Publication 901 - U.s. Tax Treaties - Internal Revenue Service Page 3
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34during the tax year is exempt from U.S. income
Income received by a resident of Austria for
during the tax year is exempt from U.S. income
tax if the residents:
services performed as an employee and mem
tax if the residents:
Are in the United States for no more than
ber of the regular complement of a ship or air
Are in the United States for no more than
183 days during the tax year, and
craft operated in international traffic is exempt
89 days during the tax year,
Do not have a fixed base regularly availa
from U.S. income tax.
Earn net income for independent services
ble to them in the United States for the pur
provided to U.S. residents that is not more
pose of performing the services.
than $5,000 (there is no dollar limit if the
Bangladesh
contractors are not U.S. residents), and
If they have a fixed base available in the United
Do not have a regular base available in the
Income that residents of Bangladesh receive for
States, they are taxed on the income attributa
United States for performing the services.
performing personal services as independent
ble to the fixed base.
contractors or selfemployed individuals (inde
If they have a regular base available in the Uni
pendent personal services) in the United States
Pay that residents of Australia receive for la
ted States but otherwise meet the conditions for
during the tax year is exempt from U.S. income
bor or personal services performed in the Uni
exemption, they are taxed only on the income
tax if the residents:
ted States as employees (dependent personal
attributable to the regular base.
Are in the United States for no more than
services), including services as a director of a
183 days in any 12month period begin
company, is exempt from U.S. income tax if:
Income that residents of Barbados receive
ning or ending in the tax year, or
The residents are in the United States for
for personal services performed in the United
Do not have a fixed base regularly availa
no more than 183 days during the tax year,
States as employees (dependent personal
ble to them in the United States for the pur
The pay is paid by, or on behalf of, an em
services) is exempt from U.S. tax if the resi
pose of performing the services.
ployer or company that is not a resident of
dents meet four requirements.
the United States, and
They are in the United States for no more
If they have a fixed base available in the United
The pay is not deductible in determining
than 183 days during the calendar year.
States, they are taxed on the income attributa
the taxable income of the trade or business
The income earned in the calendar year in
ble to the fixed base.
of the employer (or company) in the United
the United States is not more than $5,000.
States.
Their income is paid by or for an employer
Income that residents of Bangladesh re
who is not a U.S. resident.
ceive for services performed in the United
These exemptions do not apply to public en
The income is not borne by a permanent
States as employees (dependent personal
tertainers (such as theater, motion picture, ra
establishment or regular base of the em
services) is exempt from U.S. income tax if the
dio, or television entertainers, musicians, and
ployer in the United States.
residents meet the following requirements.
athletes) from Australia who earn more than
They are in the United States for no more
$10,000 in gross receipts, including reimbursed
Income of a Barbadian resident from em
than 183 days in any 12month period be
expenses, from their entertainment activities in
ployment as a member of the regular comple
ginning or ending in the tax year.
the United States during the tax year.
ment of a ship or aircraft operated in interna
Their income is paid by, or on behalf of, an
tional traffic is exempt from U.S. tax.
employer who is not a U.S. resident.
Austria
Their income is not borne by a permanent
establishment or a fixed base that the em
These exemptions do not apply to Barba
Income that residents of Austria receive for per
ployer has in the United States.
dian resident public entertainers (such as thea
sonal services as independent contractors or
ter, motion picture, radio, or television artists,
selfemployed individuals (independent per
These exemptions do not apply to pubic en
musicians, or athletes) who receive gross re
sonal services) in the United States is exempt
tertainers (such as theater, motion picture, ra
ceipts of more than $250 per day or $4,000 in
from U.S. income tax if they do not have a fixed
dio, or television entertainers, musicians, and
the tax year, not including reimbursed expen
base regularly available to them in the United
athletes) from Bangladesh who earn more than
ses, from their entertainment activities in the
States for performing the services. If they have
$10,000 in gross receipts, including reimbursed
United States. However, the exemptions do ap
a fixed base available in the United States, they
expenses, from their entertainment activities in
ply regardless of these limits on gross receipts if
are taxed on the income attributable to the fixed
the United States during the tax year. Regard
the entertainer's visit to the United States is
base.
less of these limits, income of Bangladesh en
substantially supported by Barbadian public
tertainers is exempt from U.S. income tax if their
funds or if the entertainer's services are provi
Income that residents of Austria receive for
visit to the United States is wholly or mainly
ded to a nonprofit organization.
services performed in the United States as em
supported by public funds of Bangladesh, its
ployees (dependent personal services) is ex
political subdivisions, or local authorities.
Belgium
empt from U.S. income tax if the residents meet
the following requirements.
Income received from employment as a
Income that residents of Belgium receive for
They are in the United States for no more
member of the regular complement of a ship or
personal services as independent contractors
than 183 days in any 12month period be
an aircraft operated by a Bangladesh enterprise
or selfemployed individuals are subject to the
ginning or ending in the tax year.
in international traffic is exempt from U.S. tax. If
provisions of Article 7 (Business Profits) of the
Their income is paid by, or on behalf of, an
the ship or aircraft is operated by a U.S. enter
treaty. Under that provision, business profits are
employer who is not a U.S. resident.
prise, the income is subject to U.S. tax.
exempt from U.S. income tax unless the individ
Their income is not borne by a permanent
ual has a permanent establishment in the Uni
establishment or a fixed base that the em
If the resident of Bangladesh is a share
ted States. If they have a permanent establish
ployer has in the United States.
holder in a U.S. corporation, these exemptions
ment in the United States, they are taxed on the
do not apply to directors' fees received as a
profit attributable to the permanent establish
These exemptions do not apply to public en
member of the board of directors of the U.S.
ment.
tertainers (such as theater, motion picture, ra
corporation. The amount received by the share
dio, or television entertainers, musicians, and
holder that is more than the amount paid to a di
Income that residents of Belgium receive for
athletes) from Austria who earn more than
rector that is not a shareholder is subject to U.S.
services performed in the United States as em
$20,000 in gross receipts, including reimbursed
tax at the rate of 15%.
ployees (dependent personal services) is ex
expenses, from their entertainment activities in
empt from U.S. income tax if the residents meet
the United States during the tax year.
Barbados
the following requirements.
They are in the United States for no more
Income that residents of Barbados receive for
than 183 days in any 12month period be
performing personal services as independent
ginning or ending in the tax year.
contractors or selfemployed individuals (inde
Their income is paid by, or on behalf of, an
pendent personal services) in the United States
employer who is not a U.S. resident.
Publication 901 (September 2016)
Page 3
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