Publication 901 - U.s. Tax Treaties - Internal Revenue Service Page 10
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34Morocco
The exemption does not apply to directors'
income tax if the following three requirements
fees and similar payments received by a resi
are met.
dent of Malta for services performed in the Uni
Income that residents of Morocco receive for
The resident is in the United States for no
ted States as a member of the board of direc
performing personal services as independent
more than 183 days during the tax year.
tors of a company that is a resident of the
contractors or as selfemployed persons (inde
The income is paid by, or on behalf of, an
United States.
pendent personal services) in the United States
employer who is not a U.S. resident.
during the tax year is exempt from U.S. income
The income is not borne by a permanent
tax if the residents:
establishment or fixed base the employer
Public entertainers (such as theater, motion
Are in the United States for no more than
has in the United States.
picture, radio, or television artists, musicians, or
182 days during the tax year,
athletes) from Malta who earn more than
Income received by a Netherlands resident
Do not maintain a fixed base in the United
$20,000 in gross receipts, including reimbursed
for employment as a member of the regular
States for more than 89 days during the tax
expenses, from their entertainment activities in
complement of a ship or aircraft operated in in
year, and
the United States during the tax year are sub
ternational traffic is exempt from U.S. tax.
Earn total income for those services that is
ject to U.S. tax.
not more than $5,000.
These exemptions do not apply to directors'
If they have a fixed base in the United States for
Income received by a resident of Malta for
fees and other similar payments received by a
more than 89 days, they are taxed only on the
employment aboard a ship or an aircraft oper
resident of the Netherlands for services per
income attributable to the fixed base.
ated in international traffic is exempt from U.S.
formed outside the Netherlands as a member of
income tax if the individual is a member of the
the board of directors of a company that is a
Income that residents of Morocco receive
regular complement of the ship or aircraft.
resident of the United States.
for labor or personal services performed in the
United States as employees (dependent per
Mexico
These exemptions do not apply to income
sonal services) is exempt from U.S. income tax
residents of the Netherlands receive as public
if the residents meet three requirements.
Income that residents of Mexico receive for per
entertainers (such as theater, motion picture,
They are in the United States for less than
forming personal services as independent con
radio, or television artists, or musicians) or ath
183 days during the tax year.
tractors or selfemployed individuals (independ
letes if the gross income, including reimbursed
They are employees of a resident of Mo
ent personal services) in the United States is
expenses, is more than $10,000.
rocco or of a permanent establishment of a
exempt from U.S. income tax if the residents:
resident of a country other than Morocco if
Are in the United States for no more than
New Zealand
the permanent establishment is located in
182 days in a 12month period, and
Morocco.
Do not have a fixed base that they regu
Income that residents of New Zealand receive
Their income is not borne by a permanent
larly use for performing the services.
for performing personal services as independ
establishment that the employer has in the
ent contractors or selfemployed individuals is
If they have a fixed base available, they are
United States.
subject to the provisions of Article 7 (Business
taxed only on income attributable to the fixed
Profits) of the treaty. Under that provision, busi
base.
Compensation received for services per
ness profits are exempt from U.S. income tax
formed by a member of the board of directors of
unless the individual has a permanent estab
a corporation does not qualify for this exemp
Income that residents of Mexico receive for
lishment in the United States. If they have a per
tion.
employment in the United States (dependent
manent establishment in the United States, they
personal services) is exempt from U.S. tax if the
are taxed on the profits attributable to the per
Income received by an individual for per
following three requirements are met.
manent establishment.
forming labor or personal services as an em
The resident is present in the United
ployee aboard a ship or an aircraft operated in
States for no more than 183 days in a
Income that residents of New Zealand re
international traffic by a Moroccan resident is
12month period.
ceive for labor or personal services performed
exempt from U.S. income tax if the individual is
The income is paid by, or on behalf of, an
in the United States as employees (dependent
a member of the regular complement of the ship
employer who is not a resident of the Uni
personal services) is exempt from U.S. income
or aircraft.
ted States.
tax if the residents meet these requirements.
The income is not borne by a permanent
They are present in the United States for
These exemptions do not apply to income
establishment or fixed base that the em
no more than 183 days in any consecutive
received for services performed in the United
ployer has in the United States.
12month period.
States by professional entertainers, including
Their income is paid by or on behalf of an
theater, film, radio, and television performers,
These exemptions do not apply to directors'
employer that is not a resident of the Uni
musicians, and athletes, unless the services are
fees and similar payments received by a resi
ted States.
performed by, or for the account of, a Moroccan
dent of Mexico for services performed outside
Their income is not borne by a permanent
nonprofit organization.
Mexico as a director or overseer of a company
establishment that the employer has in the
that is a U.S. resident.
United States.
Netherlands
These exemptions do not apply to income
The exemption does not apply to public en
Income that residents of the Netherlands re
residents of Mexico receive as public entertain
tertainers (artists, athletes, etc.) from New Zea
ceive for performing personal services as inde
ers (such as theater, motion picture, radio, or
land who earn more than $10,000 in gross re
pendent contractors or selfemployed individu
television artists, or musicians) or athletes if the
ceipts, including reimbursed expenses, from
als (independent personal services) in the
income, including reimbursed expenses, is
their entertainment activities in the United
United States is exempt from U.S. income tax if
more than $3,000 during the tax year for their
States during the tax year.
the income is not attributable to a fixed base in
entertainment activities in the United States.
the United States that is regularly available for
Pay received by a New Zealand resident as
This includes income from activities performed
performing the services.
an employee and member of the regular com
in the United States relating to the entertainer or
plement of a ship or aircraft operated in interna
athlete's reputation, such as endorsements of
Income that residents of the Netherlands re
tional traffic is exempt from U.S. tax.
commercial products. Regardless of this limit,
ceive for employment in the United States (de
the income of Mexican entertainers and ath
pendent personal services) is exempt from U.S.
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.
Page 10
Publication 901 (September 2016)
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