
ments on cooperation in various fields of sci
ence and technology is exempt from U.S.
income tax on all income received in connec
tion with the exchange program for a period not
longer than 1 year.
Cyprus
An individual who is a resident of Cyprus on the
date of arrival in the United States and who is
temporarily here primarily to study at a univer
sity or other recognized educational institution
in the United States, obtain professional train
ing, or study or do research as a recipient of a
grant, allowance, or award from a governmen
tal, religious, charitable, scientific, literary, or
educational organization is exempt from U.S.
income tax on the following amounts.
Gifts from abroad for maintenance, educa
tion, or training.
The grant, allowance, or award.
Income from personal services performed
in the United States of up to $2,000 for
each tax year.
An individual is entitled to this exemption for
up to 5 tax years and for an additional period as
is necessary to complete, as a fulltime student,
educational requirements for a postgraduate or
professional degree from a recognized educa
tional institution.
An individual who is a resident of Cyprus on
the date of arrival in the United States and who
is temporarily here as an employee of, or under
contract with, a resident of Cyprus is exempt
from U.S. income tax for not more than 1 year
on income from personal services for a maxi
mum of $7,500 if the individual is in the United
States primarily to either:
Acquire technical, professional, or busi
ness experience from a person other than
a resident of Cyprus or other than a person
related to that resident, or
Study at a university or other recognized
educational institution.
An individual who is a resident of Cyprus on
the date of arrival in the United States and who
is temporarily here for a period of not more than
1 year as a participant in a program sponsored
by the U.S. Government primarily to train, re
search, or study is exempt from U.S. income tax
on income for personal services for the training,
research, or study. This exemption is limited to
$10,000.
Czech Republic
An individual who is a resident of the Czech Re
public at the beginning of his or her visit to the
United States and who is temporarily present in
the United States is exempt from U.S. income
tax on certain amounts for a period of up to 5
years. To be entitled to the exemption, the indi
vidual must be in the United States for the pri
mary purpose of:
Studying at a university or other accredited
educational institution in the United States,
Obtaining training required to qualify him or
her to practice a profession or professional
specialty, or
Studying or doing research as a recipient
of a grant, allowance, or award from a gov
ernmental, religious, charitable, scientific,
literary, or educational organization.
If the individual meets any of these require
ments, the following amounts are exempt from
U.S. tax.
The payments from abroad, other than
compensation for personal services, for
the purpose of maintenance, education,
study, research, or training.
The grant, allowance, or award.
The income from personal services per
formed in the United States of up to $5,000
for the tax year.
An individual who is a Czech resident at the
beginning of the visit to the United States and
who is temporarily present in the United States
as an employee of, or under contract with, a
Czech resident is exempt from U.S. income tax
for a period of 12 consecutive months on up to
$8,000 received for personal services if the indi
vidual is in the United States primarily to:
Acquire technical, professional, or busi
ness experience from a person other than
the Czech resident, or
Study at a university or other accredited
educational institution in the United States.
An individual who is a Czech resident at the
time he or she becomes temporarily present in
the United States and who is temporarily
present in the United States for a period not lon
ger than 1 year as a participant in a program
sponsored by the U.S. Government for the pri
mary purpose of training, research, or study is
exempt from U.S. income tax on up to $10,000
of income from personal services for that train
ing, research, or study.
These exemptions do not apply to income
from research undertaken primarily for the pri
vate benefit of a specific person or persons.
Denmark
A student, apprentice, or business trainee who
is a resident of Denmark immediately before
visiting the United States and is in the United
States for the purpose of fulltime education at
an accredited educational institution, or fulltime
training, is exempt from U.S. income tax on
amounts received from sources outside the Uni
ted States for the individual's maintenance, ed
ucation, or training.
Apprentices and business trainees are enti
tled to the benefit of this exemption for a maxi
mum period of 3 years.
The exemption does not apply to income
from research undertaken primarily for the pri
vate benefit of a specific person or persons.
Egypt
An individual who is a resident of Egypt on the
date of arrival in the United States and who is
temporarily in the United States primarily to
study at a university or other recognized educa
tional institution in the United States, obtain pro
fessional training, or study or do research as a
recipient of a grant, allowance, or award from a
governmental, religious, charitable, scientific,
literary, or educational organization is exempt
from U.S. income tax on the following amounts.
