Publication 901 (Rev. September 2016) P901

User Manual: 901

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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 treatybased 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)
•IRS.gov/Korean (한국어)
•IRS.gov/Russian (Pусский)
•IRS.gov/Vietnamese (TiếngViệt)
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Oct 12, 2016
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, IR6526
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 617056613
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)
TreatyBased 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 treatybased 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
treatybased 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 selfemployed individuals (inde
pendent personal services) in the United States
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Page 2 Publication 901 (September 2016)
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
selfemployed 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 12month 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 selfemployed 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 12month 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 12month 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 selfemployed 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 selfemployed 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 12month 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 selfemployed 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 12month 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 selfemployed 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
12month 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 selfemployed 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 selfemployed 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 selfemployed 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 12month 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
12month 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 selfemployed 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 12month 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 selfemployed 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 selfemployed 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 12month 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 12month 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 selfemployed 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 12month 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 selfemployed 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 12month 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 selfemployed 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 selfemployed 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
selfemployed 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 12month 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 selfemployed 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 selfemployed 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 12month 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 12month 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 12month 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
selfemployed 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 12month 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 selfemployed 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
Page 7 of 34 Fileid: … ons/P901/201609/B/XML/Cycle01/source 10:19  12Oct2016
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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
selfemployed 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 selfemployed 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
selfemployed 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 12month 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 selfemployed 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
12month 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 12month 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 selfemployed 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 selfemployed 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 12month 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 12month 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 selfemployed 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 12month 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 12month 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 selfemployed 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 12month 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
selfemployed 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 12month 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 selfemployed 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 12month 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
12month 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 selfemployed 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 selfemployed 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 selfemployed 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
12month 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 selfemployed 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 selfemployed 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 selfemployed 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 selfemployed 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 12month 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 12month 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 selfemployed 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 selfemployed 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 selfemployed 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 12month 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
12month 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 selfemployed 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 12month 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 selfemployed 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 12month 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 12month 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 selfemployed 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
12month 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 selfemployed 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 12month 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 12month 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 selfemployed 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
12month 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 12month 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 selfemployed 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 12month 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 selfemployed 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 12month 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 selfemployed 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 selfemployed 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 12month 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 12month 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
nonprofit 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 selfemployed 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 selfemployed 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 12month 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 selfemployed 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 12month 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 2year
period is exceeded, the exemption is lost for the
entire visit, including the 2year 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
fulltime 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 fulltime education at a recog
nized educational institution or fulltime 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 fulltime 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 fulltime 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 fulltime education at a college, uni
versity, or other recognized educational institu
tion of a similar nature, or fulltime 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 fulltime education
or fulltime 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 taxexempt 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 fulltime 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 fulltime education at
an accredited educational institution, or fulltime
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 fulltime 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 fulltime 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
notforprofit 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 fulltime 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 fulltime 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 fulltime 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 fulltime 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 1040NREZ 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 fulltime study at a
U.S. university, school, or other recognized ed
ucational institution, or for fulltime 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 fulltime education at a recog
nized educational institution or fulltime 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 fulltime 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
exemption for a maximum of 5 years.
An individual who is a resident of Lithuania
on the date of arrival in the United States and
who is in the United States as an employee of,
or under contract with, a resident of Lithuania 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 individual is in the
United States primarily to:
Acquire technical, professional, or busi
ness experience from a person other than
that resident of Lithuania, or
Study at an educational institution.
An individual who is a resident of Lithuania
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
program sponsored 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 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.
Luxembourg
A student, apprentice, or business trainee who
is a resident of Luxembourg immediately before
visiting the United States and is in the United
States for the purpose of fulltime education at a
recognized educational institution or fulltime
training is exempt from U.S. income tax on
amounts received for the individual's mainte
nance, education, or training.
Apprentices and business trainees are enti
tled to the benefit of this exemption for a maxi
mum period of 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
Luxembourg and the United States agree other
wise.
Malta
A student or business trainee, who is a resident
of Malta immediately before visiting the United
States and is in the United States for the pur
pose of fulltime education or training, is exempt
from U.S. income tax on the following amounts.
Payments received from sources outside
the United States for the individual's main
tenance, education, or training. Apprenti
ces and business trainees are entitled to
this benefit for a maximum period of 1
year.
Income from personal services performed
in the United States of up to $9,000 for
each tax year.
Mexico
A student or business apprentice who is a resi
dent of Mexico immediately before visiting the
United States and is in the United States solely
for the purpose of education or training is ex
empt from U.S. tax on amounts received from
sources outside the United States for the indi
vidual's maintenance, education, or training.
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Publication 901 (September 2016) Page 23
Morocco
An individual who is a resident of Morocco 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 $2,000 each
tax year.
An individual is entitled to the benefit of this
exemption for a maximum of 5 years.
Netherlands
An individual who immediately before visiting
the United States is a resident of the Nether
lands and who is present in the United States
primarily for fulltime study at a recognized uni
versity, college, or school or securing training
as a business apprentice is exempt from U.S.
income tax on the following amounts.
Payments from abroad for maintenance,
education, or training.
Income from personal services performed
in the United States of up to $2,000 each
tax year.
The individual is entitled to this exemption
only for a period of time considered reasonable
or customarily required to complete studying or
training.
An individual who immediately before visit
ing the United States is a resident of the Nether
lands and is temporarily present in the United
States for a period not exceeding 3 years for
the purpose of study, research, or training
solely as a recipient of a grant, allowance, or
award from a scientific, educational, religious,
or charitable organization or under a technical
assistance program entered into by either the
Netherlands or the United States, or its political
subdivisions or local authorities is exempt from
U.S. income tax on the following amounts.
The amount of the grant, allowance, or
award.
Income of up to $2,000 for personal serv
ices performed in the United States for any
tax year if the services are connected with,
or incidental to, the study, research, or
training.
An individual is not entitled to these exemp
tions if, during the immediately preceding pe
riod, the individual claimed the exemption dis
cussed earlier under Professors, Teachers, and
Researchers.
New Zealand
A resident of New Zealand or an individual who
was a resident of New Zealand immediately be
fore visiting the United States who is in the
United States for fulltime education is exempt
from U.S. income tax on amounts received from
abroad for maintenance or education.
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 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 $2,000 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 Norway 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 Norway is ex
empt from U.S. income tax for a period of 12
consecutive months 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 Norway or other than a per
son related to that resident of Norway, or
Study at an educational institution.
Also exempt is a resident of Norway who is
present in the United States for not longer than
1 year as a participant in a program sponsored
by the Government of the United States primar
ily to train, research, or study. The individual is
exempt from tax on income from personal serv
ices performed in the United States and re
ceived for the training, research, or study, for a
maximum of $10,000.
Pakistan
Residents of Pakistan temporarily in the United
States are exempt from U.S. income tax on cer
tain income they may receive. To be entitled to
this exemption, they must be in the United
States only as students at a recognized univer
sity, college, or school, or as recipients of
grants, allowances, or awards from religious,
charitable, scientific, or educational organiza
tions of Pakistan primarily to study or research.
The income exempt in these cases is any pay
ment from abroad for maintenance, education,
or training, and any pay for personal services of
not more than $5,000 for any tax year.
