Publication 901 - U.s. Tax Treaties - Internal Revenue Service Page 15
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34These exemptions do not apply to directors'
contractors or selfemployed individuals are
United States as a member of the board of di
fees and similar payments received by a resi
subject to the provisions of Article 7 (Business
rectors of a company resident in the United
dent of Turkey for services provided in the Uni
Profits) of the treaty. Under that provision, busi
States.
ted States as a member of the board of direc
ness profits are exempt from U.S. income tax
Pay received by a resident of Venezuela for
tors of a company that is a resident of the
unless the individual has a permanent estab
services performed as an employee of a ship or
United States.
lishment in the United States. If they have a per
an aircraft operated in international traffic is ex
manent establishment in the United States, they
empt from U.S. income tax.
are taxed on the profits attributable to the per
These exemptions do not apply to income
manent establishment.
residents of Turkey receive as public entertain
These exemptions do not apply to income
ers (such as theater, motion picture, radio, or
residents of Venezuela receive as public enter
Income that residents of the United King
television artists, or musicians) or athletes if
tainers (such as theater, motion picture, radio,
dom receive for services performed in the Uni
their gross receipts are more than $3,000 dur
or television artists, or musicians) or sportsmen
ted States as employees (dependent personal
ing the tax year for their entertainment activities
if their gross income, including reimbursed ex
services) is exempt from U.S. income tax if the
in the United States. If their visit to the United
penses, is more than $6,000 for their personal
residents meet the following requirements.
States is substantially supported by a Turkish
activities in the United States during the tax
They are in the United States for no more
nonprofit organization or from the public funds
year. Regardless of these limits, income of Ven
than 183 days in any 12month period be
of Turkey, its political subdivisions, or local au
ezuelan entertainers or athletes is exempt from
ginning or ending in the tax year.
thorities, the income is taxed as independent
U.S. income tax if their visit to the United States
Their income is paid by, or on behalf of, an
personal services or dependent personal serv
is wholly or mainly supported by public funds of
employer who is not a U.S. resident.
ices.
Venezuela, its political subdivisions, or local au
Their income is not borne by a permanent
thorities.
establishment that the employer has in the
Ukraine
United States.
Professors, Teachers,
Income that residents of Ukraine receive for
The exemption does not apply to directors'
and Researchers
performing personal services as independent
fees and similar payments received by a resi
contractors or selfemployed individuals (inde
dent of the United Kingdom for services per
pendent personal services) in the United States
Pay of professors and teachers who are resi
formed in the United States as a member of the
is exempt from U.S. income tax if the income is
dents of the following countries is generally ex
board of directors of a company resident in the
not attributable to a fixed base in the United
empt from U.S. income tax for 2 or 3 years if
United States.
States that is regularly available for performing
they temporarily visit the United States to teach
the services.
or do research. The exemption applies to pay
Public entertainers (such as theater, motion
earned by the visiting professor or teacher dur
picture, radio, or television artists, musicians, or
Income that residents of Ukraine receive for
ing the applicable period. For most of the fol
athletes) from the United Kingdom who earn
employment in the United States (dependent
lowing countries, the applicable period begins
more than $20,000 in gross receipts, including
personal services) is exempt from U.S. income
on the date of arrival in the United States for the
reimbursed expenses, from their entertainment
tax if the following three requirements are met.
purpose of teaching or engaging in research.
activities in the United States during the tax
The resident is in the United States for no
Furthermore, for most of the following countries,
year are subject to U.S. tax.
more than 183 days during the tax year.
the exemption applies even if the stay in the
The income is paid by, or on behalf of, an
United States extends beyond the applicable
Income received by a resident of the United
employer who is not a resident of the Uni
period.
Kingdom for services performed as an em
ted States.
ployee and member of the regular complement
The exemption generally applies to pay re
The income is not borne by a permanent
of a ship or aircraft operated in international traf
ceived during a second teaching assignment if
establishment or a fixed base that the em
fic is exempt from U.S. income tax.
both are completed within the specified time,
ployer has in the United States.
even if the second assignment was not ar
Venezuela
ranged until after arrival in the United States on
These exemptions do not apply to directors'
the first assignment. For each of the countries
fees and similar payments received by a resi
Income that residents of Venezuela receive for
listed, the conditions are stated under which the
dent of Ukraine for services performed outside
personal services as independent contractors
pay of a professor or teacher from that country
of Ukraine as a member of the board of direc
or selfemployed individuals (independent per
is exempt from U.S. income tax.
tors of a company that is a resident of the Uni
sonal services) in the United States is exempt
ted States.
If you do not meet the requirements for ex
from U.S. income tax if they do not have a fixed
emption as a teacher or if you are a resident of
base regularly available to them in the United
These exemptions generally do not apply to
a treaty country that does not have a special
States for performing the services. If they have
income received as a public entertainer (such
provision for teachers, you may qualify under a
a fixed base available, they are taxed on the in
as a theater, motion picture, radio, or television
personal services income provision discussed
come attributable to the fixed base.
artist, musician, or athlete). However, income of
earlier.
Ukrainian entertainers and sportsmen is exempt
Income that residents of Venezuela receive
from U.S. income tax if their visit to the United
Bangladesh
for services performed in the United States as
States is substantially supported by public
employees (dependent personal services) is
funds of Ukraine, its political subdivisions, or lo
exempt from U.S. income tax if the residents
An individual is exempt from U.S. income tax on
cal authorities, or the visit is made pursuant to a
meet the following requirements.
income from teaching or research for not more
specific arrangement between the United
They are in the United States for no more
than 2 years from the date of arrival for such
States and Ukraine.
than 183 days in any 12month period be
purposes if he or she:
ginning or ending in the tax year.
Is a resident of Bangladesh immediately
Income derived by a resident of Ukraine
Their income is paid by, or on behalf of, an
before visiting the United States, and
from employment as a member of the regular
employer who is not a U.S. resident.
Is in the United States to teach or engage
complement of a ship or aircraft operated in in
The income is not borne by a permanent
in research at a university, college, or other
ternational traffic is exempt from U.S. tax.
establishment or a fixed base that the em
recognized educational institution.
ployer has in the United States.
United Kingdom
This exemption does not apply to income
These exemptions do not apply to directors'
from research carried on mainly for the private
Income that residents of the United Kingdom re
fees and similar payments received by a resi
benefit of any person rather than in the public
ceive for personal services as independent
dent of Venezuela for services performed in the
interest.
Publication 901 (September 2016)
Page 15
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