Gifts from abroad for maintenance, educa
tion, study, research, or training.
The grant, allowance, or award.
Income from personal services performed
in the United States of up to $3,000 each
tax year.
An individual is entitled to the benefit of this
exemption for a maximum of 5 tax years and for
any additional period of time needed to com
plete, as a fulltime student, educational re
quirements as a candidate for a postgraduate
or professional degree from a recognized edu
cational institution.
An individual who is a resident of Egypt on
the date of arrival in the United States and who
is temporarily in the United States as an em
ployee of, or under contract with, a resident of
Egypt is exempt from U.S. income tax for a pe
riod of 12 consecutive months on up to $7,500
received for personal services if the individual is
in the United States primarily to:
Acquire technical, professional, or busi
ness experience from a person other than
that resident of Egypt or other than a per
son related to that resident, or
Study at a university or other educational
institution.
An individual who is a resident of Egypt on
the date of arrival in the United States and who
is temporarily in the United States for no more
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Page 20 Publication 901 (September 2016)
than 1 year as a participant in a program spon
sored by the U.S. Government primarily to train,
research, or study is exempt from U.S. income
tax on income received for personal services for
the training, research, or study for a maximum
of $10,000.
Estonia
An individual who is a resident of Estonia on the
date of arrival in the United States and who is
temporarily in the United States primarily to
study at a university or other accredited educa
tional institution in the United States, obtain pro
fessional training, or study or do research as a
recipient of a grant, allowance, or award from a
governmental, religious, charitable, scientific,
literary, or educational organization is exempt
from U.S. income tax on the following amounts.
Payments from abroad, other than com
pensation for personal services, for main
tenance, education, study, research, or
training.
The grant, allowance, or award.
Income from personal services performed
in the United States of up to $5,000 for
each tax year.
An individual is entitled to the benefit of this
exemption for a maximum of 5 years.
An individual who is a resident of Estonia on
the date of arrival in the United States and who
is in the United States as an employee of, or un
der contract with, a resident of Estonia is ex
empt from U.S. income tax for a period of 12
consecutive months on up to $8,000 received
for personal services if the individual is in the
United States primarily to:
Acquire technical, professional, or busi
ness experience from a person other than
that resident of Estonia, or
Study at an educational institution.
An individual who is a resident of Estonia on
the date of arrival in the United States and who
is temporarily present in the United States for
not longer than 1 year as a participant in a pro
gram sponsored by the U.S. Government pri
marily to train, research, or study is exempt
from U.S. income tax on income received for
personal services for the training, research, or
study in the amount of $10,000.
These provisions do not apply to income
from research carried on mainly for the private
benefit of any person rather than in the public
interest.
Finland
A fulltime student, trainee, or business appren
tice who is a resident of Finland immediately
before visiting the United States is exempt from
U.S. income tax on amounts received from
sources outside the United States for mainte
nance, education, or training.
France
An individual who is a resident of France on the
date of arrival in the United States and who is
temporarily in the United States primarily to
study at a university or other recognized educa
tional institution in the United States, obtain pro
fessional training, or study, or do research as a
recipient of a grant, allowance, or award from a
notforprofit governmental, religious, charita
ble, scientific, artistic, cultural, or educational
organization is exempt from U.S. income tax on
the following amounts.
Gifts from abroad for maintenance, educa
tion, study, research, or training.
The grant, allowance, or award.
Income from personal services performed
in the United States of up to $5,000 each
tax year.
An individual is entitled to this benefit and
the benefit described earlier under Professors,
Teachers, and Researchers for a maximum of 5
tax years.
This exemption does not apply to income
from research carried on mainly for the private
benefit of any person rather than in the public
interest.
An individual who is a resident of France on
the date of arrival in the United States and who
is in the United States as an employee of, or un
der contract with, a resident of France is ex
empt from U.S. income tax for a period of 12
consecutive months on up to $8,000 received
for personal services if the individual is in the
United States primarily to:
Acquire technical, professional, or busi
ness experience from a person other than
that resident of France, or
Study at an educational institution.
Germany
A student or business apprentice (including Vo
lontaere and Praktikanten) who is or was imme
diately before visiting the United States a resi
dent of Germany and who is present in the
United States for fulltime education or training
is exempt from U.S. income tax on amounts
from sources outside the United States for
maintenance, education, or training.