Other residents of Pakistan who are tempo
rarily in the United States for no more than 1
year are exempt from U.S. income tax on pay of
not more than $6,000 received for that period,
including pay from the enterprise or organiza
tion of which they are employees or with which
they are under contract. To qualify for this ex
emption, they must be employees of, or under
contract with, a Pakistani enterprise or religious,
charitable, scientific, or educational organiza
tion and be in the United States only to acquire
technical, professional, or business experience
from a person other than that enterprise or or
ganization.
Also exempt from U.S. income tax on cer
tain income are residents of Pakistan tempora
rily in the United States under an arrangement
with the U.S. Government, or any of its agen
cies or instrumentalities, only for study, training,
or orientation. They are exempt from tax on in
come of not more than $10,000 for services di
rectly related to their training, study, or orienta
tion, including income from their employer
abroad.
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 study at a university or other recog
nized educational 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, chari
table, scientific, literary, or educational organi
zation 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 years.
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 as
an employee of, or under contract with, a resi
dent of the Philippines is exempt from U.S. in
come tax for a period 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 the Philippines or other
than a person related to that resident, or
Study at an educational institution.
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 (for
no more 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, up to a maximum of $10,000.
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 primarily to
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Page 24 Publication 901 (September 2016)
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.
Any other payments received from Poland,
except income from performing personal
services.
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 Poland 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
Poland is exempt from U.S. income tax for 1
year on up to $5,000 received for personal serv
ices if the individual is in the United States pri
marily to:
Acquire technical, professional, or busi
ness experience from a person other than
that resident of Poland or other than a per
son related to that resident, or
Study at an educational institution.
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 for not longer
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 up to $10,000 of income received for per
sonal services for the training, research, or
study.
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 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 for maintenance,
education, 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 the benefit of this
exemption for a maximum of 5 tax years from
the date of arrival in the United States. The ben
efits provided here and the benefits described
earlier under Professors, Teachers, and Re-
searchers cannot be claimed simultaneously or
consecutively.
An individual who is a resident of Portugal
on the date of arrival in the United States and
who is in the United States as an employee of,
or under contract with, a resident of Portugal 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 individual is in the
United States primarily to:
Acquire technical, professional, or busi
ness experience from a person other than
that resident of Portugal, or
Study at an educational institution.
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 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 $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 Romania
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 Romania 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 Romania or other than a
person related to that resident, or
Study at an educational institution.
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 for not
longer than 1 year as a participant in a program
sponsored by the U.S. Government primarily to
train, research, or study is exempt from U.S. in
come tax on up to $10,000 of income received
for personal services for the training, research,
or study.
Russia
An individual who is a resident of Russia 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, re
search, or training and on any grant, allowance,
or other similar payments. To be entitled to the
exemption, the individual must be temporarily
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
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.
Slovak Republic
An individual who is a resident of the Slovak
Republic 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 exemp
tion, the individual must be in the United States
for the primary 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 Slovak 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
Slovak resident is exempt from U.S. income tax
for a period of 12 consecutive months on up to
$8,000 received 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
the Slovak resident, or
Study at a university or other accredited
educational institution in the United States.
An individual who is a Slovak 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.
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Publication 901 (September 2016) Page 25
Slovenia
An individual who is a resident of Slovenia at
the beginning of the visit to the United States
and who is temporarily in the United States pri
marily to study at a U.S. university or other rec
ognized educational institution, to obtain train
ing to become qualified to practice a profession
or professional specialty, or to study or do re
search as a recipient of a grant, allowance, or
award from a governmental, religious, charita
ble, scientific, literary, or educational organiza
tion is exempt from U.S. income tax on the fol
lowing 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 ex
emption for a maximum of 5 tax years and for
any additional period of time needed to com
plete, as a fulltime 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 Slovenia
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 Slovenia is exempt from U.S. income tax for
a period not exceeding 12 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
that resident of Slovenia, or
Study at a university or other recognized
educational institution.
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.
South Africa
A student, apprentice, or business trainee who
is a resident of South Africa immediately before
visiting the United States and is in the United
States for the purpose of fulltime education or
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 1 year.
Spain
An individual who is a resident of Spain at the
beginning of the visit to the United States and
who is temporarily in the United States primarily
to study at a U.S. university or other accredited
educational institution, to obtain training to be
come qualified to practice a profession or pro
fessional specialty, or to study or do research
as a recipient of a grant, allowance, or award
from a governmental, religious, charitable, sci
entific, 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 ex
emption for a maximum of 5 years.
An individual who is a resident of Spain at
the beginning of the visit to the United States
and is temporarily in the United States as an
employee of, or under contract with, a resident
of Spain 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
that Spanish resident, or
Study at a university or other accredited
educational institution in the United States.
Both the $5,000 and $8,000 exemptions in
clude any amount excluded or exempted from
tax under U.S. tax law.
These exemptions do not apply to income
from research carried on mainly for the private
benefit of any person rather than in the public
interest.
Sri Lanka
A student, apprentice, or business trainee, who
is a resident of Sri Lanka resident immediately
before visiting the United States and is in the
United States for the purpose of fulltime educa
tion or training, is exempt from U.S. income tax
on amounts received from sources outside the
United States for the individual's maintenance,
education, or training.
An individual who is a resident of Sri Lanka
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 Sri Lanka, or as a participant in a program
sponsored by the United States or by any inter
national organization, is exempt from U.S. in
come tax for a period not exceeding 1 year on
up to $6,000 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 Sri Lanka or other than a
person related to that resident, or
Study at a university or other recognized
educational institution.
Sweden
A student, apprentice, or business trainee who
is a resident of Sweden immediately before vis
iting the United States and is in the United
States for the purpose of fulltime education or
training is exempt from U.S. tax on amounts re
ceived from sources outside the United States
for the individual's maintenance, education, and
training.
Switzerland
A student, apprentice, or business trainee who
is a resident of Switzerland immediately before
visiting the United States and is in the United
States for the purpose of fulltime education or
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.
Thailand
An individual who is a resident of Thailand 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 individual
must be in the United States for the primary pur
pose of:
Studying at a university or other recog
nized 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.
Gifts from abroad for the purpose of main
tenance, education, study, research, or
training.
The grant, allowance, or award.
Income from personal services performed
in the United States of up to $3,000 for the
tax year.
An individual who is a resident of Thailand 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 resident of Thailand is exempt from U.S.
income tax for a period of 12 consecutive
months on up to $7,500 received 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
the Thai resident, or
Study at a university or other recognized
educational institution in the United States.
An individual who is a resident of Thailand 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.
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Page 26 Publication 901 (September 2016)
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 primarily to study at a university or other
accredited educational 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, chari
table, scientific, literary, or educational organi
zation 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 $2,000 each
tax year, or, if the individual is obtaining
training required to qualify to practice a
profession or a professional specialty, a
maximum of $5,000 for any tax year.
An individual is entitled to the benefit of this
exemption for a maximum period of 5 tax years.
An individual who is a resident of Trinidad
and Tobago on the date of arrival in the United
States and who is in the United States as an
employee of, or under contract with, a resident
or corporation of Trinidad and Tobago is ex
empt from U.S. income tax for 1 tax year on up
to $5,000 received for personal services if the
individual is in the United States primarily to:
Study at an educational institution, or
Acquire technical, professional, or busi
ness experience from a person other than
that resident or corporation of Trinidad and
Tobago.
Also exempt is a resident of Trinidad and
Tobago who is 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. The individual
is exempt from tax on income from personal
services performed in the United States and re
ceived for the training, research, or study for up
to a maximum of $10,000.
