Publication 901 - U.s. Tax Treaties - Internal Revenue Service Page 13
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34Do not have a fixed base regularly availa
The exemption does not apply to pay re
United States as a member of the board of di
ble to them in the United States for per
ceived by employees who are members of a
rectors of a company resident in the United
forming the services.
regular complement of a ship or aircraft oper
States.
ated in international traffic by a U.S. enterprise.
If they have a fixed base available, they are
Sweden
taxed only on income attributable to the fixed
These exemptions do not apply to public en
base.
tertainers (such as theater, motion picture, ra
Income that residents of Sweden receive for
dio, or television artists, or musicians) or ath
performing personal services as independent
Income that residents of South Africa re
letes from Spain who earn more than $10,000 in
contractors or selfemployed individuals (inde
ceive for services performed in the United
income, including reimbursed expenses, from
pendent personal services) in the United States
States as employees (dependent personal
their entertainment activities in the United
during the tax year is exempt from U.S. income
services) is exempt from U.S. income tax if the
States during the tax year. Regardless of these
tax if they do not have a fixed base regularly
following requirements are met.
limits, Spanish entertainers and athletes are ex
available to them in the United States for per
The resident is in the United States for no
empt from U.S. tax if their visit to the United
forming the services. If they have a fixed base
more than 183 days in any 12month pe
States is substantially supported by public
available in the United States, they are taxed on
riod beginning or ending in the tax year.
funds of Spain, a political subdivision, or local
the income attributable to the fixed base.
The income is paid by, or on behalf of, an
authority.
employer who is not a U.S. resident.
Income that residents of Sweden receive for
The income is not borne by a permanent
Sri Lanka
labor or personal services performed in the Uni
establishment or a fixed base that the em
ted States as employees (dependent personal
ployer has in the United States.
services) is exempt from U.S. income tax if the
Income that residents of Sri Lanka receive for
performing personal services as independent
residents meet three requirements.
These exemptions do not apply to directors'
contractors or selfemployed individuals (inde
They are in the United States for no more
fees and similar payments received by a resi
pendent personal services) in the United States
than 183 days during any consecutive
dent of South Africa for services performed in
during the tax year is exempt from U.S. income
12month period.
the United States as a member of the board of
tax if the residents:
Their income is paid by, or on behalf of, an
directors of a company resident in the United
Are in the United States for no more than
employer who is not a resident of the Uni
States.
183 days in any 12month period, or
ted States.
Do not have a fixed base regularly availa
Their income is not borne by a permanent
These exemptions do not apply to income
ble to them in the United States for the pur
establishment or a fixed base that the em
residents of South Africa receive as public en
pose of performing the services.
ployer has in the United States.
tertainers (such as theater, motion picture, ra
dio, or television artists, or musicians) or ath
If they have a fixed base available in the
Income received by a resident of Sweden
letes
if
their
gross
receipts,
including
for employment as a member of the regular
United States, they are taxed on the income at
reimbursed expenses, are more than $7,500
complement of a ship or aircraft operated in in
tributable to the fixed base.
during the tax year. Regardless of these limits,
ternational traffic is exempt from U.S. tax.
income of South African entertainers or athletes
Income that residents of Sri Lanka receive
is exempt from U.S. income tax if their visit to
These exemptions do not apply to income
for services performed in the United States as
the United States is wholly or mainly supported
residents of Sweden receive as public enter
employees (dependent personal services) is
by public funds of South Africa, its political sub
tainers (such as theater, motion picture, radio,
exempt from U.S. income tax if the residents
divisions, or local authorities.
or television artists, or musicians) or athletes if
meet the following requirements.
the gross income, including reimbursed expen
They are in the United States for no more
Income received by a resident of South Af
ses, is more than $6,000 for any 12month pe
than 183 days in any 12month period.
rica for services performed as an employee and
riod.
Their income is paid by, or on behalf of, an
member of the complement of a ship or aircraft
employer who is not a U.S. resident.
operated in international traffic is exempt from
Their income is not borne by a permanent
These exemptions do not apply to directors'
U.S. income tax.
establishment or a fixed base that the em
fees received by a resident of Sweden for serv
ployer has in the United States.
ices performed outside of Sweden as a member
Spain
of the board of directors of a company that is a
resident of the United States.
Income received from employment as a
Income that residents of Spain receive as inde
member of the regular complement of a ship or
pendent contractors or selfemployed individu
Switzerland
an aircraft operated in international traffic by a
als (independent personal services) in the Uni
Sri Lanka enterprise is exempt from U.S. tax. If
ted States is exempt from U.S. income tax if the
the ship or aircraft is operated by a U.S. enter
Income that residents of Switzerland receive for
residents do not have a fixed base available to
prise, the income is subject to U.S. tax.
personal services as independent contractors
them in the United States for performing the
or selfemployed individuals (independent per
services. If they have a fixed base, they are
These exemptions do not apply to public en
sonal services) that they perform during the tax
taxed only on the income attributable to the
tertainers (such as theater, motion picture, ra
year in the United States is exempt from U.S.
fixed base.
dio, or television entertainers, musicians, and
income tax if they do not have a fixed base reg
athletes) from Sri Lanka who earn more than
ularly available to them in the United States for
$6,000 in gross receipts, including reimbursed
performing the services. If they have a fixed
Income that residents of Spain receive for
expenses, from their entertainment activities in
base available in the United States, they are
personal services performed in the United
the United States during the tax year. Regard
taxed on the income attributable to the fixed
States as employees (dependent personal
less of these limits, income of Sri Lanka enter
services) is exempt from U.S. income tax if:
base.
tainers is exempt from U.S. income tax if their
The residents are present in the United
visit to the United States is directly or indirectly
States no more than 183 days in any
Income that residents of Switzerland receive
supported wholly or substantially by public
12month period,
for services performed in the United States as
funds of Sri Lanka or the United States, their
The income is paid by, or on behalf of, an
employees (dependent personal services) is
political subdivisions, or local authorities.
employer who is not a U.S. resident, and
exempt from U.S. income tax if the residents
The income is not borne by a permanent
meet the following requirements.
establishment or fixed base the employer
These exemptions do not apply to directors'
They are in the United States for no more
has in the United States.
fees and other compensation received by a res
than 183 days in any 12month period be
ident of Sri Lanka for services performed in the
ginning or ending in the tax year.
Publication 901 (September 2016)
Page 13
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