Publication 901 - U.s. Tax Treaties - Internal Revenue Service Page 12
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34Income that residents of Romania receive
assembly or installation project, or drilling oper
board of directors of a company that is a resi
for labor or personal services performed as em
ation.
dent of the United States.
ployees (dependent personal services), includ
ing services performed by an officer of a corpo
Income from employment as a member of
Income derived by a resident of Russia from
ration or company, in the United States during
the regular complement of a ship or aircraft op
employment as a member of the regular com
the tax year is exempt from U.S. income tax if
erated by a Slovak enterprise in international
plement of a ship or aircraft operated in interna
the residents meet these requirements.
traffic is exempt from U.S. income tax. If the
tional traffic is exempt from U.S. tax.
They are in the United States for no more
ship or aircraft is operated by a U.S. enterprise,
than 182 days during the tax year.
the income is subject to U.S. income tax.
Income from technical services directly con
They are employees of a resident of Ro
nected with the application of a right or property
mania or of a permanent establishment
Slovenia
giving rise to a royalty is exempt if those serv
maintained in Romania by a resident of the
ices are provided as part of a contract granting
United States.
Income that residents of Slovenia receive for
the use of the right or property.
Their income is not borne by a permanent
personal services as independent contractors
establishment that the employer has in the
or selfemployed individuals (independent per
These exemptions do not apply to directors'
United States.
sonal services) in the United States is exempt
fees and similar payments received by a resi
from U.S. income tax if they do not have a fixed
dent of Russia as a member of the board of di
These exemptions do not apply to entertain
base regularly available to them in the United
rectors or similar body of a company that is a
ers, such as theater, motion picture, radio, or
States for performing the services. If they have
resident of the United States.
television artists, musicians, or athletes, who
a fixed base available in the United States, they
are present in the United States for more than
are taxed on the income attributable to the fixed
Slovak Republic
90 days during the tax year (90 days or more if
base.
the entertainers are employees) or who earn
gross income as entertainers in the United
Income that residents of the Slovak Republic re
Income that residents of Slovenia receive for
ceive for performing personal services as inde
States of more than $3,000 during the tax year
services performed in the United States as em
pendent contractors or selfemployed individu
($3,000 or more if they are employees). How
ployees (dependent personal services) is ex
als (independent personal services) in the
ever, the exemptions do apply, without regard
empt from U.S. income tax if the residents meet
United States is exempt from U.S. income tax if
to the 90 day, $3,000 requirement, if the enter
the following requirements.
the residents:
tainers are present in the United States by spe
They are in the United States for no more
Are present in the United States for no
cific arrangements between the United States
than 183 days in any 12month period be
more than 183 days in any 12month pe
and Romania.
ginning or ending in the tax year.
riod, and
Their income is paid by, or on behalf of, an
Do not have a fixed base regularly availa
Pay received by employees who are mem
employer who is not a U.S. resident.
ble to them in the United States for per
bers of the regular complement of a ship or air
Their income is not borne by a permanent
forming the activities.
craft operated by a resident of Romania in inter
establishment or a fixed base that the em
national traffic is exempt from U.S. tax.
If they have a fixed base available, they are
ployer has in the United States.
taxed only on income attributable to the fixed
Russia
base.
These exemptions do not apply to directors'
fees and similar payments received by a resi
Income that residents of Russia receive for per
Income that residents of the Slovak Repub
dent of Slovenia for services performed in the
forming personal services as independent con
lic receive for employment in the United States
United States as a member of the board of di
tractors or selfemployed individuals (independ
(dependent personal services) is exempt from
rectors of a company that is a resident of the
ent personal services) in the United States is
U.S. income tax if the following three require
United States.
exempt from U.S. income tax if:
ments are met.
The residents are in the United States for
The resident is present in the United
Income received by a Slovenian resident for
no more than 183 days during the calendar
States for no more than 183 days in any
employment as a member of the regular com
year, or
12month period.
plement of a ship or aircraft operated in interna
The income is not attributable to a fixed
The income is paid by, or on behalf of, an
tional traffic is exempt from U.S. tax.
base in the United States which is regularly
employer who is not a U.S. resident.
available to the residents.
The income is not borne by a permanent
These exemptions do not apply to income
establishment or a fixed base that the em
If the residents have a fixed base available, they
residents of Slovenia receive as public enter
ployer has in the United States.
are taxed only on the income attributable to the
tainers (such as theater, motion picture, radio,
fixed base.
or television artists, or musicians) or athletes if
These exemptions do not apply to income
their gross receipts, including reimbursed ex
Income that residents of Russia receive for
residents of the Slovak Republic receive as
penses, are more than $15,000 during the tax
employment in the United States (dependent
public entertainers (such as theater, motion pic
year. Regardless of these limits, income of
personal services) is exempt from U.S. income
ture, radio, or television artists, or musicians) or
Slovenian entertainers or athletes is exempt
tax if the following three requirements are met.
sportsmen if their gross receipts, including re
from U.S. tax if their visit to the United States is
The resident is in the United States for no
imbursed expenses, are more than $20,000
wholly or mainly paid by public funds of either
more than 183 days during the calendar
during the tax year. Regardless of these limits,
the United States or Slovenia or their political
year.
income of Slovak entertainers and sportsmen is
subdivisions, or local authorities.
The income is paid by, or on behalf of, an
exempt from U.S. income tax if their visit to the
employer who is not a resident of the Uni
United States is substantially supported by pub
South Africa
ted States.
lic funds of the Slovak Republic, its political
The income is not borne by a permanent
subdivisions, or local authorities, or the visit is
Income that residents of South Africa receive
establishment or a fixed base that the em
made pursuant to a specific arrangement be
for performing personal services as independ
ployer has in the United States.
tween the United States and the Slovak Repub
ent contractors or selfemployed individuals (in
lic.
However, income from employment directly
dependent personal services) in the United
connected with a place of business that is not a
States is exempt from U.S. income tax if the
permanent establishment is exempt if the resi
These exemptions do not apply to directors'
residents:
dent is present in the United States not longer
fees and similar payments received by a resi
Are in the United States for no more than
than 12 consecutive months. For this purpose,
dent of the Slovak Republic for services per
183 days in any 12month period begin
a place of business means a construction site,
formed in the United States as a member of the
ning or ending in the tax year, and
Page 12
Publication 901 (September 2016)
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