Italy
A professor or teacher who is a resident of Italy on the date of
arrival in the United States and who temporarily visits the United
States to teach or conduct research at a university, college, school,
or other educational institution, or at a medical facility primarily
funded 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 is exempt from U.S. income tax on
the income received for the teaching or research for not more than 2
years from the date of arrival in the United 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 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 institution located 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.
Korea, Republic of
An individual who is a resident of the Republic of 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 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.
Luxembourg
Note:
See the effective dates of the new treaty under Important
Changes at the beginning of this publication.
New treaty.
A resident of Luxembourg who is temporarily in the United States at
the invitation of a U.S. university, college, school, or other
recognized educational 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 otherwise.
This exemption does not apply to pay for research carried on for
the benefit of any person other than the educational institution that
extended the invitation.
Former treaty.
A resident of Luxembourg who is temporarily in the United States at
the invitation of a U.S. university, college, school, or other
recognized educational 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.
This exemption does not apply to pay for research carried on for
the benefit of any person other than the educational institution that
extended 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 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 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 private benefit of any person rather than in the
public interest. Nor does the exemption apply if the resident claimed
during the immediate preceding 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
educational 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 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.
Pakistan
A professor or teacher who is a resident of Pakistan and who
temporarily visits the United 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 Philippines 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 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 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.
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
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.
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 invitation of the U.S. Government, a university, other accredited
educational institution, or recognized research institution in the
United States, or under 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 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 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 immediately 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 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.
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 recognized 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 two years
from the date the individual first visits the United States for the
purpose of engaging in 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. This exemption does not apply if, during the immediately
preceding period, the benefits 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 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 the income received 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. Nor does the exemption apply to income if an agreement
exists between the Governments of Trinidad and Tobago and the United
States for providing the services of these individuals.
Turkey
An individual who was a resident of Turkey immediately 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 United States for teaching or research.
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.
New treaty.
There is no special provision for professors or teachers.
United Kingdom
A professor or teacher who is a resident of the United Kingdom 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, or other recognized educational
institution is exempt 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 or research
institution is exempt from U.S. income tax on the income received for
the teaching 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 executives, a citizen and resident of a
foreign country 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 received 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 Institutes 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
Program 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 visiting the United States who is
temporarily here for full-time education is exempt from U.S. income
tax on payments received from outside the United States for the
individual's maintenance or education.
Austria
A student, apprentice, or business trainee who is a resident of
Austria 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 sources outside the United States
for the individual's maintenance, education, or training.
Apprentices and business trainees are entitled to the benefit of
this exemption for a maximum period of 3 years.
Barbados
A student or business apprentice who is a resident 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, education, 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
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
primarily to study at a university or other recognized 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, charitable, scientific, literary, or
educational organization is exempt from U.S. income tax on the
following amounts.
- Gifts 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 $2,000 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 Belgium 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 Belgium is exempt 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 business experience from
a person other than that resident of Belgium or other than a person
related to that resident, or
- Study at an educational institution.
An individual who is a resident of Belgium on the date of arrival
in the United States and who is temporarily present in the United
States for not longer than one 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.
Canada
A full-time student, trainee, or business apprentice who is or was
a Canadian resident immediately before visiting the United States is
exempt from U.S. income tax on amounts received from sources outside
the United States for maintenance, education, or training.
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 obtain training,
education, or special technical experience is exempt from U.S. income
tax on the following amounts.
- Payments received from abroad for maintenance, education,
study, research, or training.
- Grants or awards from a government, scientific, educational,
or other tax-exempt organization.
- 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 complete the education or training.
Commonwealth of Independent States
An individual who is a resident of a C.I.S. member and who is
temporarily in the United States primarily to study at an educational
or scientific research institution or to obtain training for
qualification in a profession or specialty is exempt from U.S. income
tax on amounts received as stipends, scholarships, or other substitute
allowances 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,
professional, or commercial experience or perform technical services
and who is an employee of, or under contract with, a resident of a
C.I.S. member is exempt from U.S. income tax on the amounts received
from that resident. Also exempt is an amount received from U.S.
sources, of not more than $10,000, that is necessary to provide for
ordinary living expenses. The exemption contained in this paragraph is
limited to one 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
provided for by an agreement between governments on cooperation in
various fields of science and technology is exempt from U.S. income
tax on all income received in connection with the exchange program for
a period not longer than one 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
university or other recognized 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, charitable, scientific, literary, or educational
organization is exempt from U.S. income tax on the following amounts.
- Gifts from abroad for maintenance, education, 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 educational 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 one year on income from personal services for a
maximum of $7,500 if the individual is in the United States primarily
to either:
- Acquire technical, professional, or business 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 one 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 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 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 exemption, 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 governmental, religious, charitable,
scientific, literary, or educational organization.
If the individual meets any of these requirements, 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 performed 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 individual is in
the United States primarily to:
- Acquire technical, professional, or business 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 longer than 1 year as a
participant in a program sponsored by the U.S. government for the
primary 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
training, research, or study.
These exemptions do not apply to income 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.
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 United States
for the individual's maintenance, education, or training.
Apprentices and business trainees are entitled to the benefit of
this exemption for a maximum period of 3 years.
The exemption does not apply to income from research undertaken
primarily for the private benefit of a specific person or persons.
Former treaty.
A student or apprentice who is a citizen of Denmark and lives in
the United States only to study or acquire business experience is
exempt from U.S. income tax on amounts (other than the student's own
income) received from abroad for maintenance and studies.
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 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, charitable, scientific, literary, or
educational organization is exempt from U.S. income tax on the
following amounts.
- Gifts 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 $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
complete, as a full-time student, educational requirements as a
candidate for a postgraduate or professional degree from a recognized
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 as an
employee of, or under contract with, a resident of Egypt is exempt
from U.S. income 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 business experience from
a person other than that resident of Egypt or other than a person
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 than one 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 for a maximum of $10,000.
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