An individual who is or was immediately be
fore visiting the United States a resident of Ger
many is exempt from U.S. tax on amounts re
ceived as a grant, allowance, or award from a
nonprofit religious, charitable, scientific, literary,
or educational organization.
Individuals described in the previous two
paragraphs are also exempt from U.S. tax on
compensation for dependent personal services
of up to $9,000 per year if:
They are present in the United States for
not more than 4 years, and
The services are performed for the pur
pose of supplementing funds available oth
erwise for maintenance, education, or
training.
If the individual's visit exceeds 4 years, the
exemption is lost for the entire visit unless the
competent authorities of Germany and the Uni
ted States agree otherwise.
An individual who is a resident of Germany
and who is employed by a German enterprise
or by a nonprofit religious, charitable, scientific,
literary, or educational organization is exempt
from U.S. tax on compensation paid by the em
ployer from outside the United States if:
The individual is temporarily in the United
States for not more than 1 year to acquire
technical, professional, or business experi
ence from any person other than his or her
employer, and
The compensation is not more than
$10,000.
If the compensation is more than $10,000, none
of the income is exempt.
Greece
A student or business apprentice who is a resi
dent of Greece and is temporarily in the United
States only to study or acquire business experi
ence is exempt from U.S. income tax on
amounts received from sources outside the Uni
ted States for maintenance or studies.
Hungary
An individual who is a resident of Hungary im
mediately before arrival in the United States
and is here for fulltime education or training is
exempt from U.S. income tax on payments re
ceived from outside the United States for the in
dividual's maintenance, education, or training.
The fulltime student or trainee may instead
choose to be treated as a resident alien of the
United States for U.S. income tax purposes.
Once made, the choice applies for the entire
period that the individual remains qualified for
exemption as a fulltime student or trainee and
may not be changed unless permission is ob
tained from the U.S. competent authority.
Iceland
An individual who is a resident of Iceland on the
date of arrival in the United States and who is
temporarily in the United States primarily to
study at a university or other recognized educa
tional institution in the United States, obtain pro
fessional training, or study or do research as a
recipient of a grant, allowance, or award from a
governmental, religious, charitable, scientific,
literary, or educational organization is exempt
from U.S. income tax on the following amounts.
Gifts from abroad for maintenance, educa
tion, study, research, or training.
The grant, allowance, or award.
Income from personal services performed
in the United States of up to $9,000 each
tax year.
An individual is entitled to the benefit of this
exemption for a maximum of 5 years.
An individual who is a resident of Iceland on
the date of arrival in the United States and who
is temporarily in the United States as an em
ployee of, or under contract with, a resident of
Iceland is exempt from U.S. income tax for a
period of 12 consecutive months on up to
$9,000 received for personal services if the indi
vidual is in the United States primarily to:
Acquire technical, professional, or busi
ness experience from a person other than
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Publication 901 (September 2016) Page 21
that resident of Iceland or other than a per
son related to that person, or
Study at a university or other educational
institution.
An individual who is a resident of Iceland on
the date of arrival in the United States and who
is temporarily present in the United States for
not longer than 1 year as a participant in a pro
gram sponsored by the U.S. Government pri
marily to train, research, or study is exempt
from U.S. income tax on income received for
personal services for the training, research, or
study for a maximum of $9,000.
India
An individual who is a resident of India immedi
ately before visiting the United States and who
is temporarily in the United States primarily for
studying or training is exempt from U.S. income
tax on payments from abroad for maintenance,
study, or training. The exemption does not ap
ply to payments borne by a permanent estab
lishment in the United States or paid by a U.S.
citizen or resident, the U.S. Government, or any
of its agencies, instrumentalities, political subdi
visions, or local authorities.
Under the treaty, if the payments are not ex
empt under the rule described above, an indi
vidual described in the previous paragraph may
be eligible to deduct exemptions for his or her
spouse and dependents and the standard de
duction. The individual must file Form 1040NR
or Form 1040NREZ to claim these amounts.
For information on how to claim these amounts,
see chapter 5 in Publication 519.
The individual is entitled to these benefits
only for a period of time considered reasonable
or customarily required to complete studying or
training.