Tunisia
An individual who is a resident of Tunisia imme
diately before visiting the United States and
who is in the United States for fulltime study or
training is exempt from U.S. income tax on the
following amounts.
Payments from abroad for fulltime study
or training.
A grant, allowance, or award from a gov
ernmental, religious, charitable, scientific,
literary, or educational organization to
study or engage in research.
Income from personal services performed
in the United States of up to $4,000 in any
tax year.
The individual is entitled to this exemption
for a maximum of 5 years.
Turkey
A student, apprentice, or business trainee who
is a resident of Turkey immediately before visit
ing the United States and is in the United States
for the purpose of fulltime education or 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.
Ukraine
An individual who is a resident of Ukraine 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, re
search, or training and on any grant, allowance,
or other similar payments. To be entitled to the
exemption, the individual must be temporarily
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
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.
United Kingdom
A student or business apprentice who is a resi
dent of the United Kingdom immediately before
visiting the United States and is in the United
States for the purpose of fulltime education at a
recognized educational institution or fulltime
training is exempt from U.S. income tax on
amounts received from abroad for the individu
al'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.
Venezuela
An individual who is a resident of Venezuela 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.
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 generally entitled to the ben
efit of this exemption for a maximum of 5 years
from the date of arrival in the United States.
This exemption will also apply to any additional
period of time that a fulltime student needs to
complete the educational requirements as a
candidate for a postgraduate or professional
degree from a recognized educational institu
tion.
An individual who is a resident of Venezuela
on the date of arrival in the United States and
who is in the United States as an employee of,
or under contract with, a resident of Venezuela
is exempt from U.S. income tax for a period of
12 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 Venezuela, or
Study at an educational institution.
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.
Wages and Pensions
Paid by a Foreign
Government
Wages, salaries, pensions, and annuities paid
by the governments of the following countries to
their residents who are present in the United
States as nonresident aliens generally are ex
empt from U.S. income tax. The conditions un
der which the income is exempt are stated for
each of the countries listed.
Exemption under U.S. tax law. Employees of
foreign countries who do not qualify under a tax
treaty provision and employees of international
organizations should see if they can qualify for
exemption under U.S. tax law.
If you work for a foreign government in the
United States, your foreign government salary
is exempt from U.S. tax if you perform services
similar to those performed by U.S. government
employees in that foreign country and that for
eign government grants an equivalent exemp
tion. If you work for an international organization
in the United States, your salary from that
source is exempt from U.S. tax. See chapter 10
of Publication 519 for more information.
Australia
Salaries, wages, and similar income, including
pensions, paid by Australia, its political subdivi
sions, agencies, or authorities to its citizens
(other than U.S. citizens) for performing govern
mental functions as an employee of any of the
above entities are exempt from U.S. income
tax.
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Publication 901 (September 2016) Page 27
Austria
Wages, salaries, similar income, and pensions
and annuities paid from public funds of Austria,
its political subdivisions, or its local authorities,
to citizens of Austria for performing governmen
tal functions as an employee are exempt from
U.S. tax.
However, this exemption does not apply to
payments for services performed in connection
with a trade or business carried on by Austria or
its political subdivisions or local authorities.
Bangladesh
Income, other than a pension, paid by Bangla
desh, its political subdivisions, or local authori
ties to an individual for services performed for
the paying governmental body is exempt from
U.S. income tax. However, the exemption does
not apply if the services are performed in the
United States by a resident of the United States
who either:
Is a U.S. citizen, or
Did not become a U.S. resident only to
perform the services.
Pensions paid from the public funds of Ban
gladesh, its political subdivisions, or local au
thorities for services performed for Bangladesh,
its political subdivisions, or local authorities to
an individual for services performed for the pay
ing governmental body are exempt from U.S. in
come tax unless the recipient is both a resident
and citizen of the United States.
This exemption does not apply to income or
pensions for services performed in connection
with a business carried on by Bangladesh, its
political subdivisions, or local authorities.
Barbados
Income, including a pension, paid from the pub
lic funds of Barbados, or its political subdivi
sions or local authorities, to a citizen of Barba
dos for performing governmental functions is
exempt from U.S. income tax.
However, this exemption does not apply to
payments for services in connection with a busi
ness carried on by Barbados or its political sub
divisions or local authorities.
Belgium
Wages, salaries, and similar income, other than
a pension, paid by Belgium, its political subdivi
sions, or local authorities to an individual for
services performed for the paying governmental
body is exempt from U.S. income tax. However,
the exemption does not apply if the services are
performed in the United States by a resident of
the United States who either:
Is a U.S. national, or
Did not become a U.S. resident only to
perform the services.
Pensions paid by, or out of funds created
by, Belgium, its political subdivisions, or local
authorities for services performed for Belgium,
its political subdivisions, or local authorities to
an individual for services performed for the pay
ing governmental body are exempt from U.S. in
come tax unless the recipient is both a resident
and national of the United States.
However, these exemptions do not apply to
payments for services performed in connection
with a business carried on by Belgium, its politi
cal subdivisions, or local authorities.
Bulgaria
Wages, salaries, and similar income, other than
a pension, paid by Bulgaria, its political subdivi
sions, or local authorities to an individual for
services performed for the paying governmental
body are exempt from U.S. income tax. How
ever, the exemption does not apply if the serv
ices are performed in the United States by a
resident of the United States who either:
Is a U.S. national, or
Did not become a U.S. resident only to
perform the services.
Pensions paid by, or out of funds created
by, Bulgaria, its political subdivisions, or local
authorities for services performed for Bulgaria,
its political subdivisions, or local authorities to
an individual for services performed for the pay
ing governmental body are exempt from U.S. in
come tax unless the recipient is both a resident
and national of the United States.
However, these exemptions do not apply to
payments for services performed in connection
with a business carried on by Bulgaria, its politi
cal subdivisions, or local authorities.
Canada
Wages, salaries, and similar income (other than
pensions) paid by Canada or by a Canadian po
litical subdivision or local authority to a citizen of
Canada for performing governmental functions
are exempt from U.S. income tax. This exemp
tion does not apply, however, to payments for
services performed in connection with a trade
or business carried on by Canada or its political
subdivisions or local authorities.
Also see Publication 597, Information on the
United States–Canada Income Tax Treaty.
China, People's Republic of
Income, other than a pension, paid by the Peo
ple's Republic of China or its political subdivi
sions or local authorities to an individual for
services performed for the paying governmental
body is exempt from U.S. income tax. However,
the exemption does not apply to payments for
services performed in the United States by a
resident of the United States who either:
Is a U.S. citizen, or
Did not become a U.S. resident only to
perform the services.
Pensions paid by the People's Republic of
China for services performed for China are ex
empt from U.S. income tax unless the recipient
is both a citizen and a resident of the United
States.
These exemptions do not apply to income or
pensions for services performed in connection
with a business carried on by the People's Re
public of China or its subdivisions or local au
thorities.
Commonwealth of
Independent States (C.I.S.)
Wages, salaries, and similar income paid by the
C.I.S. or a member of the C.I.S. to its citizens
for personal services performed as an em
ployee of a governmental agency or institution
of the C.I.S. or a member of the C.I.S. (exclud
ing local government employees) in the dis
charge of governmental functions are exempt
from U.S. income tax. For this purpose, persons
engaged in commercial activities are not con
sidered engaged in the discharge of govern
mental functions.
Cyprus
Wages, salaries, and similar income, including
pensions, annuities, and similar benefits, paid
from public funds of Cyprus to a citizen of Cy
prus for labor or personal services performed
as an employee of Cyprus in the discharge of
governmental functions are exempt from U.S.
income tax.
