Sweden

Income that residents of Sweden receive for performing personal services as independent contractors or self-employed individuals (independent 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 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 Sweden receive 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 three requirements.

1. They are in the United States for no more than 183 days during any consecutive 12-month period.
2. Their income is paid by, or on behalf of, an employer who is not a resident of the United States.
3. Their income is not borne by a permanent establishment or a fixed base that the employer 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 international traffic is exempt from U.S. tax.

These exemptions do not apply to income residents of Sweden receive as public entertainers (such as theater, motion picture, radio, or television artists, or musicians) or athletes if the gross income, including reimbursed expenses, is more than $6,000 for any 12-month period.

These exemptions do not apply to directors' fees received by a resident of Sweden for services 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 personal 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 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 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.

1. They are in the United States for no more than 183 days in any 12-month period beginning or ending in the tax year.
2. Their income is paid by, or on behalf of, an employer who is not a U.S. resident.
3. Their income is not borne by a permanent establishment or a fixed base that the employer has in the United States.

These exemptions do not apply to directors' fees and similar payments received by a resident of Switzerland 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 public entertainers (such as theater, motion picture, radio, 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 Switzerland 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 (independent personal services) in the United States during the tax year is exempt from U.S. income tax if the residents:

1. Are in the United States for no more than 89 days during the tax year, and
2. Do not have a fixed base regularly available to them in the United States for performing their services.

If they have a fixed base available in the United States, they are taxed only on the income attributable to the fixed base.

This exemption does not apply if a resident of Thailand earns more than $10,000 for independent personal services and that income is paid by a U.S. resident or borne by a permanent establishment or fixed base in the United States.

Income that residents of Thailand receive 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.

1. The resident is in the United States for no more than 183 days in any 12-month period beginning or ending in the tax year.
2. The income is paid by, or on behalf of, an employer who is not a U.S. resident.
3. The income is not borne by a permanent establishment or a fixed base that the employer has in the United States.

These exemptions do not apply to directors' fees and similar payments received by a resident of Thailand for services performed outside of Thailand 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 Thailand receive for performing services in the United States as entertainers (such as theater, motion picture, radio, or television artists, musicians) and athletes, if the income 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 supported by public funds of Thailand or its poilitical subdivisions or local authorities.

Pay received by employees of a ship or aircraft operated in international traffic by a Thai enterprise may be taxed by Thailand.

Trinidad and Tobago

Income (including reimbursed travel expenses) that residents of Trinidad and Tobago receive during the tax year for personal services performed 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:

1. The residents are employees of a resident of a country other than the United States or are employees of a permanent establishment of a U.S. resident outside the United States and the income is not deducted in figuring the profits of a permanent establishment in the United States, or
2. The income is not more than $3,000 (excluding reimbursed travel expenses).

These exemptions do not apply to the professional 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 reimbursed travel expenses).

Pay received by members of the regular complement of a ship or aircraft operated in international traffic by a resident of Trinidad and Tobago is exempt from U.S. tax.

Tunisia

Income that residents of Tunisia receive for performing personal services as independent contractors or self-employed individuals (independent personal services) in the United States are exempt from U.S. income tax if:

1. They are in the United States for no more than 183 days during the tax year,
2. They do not have a fixed base regularly available in the United States for performing the services, and
3. 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:

1. The residents are in the U.S. for no more than 183 days during the tax year,
2. Their income is paid by, or on behalf of, an employer who is not a resident of the United States, and
3. 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 members of the regular complement of a ship or aircraft operated by an enterprise in international traffic is exempt from U.S. tax if the place of management of the enterprise is in Tunisia.

These exemptions do not apply to income residents of Tunisia receive as public entertainers (such as theater, motion picture, radio, or television artists and musicians) or athletes if their gross receipts, including reimbursed expenses, are more than $7,500 during the tax year.

These exemptions do not apply to fees received by a resident of Tunisia for services performed 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 corporation.

Turkey

Income that residents of Turkey receive for performing personal services as independent contractors or self-employed individuals (independent personal services) in the United States is exempt from U.S. income tax if the residents:

1. Are in the United States for purposes of performing the services or activities for no more than 183 days in any 12-month period, and
2. 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 only on income attributable to the fixed base.

Income that residents of Turkey receive 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.

1. The resident is in the United States for no more than 183 days in any 12-month period.
2. The income is paid by, or on behalf of, an employer who is not a U.S. resident.
3. The income is not borne by a permanent establishment or a fixed base that the employer has in the United States.

These exemptions do not apply to directors' fees and similar payments received by a resident of Turkey for services provided in the United States 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 Turkey receive as public entertainers (such as theater, motion picture, radio, or television artists, or musicians) or athletes if their gross receipts are more than $3,000 during 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 authorities, the income is taxed as independent personal services or dependent personal services.

These exemptions do not apply to a resident of Turkey who performs services as a member of the regular complement of a ship or an aircraft operated by a United States resident in international traffic.

Ukraine

Note:    See the effective dates of the new treaty under Important Changes at the beginning of this publication. For information on the old provisions, see Commonwealth of Independent States.