Indonesia
An individual who is a resident of Indonesia im
mediately before visiting the United States and
who is temporarily in the United States is ex
empt from U.S. income tax on certain amounts
for a period of up to 5 years. To be entitled to
the exemption, the individual must be tempora
rily in the United States for fulltime study at a
U.S. university, school, or other recognized ed
ucational institution, or for fulltime study, re
search, or training as a recipient of a grant, al
lowance, or award from either the U.S. or
Indonesian Government, a scientific, educa
tional, religious, or charitable organization, or
under a technical assistance program entered
into by either the U.S. or Indonesian Govern
ment. If the individual meets any of these re
quirements, the following amounts are exempt
from tax.
All payments from abroad for mainte
nance, education, study, research, or train
ing.
The grant, allowance, or award.
Income from personal services performed
in the United States of up to $2,000 each
tax year.
An individual who is a resident of Indonesia
immediately before visiting the United States
and is temporarily in the United States only as a
business or technical apprentice is exempt from
U.S. income tax for a period of 12 consecutive
months on up to $7,500 received for personal
services.
Ireland
A student, apprentice, or business trainee who
is a resident of Ireland immediately before visit
ing the United States and is in the United States
for the purpose of fulltime education at a recog
nized educational institution or fulltime training
is exempt from U.S. income tax on amounts re
ceived from sources outside the United States
for the individual's maintenance, education, or
training.
Apprentices and business trainees are enti
tled to the benefit of this exemption for a maxi
mum period of 1 year.
Israel
An individual who is a resident of Israel on the
date of arrival in the United States and who is
temporarily in the United States primarily to
study at a university or other recognized educa
tional institution in the United States, obtain pro
fessional training, or study or do research as a
recipient of a grant, allowance, or award from a
governmental, religious, charitable, scientific,
literary, or educational organization is exempt
from U.S. income tax on the following amounts.
Gifts from abroad for maintenance, educa
tion, study, research, or training.
The grant, allowance, or award.
Income from personal services performed
in the United States of up to $3,000 each
tax year.
An individual is entitled to the benefit of this
exemption for a maximum of 5 tax years.
An individual who is a resident of Israel on
the date of arrival in the United States and who
is temporarily in the United States as an em
ployee of, or under contract with, a resident of
Israel is exempt from U.S. income tax for a pe
riod of 12 consecutive months on up to $7,500
received for personal services if the individual is
in the United States primarily to:
Acquire technical, professional, or busi
ness experience from a person other than
that resident of Israel or other than a per
son related to that resident, or
Study at a university or other educational
institution.
An individual who is a resident of Israel on
the date of arrival in the United States and who
is temporarily in the United States for no more
than 1 year as a participant in a program spon
sored by the U.S. Government primarily to train,
research, or study is exempt from U.S. income
tax on income received for personal services for
the training, research, or study for a maximum
of $10,000.
Italy
A student or business apprentice (trainee) who
is a resident of Italy immediately before the date
of arrival in the United States and who is
present in the United States only for education
or training at a recognized educational institu
tion is exempt from U.S. income tax on amounts
received from outside the United States for
maintenance, education, and training.
Jamaica
A student who is a resident of Jamaica on the
date of arrival in the United States and is here
for fulltime education or training is exempt from
U.S. income tax on payments received from
outside the United States for the student's
maintenance, education, or training.
An individual who is a resident of Jamaica
on the date of arrival in the United States and
who is temporarily in the United States as an
employee of, or under contract with, a resident
of Jamaica is exempt from U.S. income tax for a
period of 12 consecutive months on up to
$7,500 of net income from personal services if
the individual is in the United States primarily to:
Acquire technical, professional, or busi
ness experience from a person other than
that resident of Jamaica or other than a
person related to that resident, or
Study at a university or other recognized
educational institution.
An individual who qualifies for one of the ex
emptions discussed above may instead choose
to be treated as a resident alien of the United
States for all U.S. income tax purposes. Once
made, the choice applies for the entire period
that the individual remains qualified for exemp
tion and may not be revoked unless permission
is obtained from the U.S. competent authority.
Japan
A student or business apprentice who is a resi
dent of Japan immediately before visiting the
United States and is in the United States for the
purpose of education or training is exempt from
U.S. income tax on amounts received from
abroad for the individual's maintenance, educa
tion, or training.
Business apprentices are entitled to the
benefit of this exemption for a maximum period
of 1 year.
