Publication 901 - U.s. Tax Treaties - Internal Revenue Service Page 14
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34Their income is paid by, or on behalf of, an
services in the United States as entertainers
Their income is paid by, or on behalf of, an
employer who is not a U.S. resident.
(such as theater, motion picture, radio, or televi
employer who is not a resident of the Uni
Their income is not borne by a permanent
sion artists, or musicians) and athletes, if the in
ted States, and
establishment or a fixed base that the em
come is more than $100 a day or $3,000 for the
Their income is not borne by a permanent
ployer has in the United States.
tax year. Regardless of these limits, income of
establishment or fixed base the employer
Thai entertainers is exempt from U.S. tax if their
has in the United States.
visit to the United States is substantially suppor
These exemptions do not apply to directors'
Pay received by employees who are mem
ted by public funds of Thailand or its political
fees and similar payments received by a resi
bers of the regular complement of a ship or air
subdivisions or local authorities.
dent of Switzerland as a member of the board
craft operated by an enterprise in international
of directors of a company that is a resident of
traffic is exempt from U.S. tax if the place of
the United States.
The exemption does not apply to pay re
management of the enterprise is in Tunisia.
ceived by employees who are members of the
However, if the enterprise is created under the
These exemptions do not apply to public en
regular complement of a ship or aircraft oper
laws of the United States (or a U.S. state), the
tertainers (such as theater, motion picture, ra
ated in international traffic by a U.S. enterprise.
pay is subject to U.S. tax.
dio, or television entertainers, musicians, and
athletes) from Switzerland who earn more than
Trinidad and Tobago
These exemptions do not apply to income
$10,000 in gross receipts, including reimbursed
residents of Tunisia receive as public entertain
expenses, from their entertainment activities in
Income (including reimbursed travel expenses)
ers (such as theater, motion picture, radio, or
the United States during the tax year.
that residents of Trinidad and Tobago receive
television artists, and musicians) or athletes if
during the tax year for personal services per
their gross receipts, including reimbursed ex
Income received by a resident of Switzer
formed in the United States is exempt from U.S.
penses, are more than $7,500 during the tax
land for services performed as an employee
income tax if the individuals are in the United
year.
and member of the regular complement of a
States for no more than 183 days during the tax
ship or aircraft operated in international traffic is
year and either:
These exemptions do not apply to fees re
exempt from U.S. income tax.
The residents are employees of a resident
ceived by a resident of Tunisia for services per
of a country other than the United States or
formed as a director of a U.S. corporation if the
Thailand
are employees of a permanent establish
fees are treated as a distribution of profits and
ment of a U.S. resident outside the United
cannot be taken as a deduction by the corpora
Income that residents of Thailand receive for
States and the income is not deducted in
tion.
performing personal services as independent
figuring the profits of a permanent estab
contractors or as selfemployed individuals (in
lishment in the United States, or
Turkey
dependent personal services) in the United
The income is not more than $3,000 (ex
States during the tax year is exempt from U.S.
cluding reimbursed travel expenses).
Income that residents of Turkey receive for per
income tax if the residents:
forming personal services as independent con
Are in the United States for no more than
These exemptions do not apply to the pro
tractors or selfemployed individuals (independ
89 days during the tax year, and
fessional earnings of public entertainers such
ent personal services) in the United States is
Do not have a fixed base regularly availa
as actors, musicians, and professional athletes
exempt from U.S. income tax if the residents:
ble to them in the United States for per
or to any person providing their services if the
Are in the United States for purposes of
forming their services.
pay is more than $100 per day (excluding reim
performing the services or activities for no
bursed travel expenses).
If they have a fixed base available in the United
more than 183 days in any 12month pe
States, they are taxed only on the income attrib
riod, and
utable to the fixed base.
Pay received by members of the regular
Do not have a fixed base regularly availa
complement of a ship or aircraft operated in in
ble to them in the United States for per
This exemption does not apply if a resident
ternational traffic by a resident of Trinidad and
forming the services.
of Thailand earns more than $10,000 for inde
Tobago is exempt from U.S. tax.
If they have a fixed base available, they are
pendent personal services and that income is
taxed only on income attributable to the fixed
paid by a U.S. resident or borne by a perma
Tunisia
base.
nent establishment or fixed base in the United
States.
Income that residents of Tunisia receive for per
Income that residents of Turkey receive for
forming personal services as independent con
services performed in the United States as em
Income that residents of Thailand receive for
tractors or selfemployed individuals (independ
ployees (dependent personal services) is ex
services performed in the United States as em
ent personal services) in the United States are
empt from U.S. income tax if the following re
ployees (dependent personal services) is ex
exempt from U.S. income tax if:
quirements are met.
empt from U.S. income tax if the following re
They are in the United States for no more
The resident is in the United States for no
quirements are met.
than 183 days during the tax year,
more than 183 days in any 12month pe
The resident is in the United States for no
They do not have a fixed base regularly
riod.
more than 183 days in any 12month pe
available in the United States for perform
The income is paid by, or on behalf of, an
riod beginning or ending in the tax year.
ing the services, and
employer who is not a U.S. resident.
The income is paid by, or on behalf of, an
The gross income for the tax year from
The income is not borne by a permanent
employer who is not a U.S. resident.
U.S. residents for services performed in
establishment or a fixed base that the em
The income is not borne by a permanent
the United States is no more than $7,500.
ployer has in the United States.
establishment or a fixed base that the em
ployer has in the United States.
This exemption does not apply to a resident
If they do not meet condition (2), they are
of Turkey who performs services as a member
taxed on the income that is attributable to the
These exemptions do not apply to directors'
of the regular complement of a ship or an air
fixed base.
fees and similar payments received by a resi
craft operated by a U.S. resident in international
dent of Thailand for services performed outside
traffic.
Income that residents of Tunisia receive for
of Thailand as a member of the board of direc
personal services performed in the United
tors of a company that is a resident of the Uni
States as employees (dependent personal
ted States.
services) is exempt from U.S. income tax if:
The residents are in the U.S. for no more
These exemptions do not apply to income
than 183 days during the tax year,
residents of Thailand receive for performing
Page 14
Publication 901 (September 2016)
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