Income that residents of Ukraine receive for performing personal services as independent contractors or self-employed individuals (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 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.

1. The resident is in the United States for no more than 183 days during the tax year.
2. The income is paid by, or on behalf of, an employer who is not a resident of the United States.
3. The income is not borne by a permanent establishment or a fixed base that the employer has in the United States.

These exemptions do not apply to directors' fees and similar payments received by a resident of Ukraine for services performed outside of Ukraine as a member of the board of directors of a company that is a resident of the United 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 Ukranian 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 local authorities, or the visit is made pursuant to a specific arrangement between the United States and Ukraine.

Income from employment as a member of the regular complement of a ship or aircraft operated in international traffic is exempt from U.S. tax.

United Kingdom

Income that residents of the United Kingdom receive for performing personal services as independent contractors or self-employed individuals (independent personal services) in the United States during the tax year is exempt from U.S. tax if the residents:

1. Are in the United States for no more than 183 days during the tax year, and
2. Do not have a fixed base regularly available in the United States.

Income that residents of the United Kingdom receive for labor or personal services performed in the United States as employees (dependent personal services) is exempt from U.S. tax if the employees meet three requirements.

1. They are in the United States for no more than 183 days.
2. Their income is paid by or on behalf of an employer who is not a resident of the United States.
3. Their income is not borne by a permanent establishment or a fixed base that the employer has in the United States.

Income for services performed by an employee and member of the regular complement of a ship or aircraft operated in international traffic is taxed by the country of which the employer operating the ship or aircraft is a resident.

These exemptions do not apply to income received for services performed in the United States as an entertainer, musician, or athlete if the income, including reimbursed expenses, is more than $15,000 in any tax year.

Venezuela

Income that residents of Venezuela receive for personal services as independent contractors or self-employed individuals (independent 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, they are taxed on the income 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.

1. They are in the United States for no more than 183 days in any 12-month period beginning or ending in the tax year.
2. Their income is paid by, or on behalf of, an employer who is not a U.S. resident.
3. The income is not borne by a permanent establishment or a fixed base that the employer has in the United States.

These exemptions do not apply to directors' fees and similar payments received by a resident of Venezuela for services performed in the United States as a member of the board of directors 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 exempt from U.S. income tax.

These exemptions do not apply to income residents of Venezuela receive as public entertainers (such as theater, motion picture, radio, or television artists, or musicians) or sportsmen if their gross income, including reimbursed expenses, is more than $6,000 for their personal activities in the United States during the tax year. Regardless of these limits, income of Venezuelan 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 authorities.

Professors, Teachers, and Researchers

Pay of professors and teachers who are residents of the following countries is generally exempt 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 during the applicable period. For most of the following 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 received during a second teaching assignment if both are completed within the specified time, even if the second assignment was not arranged 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 exemption 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.

Belgium

An individual who is a resident of Belgium 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 accredited 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.

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 conduct research at a university or other accredited educational institution or scientific research institution is exempt from U.S. income tax on income 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

An individual who is a resident of a C.I.S. member 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 educational or scientific research institution in the United States primarily to teach, engage in research, 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 maximum 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 enterprise 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. Government or other appropriate institution, nor does it matter that they are employed by a private person, including commercial enterprises and foreign 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:

1. Is a resident of the Czech Republic immediately before visiting the United States, and
2. 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:

1. The resident claimed during the immediate preceding period the benefits described later under Students and Apprentices, or
2. The income is from research undertaken primarily for the private benefit of a specific person or persons.

Denmark

Note:    See the effective dates of the new treaty under Important Changes at the beginning of this publication.

New treaty.   There is no special provision for professors or teachers.

Former treaty.    A professor or teacher who is a resident of Denmark and temporarily visits the United States to teach at a university, college, school, or other educational institution for a period not longer than 2 years is exempt from U.S. income tax on income for teaching during that period.

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 university or other recognized educational institution 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.

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 educational or research 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 may claim this benefit only once. Also, this benefit and the benefits described 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 Germany and who is in the United States for not more than 2 years to engage in advanced study or research or teaching at an accredited educational institution or institution engaged in research for the public benefit is exempt from U.S. tax on income received for such study, research, or teaching. If the individual's visit to the United States exceeds 2 years, the exemption is lost for the entire visit unless the competent authorities of Germany and the United States agree otherwise.

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.

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 university or other recognized 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. 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

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 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 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.

India

An individual is exempt from U.S. tax on income received for teaching or research if he or she:

1. Is a resident of India immediately before visiting the United States, and
2. 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:

1. Is a resident of Indonesia immediately before visiting the United States, and
2. Is in the United States at the invitation of a university, school, or other recognized educational institution to teach or engage in research, or both, at that educational institution.

A resident of Indonesia is entitled to this exemption 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 university or other recognized educational institution 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, during the immediately preceding period, the benefits described in Article 24(1) of the treaty, pertaining to students, were claimed.

Previous | First | Next

Publication Index | 2002 Tax Help Archives | Tax Help Archives | Home