Kazakhstan
An individual who is a resident of Kazakhstan at
the beginning of his or her visit to the United
States is exempt from U.S. tax on payments
from abroad for maintenance, education, study,
research, or training and on any grant, allow
ance, or other similar payments. To be entitled
to the exemption, the individual must be tempo
rarily present in the United States primarily to:
Study at a university or other accredited
educational institution,
Obtain training required to qualify him or
her to practice a profession or professional
specialty, or,
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Page 22 Publication 901 (September 2016)
Study or do research as a recipient of a
grant, allowance, or other similar payments
from a governmental, religious, charitable,
scientific, literary, or educational organiza
tion.
The individual is entitled to this exemption
only for a period of time necessary to complete
the study, training, or research, but the exemp
tion for training or research may not extend for a
period exceeding 5 years.
These exemptions do not apply to income
from research if it is undertaken primarily for the
private benefit of a specific person or persons.
Korea, South
An individual who is a resident of South Korea
on the date of arrival in the United States and
who is temporarily in the United States primarily
to study at a university or other recognized edu
cational institution in the United States, obtain
professional training, or study or do research as
a recipient of a grant, allowance, or award from
a governmental, religious, charitable, scientific,
literary, or educational organization is exempt
from U.S. income tax on the following amounts.
Amounts from abroad for maintenance, ed
ucation, study, research, or training.
The grant, allowance, or award.
Income from personal services performed
in the United States of up to $2,000 each
tax year.
An individual is entitled to the benefit of this
exemption for a maximum of 5 years.
An individual who is a resident of Korea on
the date of arrival in the United States and who
is temporarily in the United States as an em
ployee of, or under contract with, a resident of
Korea is exempt from U.S. income tax for 1 year
on up to $5,000 received for personal services
if the individual is in the United States primarily
to:
Acquire technical, professional, or busi
ness experience from a person other than
that resident of Korea or other than a per
son related to that resident, or
Study at an educational institution.
An individual who is a resident of Korea on
the date of arrival in the United States and who
is temporarily present in the United States for
not longer than 1 year as a participant in a pro
gram sponsored by the U.S. Government pri
marily to train, research, or study is exempt
from U.S. income tax on income received for
personal services for the training, research, or
study for a maximum of $10,000.
Latvia
An individual who is a resident of Latvia on the
date of arrival in the United States and who is
temporarily in the United States primarily to
study at a university or other accredited educa
tional institution in the United States, obtain pro
fessional training, or study or do research as a
recipient of a grant, allowance, or award from a
governmental, religious, charitable, scientific,
literary, or educational organization is exempt
from U.S. income tax on the following amounts.
Payments from abroad, other than com
pensation for personal services, for main
tenance, education, study, research, or
training.
The grant, allowance, or award.
Income from personal services performed
in the United States of up to $5,000 for
each tax year.
An individual is entitled to the benefit of this
exemption for a maximum of 5 years.
An individual who is a resident of Latvia on
the date of arrival in the United States and who
is in the United States as an employee of, or un
der contract with, a resident of Latvia is exempt
from U.S. income tax for a period of 12 consec
utive months on up to $8,000 received for per
sonal services if the individual is in the United
States primarily to:
Acquire technical, professional, or busi
ness experience from a person other than
that resident of Latvia, or
Study at an educational institution.
An individual who is a resident of Latvia on
the date of arrival in the United States and who
is temporarily present in the United States for
not longer than 1 year as a participant in a pro
gram sponsored by the U.S. Government pri
marily to train, research, or study is exempt
from U.S. income tax on income received for
personal services for the training, research, or
study in the amount of $10,000.
These provisions do not apply to income
from research carried on mainly for the private
benefit of any person rather than in the public
interest.
Lithuania
An individual who is a resident of Lithuania on
the date of arrival in the United States and who
is temporarily in the United States primarily to
study at a university or other accredited educa
tional institution in the United States, obtain pro
fessional training, or study or do research as a
recipient of a grant, allowance, or award from a
governmental, religious, charitable, scientific,
literary, or educational organization is exempt
from U.S. income tax on the following amounts.
Payments from abroad, other than com
pensation for personal services, for main
tenance, education, study, research, or
training.
The grant, allowance, or award.
Income from personal services performed
in the United States of up to $5,000 for
each tax year.
An individual is entitled to the benefit of this