| 4 |
Does not apply to compensation for research work primarily for private benefit. |
| 5 |
Grant must be from a nonprofit organization. In many cases, the exemption also applies to amounts from either the U.S. or foreign government. For Indonesia and the Netherlands, the exemption also applies if the amount is awarded under a technical assistance program entered into by the United States or the foreign government, or its political subdivision or local authorities. |
| 6 |
Reimbursed expenses are not taken into account in figuring any maximum compensation to which the exemption applies. For Japan and Trinidad and Tobago, only reimbursed travel expenses are disregarded in figuring the maximum compensation. |
| 7 |
Does not apply to fees of foreign directors of a U.S.
corporation. |
| 9 |
Exemption does not apply if gross receipts exceed this amount. Income is fully exempt if visit to the United States is substantially supported by public funds of the treaty country or its political subdivisions or local authorities. |
| 10 |
Applies only to full-time students or trainees. |
| 12 |
Does not apply to compensation paid to public entertainers (actors, artists, musicians, athletes, etc.) |
| 13 |
Does not apply to compensation paid to public
entertainers that is more than $100 a day. |
| 14 |
Exemption applies only if the compensation is subject
to tax in the country of residence. |
| 19 |
Also exempt are amounts of up to $10,000 received from
U.S. sources to provide ordinary living expenses. For students the
amount will be less than $10,000, determined on a case by case basis. |
| 22 |
Exemption does not apply to the extent income is attributable to the recipient's fixed U.S. base. For residents of Japan, this fixed base must be maintained in the U.S. for more than 183 days during the tax year for the exemption not to apply; for residents of Belgium, Iceland, Korea, and Norway, the fixed base must be maintained for more than 182 days; for residents of Morocco, the fixed base must be maintained for more than 89 days. |
| 24 |
Fees paid to a resident of the treaty country for services performed in the United States as a director of a U.S. corporation are subject to U.S. tax. |
| 25 |
Exemption does not apply if gross receipts (including
reimbursements) exceed this amount. |
| 26 |
Exemption does not apply if net income exceeds this amount. |
| 29 |
The exemption applies only to income from activities
performed under special cultural exchange programs agreed to by the U.S.
and Chinese governments. |
| 30 |
Exemption does not apply is gross receipts (or compensation for Portugal), including reimbursements, exceed this amount. Income is fully exempt if visit to the United States is substantially supported by public funds of the treaty country or its political subdivisions or local authorities. |
| 31 |
The 5-year limit pertains only to training or
research. |
| 33 |
Exemption does not apply if, during the immediately
preceding period, the individual claimed the benefits of Article 21. |
| 40 |
The combined period of benefits under Article 20 and
21(1) cannot exceed 5 years. |
| 42 |
Exemption does not apply if gross receipts (including
reimbursements) exceed this amount during any 12-month period. |
| 43 |
This provision does not apply if the competent authority of the treaty country certifies that the visit is substantially supported by that treaty country. |
| 44 |
Applies to grants, allowances, and other similar
payments received for studying or doing research. |
| 45 |
A $10,000 limit applies if the expense is borne by a
permanent establishment or a fixed base in the United States. |
| 46 |
This provision does not apply if the activities are
substantially supported by a nonprofit organization or by public funds
of the treaty country of its political subdivisions or local
authorities. |
| 47 |
Applies to any additional period that a full-time
student needs to complete the educational requirements as a candidate
for a postgraduate or professional degree from a recognized educational
institution. |
| 49 |
Exemption does not apply if the recipient maintains a
permanent establishment in the U.S. with which the income is effectively
connected. |
| 50 |
The exemption does not apply to income received for performing services in the United States as an entertainer or a sportsman. However, this income is exempt for U.S. income tax if the visit is (a) substantially supported by public funds of Ukraine, its political subdivisions, or local authorities, or (b) made under a specific arrangement agreed to by the governments of the treaty countries. |
| 51 |
Exemption does not apply if gross receipts, including reimbursements, exceed this amount during the year. Income is fully exempt if visit is wholly or mainly supported by public funds of one or both of the treaty countries or their political subdivisions or local authorities. |
| 52 |
If the compensation exceeds $400 per day, the entertainer may be taxed on the full amount. If the individual receives a fixed amount for more than one performance, the amount is prorated over the number of days the individual performs the services (including rehearsals) |
| 53 |
Exemption does not apply if gross receipts exceed this amount. |
| 54 |
Treated as business profits under Article 7 of the treaty. |