Czech Republic
Income, including a pension, paid from the pub
lic funds of the Czech Republic, its political sub
divisions, or local authorities to a Czech citizen
for services performed in the discharge of gov
ernmental functions is exempt from U.S. in
come tax. This exemption does not apply to in
come paid for services performed in connection
with a business carried on by the Czech Repub
lic, its political subdivisions, or local authorities.
Denmark
Income, other than a pension, paid from public
funds of Denmark, its political subdivisions, or
local authorities to an individual for services
performed for the paying governmental body in
the discharge of governmental functions is ex
empt from U.S. income tax. However, the ex
emption does not apply if the services are per
formed in the United States by a resident of the
United States who either:
Is a U.S. national, or
Did not become a U.S. resident only to
perform the services.
Pensions paid from the public funds of Den
mark, its political subdivisions, or local authori
ties for services performed for Denmark are ex
empt from U.S. income tax unless the recipient
is a resident and a national of the United States.
These exemptions do not apply to income or
pensions for services performed in connection
with a trade or business carried on by Denmark,
its political subdivisions, or local authorities.
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Page 28 Publication 901 (September 2016)
Egypt
Wages, salaries, and similar income, including
pensions, annuities, and similar benefits, paid
from public funds of the Arab Republic of Egypt
to a citizen of Egypt (or to a citizen of another
country who comes to the United States specifi
cally to work for the Government of Egypt) for
labor or personal services performed as an em
ployee of the national Government of Egypt, or
any of its agencies, in the discharge of govern
mental functions are exempt from U.S. income
tax.
This exemption does not apply to U.S. citi
zens or to alien residents of the United States.
The exemption also does not apply to payments
for services performed in connection with a
trade or business carried on by Egypt or any of
its agencies.
Estonia
Income, other than a pension, paid by or from
public funds of Estonia, its political subdivi
sions, or local authorities to an individual for
services performed as an employee for the pay
ing governmental body in the discharge of gov
ernmental functions is exempt from U.S. in
come tax. However, the exemption does not
apply if the services are performed in the United
States by a resident of the United States who
either:
Is a U.S. citizen, or
Did not become a U.S. resident only to
perform the services.
Pensions paid by or from the public funds of
Estonia, its political subdivisions, or local au
thorities for services performed for Estonia are
exempt from U.S. income tax unless the recipi
ent is both a resident and citizen of the United
States.
Finland
Income, other than a pension, paid by Finland,
its political subdivisions, statutory bodies, or lo
cal authorities to an individual for services per
formed for the paying governmental body is ex
empt from U.S. income tax. However, the
exemption does not apply to payments for serv
ices performed in the United States by a U.S.
resident who either:
Is a U.S. citizen, or
Did not become a U.S. resident only to
perform the services.
Pensions paid by Finland for services per
formed for Finland are exempt from U.S. in
come tax unless the recipient is a resident and
citizen of the United States.
These exemptions do not apply to income or
pensions for services performed in connection
with a trade or business carried on by Finland or
its political subdivisions, statutory bodies, or lo
cal authorities.
France
Income, other than a pension, paid by the
French Government or a local authority thereof
to an individual in the United States for services
performed for France (or for a local authority of
France) in the discharge of governmental func
tions is exempt from U.S. tax. This exemption
does not apply to a person who is both a resi
dent and citizen of the United States or a green
card holder.
This exemption does not apply to any in
come paid because of services (or past serv
ices) performed in connection with a business
carried on by the French Government (or a local
authority thereof).
Germany
Wages, salaries, and similar income, other than
a pension, paid by Germany, its political subdi
visions, local authorities, or instrumentalities to
an individual for services performed for the pay
ing governmental body is exempt from U.S. in
come tax. However, the exemption does not
apply if the services are performed in the United
States by a resident of the United States who
either:
Is a U.S. national, or
Did not become a U.S. resident only to
perform the services.
Pensions paid by, or out of funds created
by, Germany, its political subdivisions, local au
thorities, or instrumentalities for services per
formed for the paying governmental body are
exempt from U.S. income tax unless the recipi
ent is both a resident and a national of the Uni
ted States.
This exemption does not apply to income or
pensions for services performed in connection
with a business carried on by Germany, its polit
ical subdivisions, local authorities, or instrumen
talities.
Greece
Wages, salaries, and similar income and pen
sions paid by Greece or its subdivisions to indi
viduals living in the United States for services
rendered to Greece or its subdivisions are ex
empt from U.S. income tax. This exemption
does not apply to citizens of the United States
or alien residents of the United States.
Hungary
Income (other than a pension) paid by the Re
public of Hungary or its political subdivisions for
labor or personal services performed for the
paying governmental body is exempt from U.S.
tax. However, the exemption does not apply to
payments for services performed in the United
States by a resident of the United States who
either:
Is a U.S. citizen, or
Did not become a resident of the United
States only to perform the services.
Pensions paid by Hungary for services per
formed for Hungary are exempt from U.S. in
come tax unless the recipient is both a citizen
and a resident of the United States.
These exemptions do not apply to income or
pensions for services performed in connection
with a trade or business carried on by Hungary
or its subdivisions.
Iceland
Wages, salaries, and similar income, other than
a pension, paid by Iceland, its political subdivi
sions, or local authorities to an individual for
services performed for the paying governmental
body are exempt from U.S. income tax. How
ever, the exemption does not apply if the serv
ices are performed in the United States by a
resident of the United States who either:
Is a U.S. national, or
Did not become a U.S. resident only to
perform the services.
Pensions paid by, or out of funds created
by, Iceland, its political subdivisions, or local au
thorities for services performed for Iceland, its
political subdivisions, or local authorities to an
individual for services performed for the paying
governmental body are exempt from U.S. in
come tax unless the recipient is both a resident
and national of the United States.
However, these exemptions do not apply to
payments for services performed in connection
with a business carried on by Iceland, its politi
cal subdivisions, or local authorities.
India
Income, other than a pension, paid by India, its
political subdivisions, or local authorities to an
individual for services performed for the paying
governmental body is exempt from U.S. income
tax. However, the exemption does not apply if
the services are performed in the United States
by a U.S. resident who either:
Is a U.S. citizen, or
Did not become a U.S. resident only to
perform the services.
Pensions paid by India for services per
formed for India are exempt from U.S. tax un
less the individual is both a resident and citizen
of the United States.
These exemptions do not apply to income or
pensions for services performed in connection
with a business carried on by India, its subdivi
sions, or local authorities.
Indonesia
Income, other than a pension, paid by Indone
sia, its political subdivisions, or local authorities
to an individual for services performed for the
paying governmental body is exempt from U.S.
income tax. However, the exemption does not
apply if the services are performed in the United
States by a U.S. resident who either:
Is a U.S. citizen, or
Did not become a U.S. resident only to
perform the services.
Pensions paid by Indonesia for services per
formed for Indonesia are exempt from U.S. tax.
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Publication 901 (September 2016) Page 29
These exemptions do not apply to income or
pensions for services performed in connection
with a trade or business carried on by Indone
sia, its subdivisions, or local authorities.
Ireland
Income, other than a pension, paid by Ireland or
its political subdivisions or local authorities to an
individual for services performed for the paying
governmental body is exempt from U.S. income
tax. However, the exemption does not apply to
payments for services performed in the United
States by a resident of the United States who
either:
Is a U.S. citizen, or
Did not become a U.S. resident only to
perform the services.
Pensions paid by Ireland for services per
formed for Ireland are exempt from U.S. income
tax unless the recipient is both a resident and
citizen of the United States.
These exemptions do not apply to income or
pensions for services performed in connection
with a business carried on by Ireland or its sub
divisions or local authorities.
Israel
Wages, salaries, and similar income, including
pensions and similar benefits, paid from public
funds by the national government of Israel or its
agencies, for services performed in the dis
charge of governmental functions, are exempt
from U.S. income tax. This exemption does not
apply to citizens of the United States or alien
residents of the United States.
Italy
Income, other than a pension, paid by Italy or by
an Italian political or administrative subdivision
or local authority to an individual for services
performed for the paying governmental body is
exempt from U.S. income tax. However, the ex
emption does not apply to payments for serv
ices performed in the United States by a resi
dent of the United States who either:
Is a U.S. national and not a national of
Italy, or
Did not become a U.S. resident only to
perform the services.
The spouse and dependent children of an indi
vidual, however, are not subject to the second
restriction if that individual is receiving exempt
income for governmental services performed
for Italy and that individual does not come under
either of the restrictions.
Pensions paid by Italy for services per
formed for Italy are exempt from U.S. income
tax unless the recipient is both a citizen and a
resident of the United States.
These exemptions do not apply to income or
pensions for services performed in connection
with a trade or business carried on by Italy or its
subdivisions or local authorities.
Jamaica
Income, other than a pension, paid by the Gov
ernment of Jamaica or its political subdivisions
or local authorities for personal services per
formed for the paying governmental body is ex
empt from U.S. income tax.
This exemption does not apply to payments
for services performed in the United States by
an individual who is a citizen and resident of the
United States.
Pensions paid by Jamaica for services per
formed for Jamaica generally are exempt from
U.S. income tax. However, if the recipient of the
pension is a citizen and resident of the United
States and was a U.S. citizen at the time the
services were performed, the pension is taxable
in the United States.
These exemptions do not apply to income or
pensions for services performed in connection
with a trade or business carried on by Jamaica
or its subdivisions or local authorities.
Japan
Income, other than a pension, paid by Japan, its
political subdivisions, or local authorities to an
individual for services performed for the paying
governmental body is exempt from U.S. income
tax. However, the exemption does not apply if
the services are performed in the United States
by a resident of the United States who either:
Is a U.S. citizen, or
Did not become a U.S. resident only to
perform the services.
Pensions paid by, or out of funds to which
contributions are made by, Japan, its political
subdivisions, or local authorities for services
performed for Japan are exempt from U.S. in
come tax unless the recipient is a resident and
citizen of the United States.
These exemptions do not apply to income or
pensions for services performed in connection
with a business carried on by Japan, its political
subdivisions, or local authorities.
Kazakhstan
Income, other than a pension, paid by Kazakh
stan, or its subdivisions or local authorities to an
individual for government services is exempt
from U.S. tax. However, the exemption does
not apply if the services are performed in the
United States by a U.S. resident who either:
Is a U.S. citizen, or
Did not become a U.S. resident solely for
the purpose of performing the services.
These exemptions do not apply to income for
services performed in connection with a busi
ness.
Pensions paid by Kazakhstan, or its subdivi
sions or local authorities for services performed
for Kazakhstan is exempt from U.S. tax unless
the individual is both a resident and citizen of
the United States.
Korea, South
Wages, salaries, and similar income, including
pensions and similar benefits, paid from public
funds of South Korea to a citizen of Korea
(other than a U.S. citizen or an individual admit
ted to the United States for permanent resi
dence) for services performed as an employee
of Korea discharging government functions are
exempt from U.S. income tax.
Latvia
Income, other than a pension, paid by or from
public funds of Latvia, its political subdivisions,
or local authorities to an individual for services
performed as an employee for the paying gov
ernmental body in the discharge of governmen
tal functions is exempt from U.S. income tax.
However, the exemption does not apply if the
services are performed in the United States by
a resident of the United States who either:
Is a U.S. citizen, or
Did not become a U.S. resident only to
perform the services.
Pensions paid by or from the public funds of
Latvia, its political subdivisions, or local authori
ties for services performed for Latvia are ex
empt from U.S. income tax unless the recipient
is both a resident and citizen of the United
States.
Lithuania
Income, other than a pension, paid by or from
public funds of Lithuania, its political subdivi
sions, or local authorities to an individual for
services performed as an employee for the pay
ing governmental body in the discharge of gov
ernmental functions is exempt from U.S. in
come tax. However, the exemption does not
apply if the services are performed in the United
States by a resident of the United States who
either:
Is a U.S. citizen, or
Did not become a U.S. resident only to
perform the services.
Pensions paid by or from the public funds of
Lithuania, its political subdivisions, or local au
thorities for services performed for Lithuania are
exempt from U.S. income tax unless the recipi
ent is both a resident and citizen of the United
States.
Luxembourg
Income, other than a pension, paid by Luxem
bourg, its political subdivisions, or local authori
ties to an individual for services performed for
the paying governmental body is exempt from
U.S. income tax. However, the exemption does
not apply if the services are performed in the
United States by a resident of the United States
who either:
Is a U.S. citizen, or
Did not become a U.S. resident only to
perform the services.
Pensions paid by Luxembourg, its political
subdivisions, or local authorities for services
performed for Luxembourg are exempt from
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Page 30 Publication 901 (September 2016)
U.S. income tax unless the recipient is both a
resident and citizen of the United States.
These exemptions do not apply to income or
pensions for services performed in connection
with a trade or business carried on by Luxem
bourg, its political subdivisions, or local authori
ties.
Malta
Income, other than a pension, paid by Malta, its
political subdivisions, or local authorities to an
individual for services performed for the paying
governmental body is exempt from U.S. income
tax. However, the exemption does not apply if
the services are performed in the United States
by a U.S. resident who either:
Is a U.S. national, or
Did not become a resident of the United
States solely for purposes of performing
the services.
Pensions paid by Malta, its political subdivi
sions, or local authorities for services performed
for the paying governmental body are exempt
from U.S. income tax unless the individual is
both a resident and national of the United
States.
These exemptions do not apply to income or
pensions for services performed in connection
with a business carried on by Malta, its political
subdivisions, or local authorities.
Mexico
Income, other than a pension, paid by Mexico,
its political subdivisions, or local authorities to
an individual for services performed for the pay
ing governmental body is exempt from U.S. in
come tax. However, the exemption does not
apply if the services are performed in the United
States by a U.S. resident who either:
Is a U.S. national, or
Did not become a resident of the United
States solely for purposes of performing
the services.
Pensions paid by Mexico, its political subdi
visions, or local authorities for services per
formed for the paying governmental body are
exempt from U.S. income tax unless the individ
ual is both a resident and national of the United
States.
These exemptions do not apply to income or
pensions connected with commercial or indus
trial activities carried on by Mexico, its political
subdivisions, or local authorities.
Morocco
Wages, salaries, and similar income, including
pensions and similar benefits, paid from public
funds of the Kingdom of Morocco to a citizen of
Morocco (other than a U.S. citizen or an individ
ual admitted to the United States for permanent
residence) for labor or personal services per
formed for Morocco or for any of its political
subdivisions or local authorities in the discharge
of governmental functions are exempt from U.S.
income tax.
Netherlands
Income, other than a pension, paid by the Neth
erlands, its political subdivisions, or local au
thorities to an individual for services performed
for the paying governmental body is exempt
from U.S. income tax. However, the exemption
does not apply if the services are rendered in
the United States and the individual is a U.S.
resident who either:
Is a U.S. national, or
Did not become a U.S. resident solely for
the purpose of performing the services.
Pensions paid by the Netherlands for serv
ices performed for the Netherlands are exempt
from U.S. income tax unless the individual is
both a resident and national of the United
States.
These exemptions do not apply to income or
pensions for services performed in connection
with a business carried on by the Netherlands,
its political subdivisions, or local authorities.
New Zealand
Income (other than pensions) paid by the Gov
ernment of New Zealand, its political subdivi
sions, or local authorities for services performed
in the discharge of governmental functions is
exempt from U.S. income tax. However, the in
come is not exempt if the services are per
formed in the United States by a U.S. citizen
resident in the United States or by a resident of
the United States who did not become a resi
dent only to perform the services.
Pensions paid by New Zealand in consider
ation for past governmental services are ex
empt from U.S. income tax unless paid to U.S.
citizens resident in the United States.
These exemptions do not apply to payments
for services performed in connection with a
business carried on by New Zealand, its politi
cal subdivisions, or local authorities.
Norway
Wages, salaries, and similar income, including
pensions and similar benefits paid by or from
public funds of Norway or its political subdivi
sions or local authorities to a citizen of Norway
for labor or personal services performed for
Norway or any of its political subdivisions or lo
cal authorities in the discharge of governmental
functions are exempt from U.S. income tax.
Pakistan
Income, including pensions and annuities, paid
to certain individuals by or on behalf of the Gov
ernment of Pakistan or the Government of a
Province in Pakistan or one of its local authori
ties for services performed in the discharge of
functions of that Government or local authority
is exempt from U.S. income tax. To be exempt
from tax, these payments must be made to citi
zens of Pakistan who do not have immigrant
status in the United States. This exemption
does not apply to payments for services per
formed in connection with any trade or business
carried on for profit.
Philippines
Wages, salaries, and similar income, including
pensions, annuities, and similar benefits, paid
from public funds of the Republic of the Philip
pines to a citizen of the Philippines (or to a citi
zen of another country other than the United
States who comes to the United States specifi
cally to work for the Government of the Philip
pines) for labor or personal services performed
as an employee of the national Government of
the Philippines or any of its agencies in the dis
charge of governmental functions are exempt
from U.S. income tax.
Poland
Wages, salaries, and similar income, including
pensions, annuities, and similar benefits, paid
from public funds of Poland to a citizen of Po
land (other than a U.S. citizen or one admitted
to the United States for permanent residence)
for labor or personal services performed as an
employee of the national Government of Poland
in the discharge of governmental functions are
exempt from U.S. income tax.
Portugal
Income, other than a pension, paid by Portugal,
its political or administrative subdivisions, or lo
cal authorities to an individual for services per
formed for the paying governmental body is ex
empt from U.S. income tax. However, the
exemption does not apply to payments for serv
ices performed in the United States by a U.S.
resident who either:
Is a U.S. national, or
Did not become a U.S. resident only to
perform the services.
Pensions paid by Portugal for services per
formed for Portugal are exempt from U.S. in
come tax unless the recipient is a resident and
national of the United States.
These exemptions do not apply to income or
pensions for services performed in connection
with a business carried on by Portugal or its po
litical or administrative subdivisions, or local au
thorities.
Romania
Wages, salaries, and similar income, including
pensions, annuities, and similar benefits, paid
from public funds of Romania to a citizen of Ro
mania (other than a U.S. citizen or one admitted
to the United States for permanent residence)
for labor or personal services performed as an
employee of the national Government of Roma
nia in the discharge of governmental functions
are exempt from U.S. income tax.
Russia
Income, other than a pension, paid by Russia,
its republics, or local authorities to an individual
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Publication 901 (September 2016) Page 31
for government services is exempt from U.S.
tax. However, the exemption does not apply if
the services are performed in the United States
by a U.S. resident who either:
Is a U.S. citizen, or
Did not become a U.S. resident solely for
the purpose of performing the services.
Pensions paid by Russia, its republics, or lo
cal authorities for services performed for Russia
are exempt from U.S. tax unless the individual
is both a resident and citizen of the United
States.
These exemptions do not apply to income or
pensions for services performed in connection
with a business.
Slovak Republic
Income, including a pension, paid from the pub
lic funds of the Slovak Republic, its political
subdivisions, or local authorities to a Slovak citi
zen for services performed in the discharge of
governmental functions is exempt from U.S. in
come tax. This exemption does not apply to in
come paid for services performed in connection
with a business carried on by the Slovak Re
public, its political subdivisions, or local authori
ties.
Slovenia
Income, other than a pension, paid from public
funds of Slovenia, its political subdivisions, or
local authorities to an individual for services
performed for the paying governmental body in
the discharge of governmental functions is ex
empt from U.S. income tax. However, the ex
emption does not apply if the services are per
formed in the United States by a resident of the
United States who either:
Is a U.S. citizen, or
Did not become a U.S. resident only to
perform the services.
Pensions paid from the public funds of Slov
enia, its political subdivisions, or local authori
ties for services performed for Slovenia in the
discharge of governmental functions are ex
empt from U.S. income tax unless the recipient
is both a resident and citizen of the United
States.
South Africa
Income, other than a pension, paid by South Af
rica or its political subdivisions or local authori
ties to an individual for services performed for
the paying governmental body is exempt from
U.S. income tax. However, the exemption does
not apply to payments for services performed in
the United States by a resident of the United
States who either:
Is a U.S. citizen, or
Did not become a U.S. resident only to
perform the services.
Pensions paid by South Africa for services
performed for South Africa are exempt from
U.S. income tax unless the recipient is both a
resident and citizen of the United States.
These exemptions do not apply to income or
pensions for services performed in connection
with a business carried on by South Africa or its
subdivisions or local authorities.
Spain
Income, other than a pension, paid by Spain, its
political subdivisions, or local authorities to an
individual for services performed for the paying
governmental body is exempt from U.S. income
tax. However, the exemption does not apply to
payments for services performed in the United
States by a resident of the United States who
either:
Is a U.S. citizen, or
Did not become a U.S. resident only to
perform the services.
Pensions paid by Spain, its political subdivi
sions, or local authorities for services performed
for Spain are exempt from U.S. tax unless the
individual is both a citizen and resident of the
United States.
These exemptions do not apply to income or
pensions for services performed in connection
with a trade or business carried on by Spain, its
subdivisions, or local authorities.
Sri Lanka
Income, including a pension, paid from the pub
lic funds of Sri Lanka, its political subdivisions,
or local authorities to a citizen or national of Sri
Lanka for services performed for Sri Lanka in
the discharge of functions of a governmental
nature is exempt from U.S. income tax. This ex
emption does not apply to income paid for serv
ices performed in connection with a business
carried on by Sri Lanka, its political subdivi
sions, or local authorities.
Sweden
Income, other than a pension, paid by Sweden,
its political subdivisions, or local authorities to
an individual for services performed for the pay
ing governmental body is exempt from U.S. in
come tax. However, the exemption does not
apply if the services are performed in the United
States by a U.S. resident who either:
Is a U.S. citizen, or
Did not become a U.S. resident solely for
the purpose of performing the services.
Pensions paid by Sweden, its political subdi
visions, or local authorities for services per
formed for Sweden are exempt from U.S. tax
unless the individual is both a resident and citi
zen of the United States.
These exemptions do not apply to income or
pensions for services performed in connection
with a business carried on by Sweden, its politi
cal subdivisions, or local authorities.
Switzerland
Income, other than a pension, paid by Switzer
land or its political subdivisions or local authori
ties to an individual for services performed for
the paying governmental body is exempt from
U.S. income tax. However, the exemption does
not apply to payments for services performed in
the United States by a resident of the United
States who either:
Is a U.S. citizen, or
Did not become a U.S. resident only to
perform the services.
Pensions paid by Switzerland for services
performed for Switzerland are exempt from U.S.
income tax unless the recipient is both a resi
dent and citizen of the United States.
These exemptions do not apply to income or
pensions for services performed in connection
with a business carried on by Switzerland or its
subdivisions or local authorities.
Thailand
Income, other than a pension, paid by Thailand
or its political subdivisions or local authorities to
an individual for services performed for the pay
ing governmental body is exempt from U.S. in
come tax. However, the exemption does not
apply to payments for services performed in the
United States by a resident of the United States
who either:
Is a U.S. citizen, or
Did not become a U.S. resident only to
perform the services.
Pensions paid by Thailand for services per
formed for Thailand are exempt from U.S. in
come tax unless the recipient is both a resident
and citizen of the United States.
These exemptions do not apply to income or
pensions for services performed in connection
with a business carried on by Thailand or its
subdivisions or local authorities.
Trinidad and Tobago
Wages, salaries, and similar income and pen
sions, annuities, and similar benefits paid by or
from the public funds of the Government of Tri
nidad and Tobago to a national of that country
for services performed for Trinidad and Tobago
in the discharge of governmental functions are
exempt from U.S. tax.
Tunisia
Income, other than a pension, paid by Tunisia,
its political subdivisions, or local authorities to a
Tunisian citizen for personal services per
formed in the discharge of governmental func
tions is exempt from U.S. income tax.
Pensions paid by Tunisia, its political subdi
visions, or local authorities for services per
formed for Tunisia are exempt from U.S. in
come tax unless the recipient is a U.S. citizen.
These exemptions do not apply to income or
pensions for services performed in connection
with a trade or business carried on by Tunisia,
its political subdivisions, or local authorities.
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Page 32 Publication 901 (September 2016)
Turkey
Income, other than a pension, paid by Turkey or
its political subdivisions or local authorities to an
individual for services performed for the paying
governmental body is exempt from U.S. income
tax. However, the exemption does not apply to
payments for services performed in the United
States by a resident of the United States who
either:
Is a U.S. citizen, or
Did not become a U.S. resident only to
perform the services.
Pensions paid by Turkey for services per
formed for Turkey are exempt from U.S. income
tax unless the recipient is both a resident and
citizen of the United States.
These exemptions do not apply to income or
pensions for services performed in connection
with a business carried on by Turkey or its sub
divisions or local authorities.
Ukraine
Income, other than a pension, paid from public
funds of Ukraine, its political subdivisions, or lo
cal authorities to an individual for services per
formed in the discharge of governmental func
tions is exempt from U.S. income tax. However,
the exemption does not apply if the services are
performed in the United States by a resident of
the United States who either:
Is a U.S. citizen, or
Did not become a U.S. resident only to
perform the services.
Pensions paid by, or by funds created by,
Ukraine, its political subdivisions, or local au
thorities for services performed for Ukraine are
exempt from U.S. income tax unless the recipi
ent is both a resident and citizen of the United
States.
These exemptions do not apply to income or
pensions for services performed in connection
with a trade or business carried on by Ukraine,
its political subdivisions, or local authorities.
United Kingdom
Income, other than a pension, paid from the
public funds of the United Kingdom, its political
subdivisions, or local authorities to an individual
for services performed for the paying govern
mental body is exempt from U.S. income tax.
However, the exemption does not apply if the
services are performed in the United States by
a resident of the United States who either:
Is a U.S. citizen, or
Did not become a U.S. resident only to
perform the services.
Pensions paid by, or funds created by, the
United Kingdom, its political subdivisions, or lo
cal authorities for services performed for the
United Kingdom are exempt from U.S. income
tax unless the recipient is both a resident and
citizen of the United States.
These exemptions do not apply to income or
pensions for services performed in connection
with a business carried on by the United King
dom, its political subdivisions, or local authori
ties.
Venezuela
Income, other than a pension, paid by Vene
zuela, its political subdivisions, or local authori
ties to an individual for services performed for
the paying governmental body is exempt from
U.S. income tax. However, the exemption does
not apply to payments for services performed in
the United States by a resident of the United
States who either:
Is a U.S. citizen, or
Did not become a U.S. resident only to
perform the services.
Pensions paid by Venezuela, its political
subdivisions, or local authorities for services
performed for Venezuela are exempt from U.S.
income tax unless the recipient is both a resi
dent and citizen of the United States.
These exemptions do not apply to payments
or pensions for services performed in connec
tion with a business carried on by Venezuela,
its political subdivisions, or local authorities.
How To Get Tax Help
You can get help with unresolved tax issues, or
der free publications and forms, ask tax ques
tions, and get information from the IRS in sev
eral ways. By selecting the method that is best
for you, you will have quick and easy access to
tax help.
Taxpayer Assistance
Inside the United States
Preparing and filing your tax return. Find
free options to prepare and file your return on
IRS.gov or in your local community if you qual
ify.
Go to IRS.gov and click on the Filing tab to
see your options.
Enter “Free File” in the search box to see
whether you can use brandname software
to prepare and e-file your federal tax return
for free.
Enter “VITA” in the search box, download
the free IRS2Go app, or call
18009069887 to find the nearest Volun
teer Income Tax Assistance or Tax Coun
seling for the Elderly (TCE) location for free
tax preparation.
Enter “TCE” in the search box, download
the free IRS2Go app, or call
18882277669 to find the nearest Tax
Counseling for the Elderly location for free
tax preparation.
The Volunteer Income Tax Assistance
(VITA) program offers free tax help to people
who generally make $54,000 or less, persons
with disabilities, the elderly, and limitedEng
lishspeaking taxpayers who need help prepar
ing their own tax returns. The Tax Counseling
for the Elderly (TCE) program offers free tax
help for all taxpayers, particularly those who are
60 years of age and older. TCE volunteers spe
cialize in answering questions about pensions
and retirementrelated issues unique to seniors.
Getting answers to your tax law
questions. On IRS.gov get answers to
your tax questions anytime, anywhere.
Go to www.irs.gov/Help- &-Resources for a
variety of tools that will help you with your
taxes.
Enter “ITA” in the search box on IRS.gov
for the Interactive Tax Assistant, a tool that
will ask you questions on a number of tax
law topics and provide answers. You can
print the entire interview and the final re
sponse.
Enter “Pub 17” in the search box on
IRS.gov to get Pub. 17, Your Federal In
come Tax for Individuals, which features
details on taxsaving opportunities, 2015
tax changes, and thousands of interactive
links to help you find answers to your ques
tions.
Additionally, you may be able to access
tax law information in your electronic filing
software.
Tax forms and publications. You can down
load or print all of the forms and publications
you may need on www.irs.gov/formspubs. Oth
erwise, you can go to www.irs.gov/orderforms
to place an order and have forms mailed to you.
You should receive your order within 10 busi
ness days.
Direct deposit. The fastest way to receive a
tax refund is by combining direct deposit and
IRS e-file. Direct deposit securely and electroni
cally transfers your refund directly into your fi
nancial account. Eight in 10 taxpayers use di
rect deposit to receive their refund. The majority
of refunds are received within 21 days or less.
Getting a transcript or copy of a return.
Go to IRS.gov and click on “Get Transcript
of Your Tax Records” under “Tools.”
Call the transcript tollfree line at
18009089946.
Mail Form 4506T or Form 4506TEZ (both
available on IRS.gov).
Using online tools to help prepare your re-
turn. Go to IRS.gov and click on the Tools bar
to use these and other selfservice options.
The Earned Income Tax Credit Assistant
determines if you are eligible for the EIC.
The Online EIN Application helps you get
an employer identification number.
The IRS Withholding Calculator estimates
the amount you should have withheld from
your paycheck for federal income tax pur
poses.
The Electronic Filing PIN Request helps to
verify your identity when you do not have
your prior year AGI or prior year selfselec
ted PIN available.
The First Time Homebuyer Credit Account
Look-up tool provides information on your
repayments and account balance.
For help with the alternative minimum tax,
go to IRS.gov/AMT.
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Publication 901 (September 2016) Page 33
Understanding identity theft issues.
Go to www.irs.gov/uac/Identity-Protection
for information and videos.
If your SSN has been lost or stolen or you
suspect you are a victim of taxrelated
identity theft, visit www.irs.gov/identitytheft
to learn what steps you should take.
Checking on the status of a refund.
Go to www.irs.gov/refunds.
Download the free IRS2Go app to your
smart phone and use it to check your re
fund status.
Call the automated refund hotline at
18008291954.
Making a tax payment. The IRS uses the lat
est encryption technology so electronic pay
ments are safe and secure. You can make elec
tronic payments online, by phone, or from a
mobile device. Paying electronically is quick,
easy, and faster than mailing in a check or
money order. Go to www.irs.gov/payments to
make a payment using any of the following op
tions.
IRS Direct Pay (for individual taxpayers
who have a checking or savings account).
Debit or credit card (approved payment
processors online or by phone).
Electronic Funds Withdrawal (available
during e-file).
Electronic Federal Tax Payment Sys-
tem (best option for businesses; enroll
ment required).
Check or money order.
IRS2Go provides access to mobilefriendly
payment options like IRS Direct Pay, offer
ing you a free, secure way to pay directly
from your bank account. You can also
make debit or credit card payments
through an approved payment processor.
Simply download IRS2Go from Google
Play, the Apple App Store, or the Amazon
Appstore, and make your payments any
time, anywhere.
What if I can’t pay now? Click on the “Pay
Your Tax Bill” icon on IRS.gov for more informa
tion about these additional options.
Apply for an online payment agreement to
meet your tax obligation in monthly install
ments if you cannot pay your taxes in full
today. Once you complete the online proc
ess, you will receive immediate notification
of whether your agreement has been ap
proved.
An offer in compromise allows you to settle
your tax debt for less than the full amount
you owe. Use the Offer in Compromise
Pre-Qualifier to confirm your eligibility.
Checking the status of an amended return.
Go to IRS.gov and click on the Tools tab and
then Where’s My Amended Return?
Understanding an IRS notice or letter. Enter
“Understanding your notice” in the search box
on IRS.gov to find additional information about
your IRS notice or letter.
Visiting the IRS. Locate the nearest Taxpayer
Assistance Center using the Office Locator tool
on IRS.gov. Enter “office locator” in the search
box. Or choose the “Contact Us” option on the
IRS2Go app and search Local Offices. Before
you visit, use the Locator tool to check hours
and services available.
Watching IRS videos. The IRS Video portal
www.irsvideos.gov contains video and audio
presentations for individuals, small businesses,
and tax professionals. You’ll find video clips of
tax topics, archived versions of panel discus
sions and Webinars, and audio archives of tax
practitioner phone forums.
Getting tax information in other languages.
For taxpayers whose native language is not
English, we have the following resources availa
ble.
1. Taxpayers can find information on IRS.gov
in the following languages.
a. Spanish.
b. Chinese.
c. Vietnamese.
d. Korean.
e. Russian.
2. The IRS Taxpayer Assistance Centers
provide overthephone interpreter service
in over 170 languages, and the service is
available free to taxpayers.
The Taxpayer Advocate
Service Is Here To Help You
What is the Taxpayer Advocate
Service?
The Taxpayer Advocate Service (TAS) is an in
dependent organization within the Internal
Revenue Service that helps taxpayers and pro
tects taxpayer rights. Our job is to ensure that
every taxpayer is treated fairly and that you
know and understand your rights under the
Taxpayer Bill of Rights.
What Can the Taxpayer Advocate
Service Do For You?
We can help you resolve problems that you
can’t resolve with the IRS. And our service is
free. If you qualify for our assistance, you will be
assigned to one advocate who will work with
you throughout the process and will do every
thing possible to resolve your issue. TAS can
help you if:
Your problem is causing financial difficulty
for you, your family, or your business,
You face (or your business is facing) an
immediate threat of adverse action, or
You’ve tried repeatedly to contact the IRS
but no one has responded, or the IRS
hasn’t responded by the date promised.
How Can You Reach Us?
We have offices in every state, the District of
Columbia, and Puerto Rico. Your local advo
cate’s number is in your local directory and at
www.taxpayeradvocate.irs.gov. You can also
call us at 18777774778.
How Can You Learn About Your
Taxpayer Rights?
The Taxpayer Bill of Rights describes ten basic
rights that all taxpayers have when dealing with
the IRS. Our Tax Toolkit at
www.taxpayeradvocate.irs.gov can help you
understand what these rights mean to you and
how they apply. These are your rights. Know
them. Use them.
How Else Does the Taxpayer
Advocate Service Help Taxpayers?
TAS works to resolve largescale problems that
affect many taxpayers. If you know of one of
these broad issues, please report it to us at
www.irs.gov/sams.
Low Income Taxpayer
Clinics
Low Income Taxpayer Clinics (LITCs) serve in
dividuals whose income is below a certain level
and need to resolve tax problems such as au
dits, appeals, and tax collection disputes. Some
clinics can provide information about taxpayer
rights and responsibilities in different languages
for individuals who speak English as a second
language. To find a clinic near you, visit
www.irs.gov/litc or see IRS Publication 4134,
Low Income Taxpayer Clinic List.
Taxpayer Assistance
Outside the United
States
If you are outside the United States,
you can call 2679411000 (Eng
lishspeaking only). This number is not
toll free.
If you wish to write instead of calling,
please address your letter to:
Internal Revenue Service
International Accounts
Philadelphia, PA 192550725
U.S.A.
Additional contact information for taxpayers
who live outside the U.S. is available at
www.irs.gov/uac/Contact-My-Local-Office-
Internationally.
Taxpayer Advocate International. You can
call the Taxpayer Advocate tollfree at
18777774778. For more information on the
Taxpayer Advocate Service and contacts if you
are outside of the United States go to
www.irs.gov/Advocate/Local-Taxpayer-
Advocate/Contact-Your-Local-Taxpayer-
Advocate.
Page 34 of 34 Fileid: … ons/P901/201609/B/XML/Cycle01/source 10:19  12Oct2016
The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.
Page 34 Publication 901 (September 2016)

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