Publication 901 - U.s. Tax Treaties - Internal Revenue Service Page 30
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34Jamaica
Korea, South
These exemptions do not apply to income or
pensions for services performed in connection
with a trade or business carried on by Indone
Income, other than a pension, paid by the Gov
Wages, salaries, and similar income, including
sia, its subdivisions, or local authorities.
ernment of Jamaica or its political subdivisions
pensions and similar benefits, paid from public
or local authorities for personal services per
funds of South Korea to a citizen of Korea
formed for the paying governmental body is ex
(other than a U.S. citizen or an individual admit
Ireland
empt from U.S. income tax.
ted to the United States for permanent resi
dence) for services performed as an employee
Income, other than a pension, paid by Ireland or
of Korea discharging government functions are
its political subdivisions or local authorities to an
This exemption does not apply to payments
exempt from U.S. income tax.
individual for services performed for the paying
for services performed in the United States by
governmental body is exempt from U.S. income
an individual who is a citizen and resident of the
Latvia
tax. However, the exemption does not apply to
United States.
payments for services performed in the United
States by a resident of the United States who
Income, other than a pension, paid by or from
Pensions paid by Jamaica for services per
either:
public funds of Latvia, its political subdivisions,
formed for Jamaica generally are exempt from
Is a U.S. citizen, or
or local authorities to an individual for services
U.S. income tax. However, if the recipient of the
Did not become a U.S. resident only to
performed as an employee for the paying gov
pension is a citizen and resident of the United
perform the services.
ernmental body in the discharge of governmen
States and was a U.S. citizen at the time the
tal functions is exempt from U.S. income tax.
services were performed, the pension is taxable
Pensions paid by Ireland for services per
However, the exemption does not apply if the
in the United States.
formed for Ireland are exempt from U.S. income
services are performed in the United States by
tax unless the recipient is both a resident and
a resident of the United States who either:
These exemptions do not apply to income or
citizen of the United States.
Is a U.S. citizen, or
pensions for services performed in connection
Did not become a U.S. resident only to
with a trade or business carried on by Jamaica
These exemptions do not apply to income or
perform the services.
or its subdivisions or local authorities.
pensions for services performed in connection
with a business carried on by Ireland or its sub
Pensions paid by or from the public funds of
Japan
divisions or local authorities.
Latvia, its political subdivisions, or local authori
ties for services performed for Latvia are ex
Income, other than a pension, paid by Japan, its
Israel
empt from U.S. income tax unless the recipient
political subdivisions, or local authorities to an
is both a resident and citizen of the United
individual for services performed for the paying
Wages, salaries, and similar income, including
States.
governmental body is exempt from U.S. income
pensions and similar benefits, paid from public
tax. However, the exemption does not apply if
funds by the national government of Israel or its
Lithuania
the services are performed in the United States
agencies, for services performed in the dis
by a resident of the United States who either:
charge of governmental functions, are exempt
Income, other than a pension, paid by or from
Is a U.S. citizen, or
from U.S. income tax. This exemption does not
public funds of Lithuania, its political subdivi
Did not become a U.S. resident only to
apply to citizens of the United States or alien
sions, or local authorities to an individual for
perform the services.
residents of the United States.
services performed as an employee for the pay
ing governmental body in the discharge of gov
Pensions paid by, or out of funds to which
Italy
ernmental functions is exempt from U.S. in
contributions are made by, Japan, its political
come tax. However, the exemption does not
subdivisions, or local authorities for services
apply if the services are performed in the United
Income, other than a pension, paid by Italy or by
performed for Japan are exempt from U.S. in
States by a resident of the United States who
an Italian political or administrative subdivision
come tax unless the recipient is a resident and
either:
or local authority to an individual for services
citizen of the United States.
Is a U.S. citizen, or
performed for the paying governmental body is
Did not become a U.S. resident only to
exempt from U.S. income tax. However, the ex
These exemptions do not apply to income or
perform the services.
emption does not apply to payments for serv
pensions for services performed in connection
ices performed in the United States by a resi
with a business carried on by Japan, its political
dent of the United States who either:
Pensions paid by or from the public funds of
subdivisions, or local authorities.
Is a U.S. national and not a national of
Lithuania, its political subdivisions, or local au
Italy, or
thorities for services performed for Lithuania are
Did not become a U.S. resident only to
Kazakhstan
exempt from U.S. income tax unless the recipi
perform the services.
ent is both a resident and citizen of the United
States.
Income, other than a pension, paid by Kazakh
The spouse and dependent children of an indi
stan, or its subdivisions or local authorities to an
vidual, however, are not subject to the second
individual for government services is exempt
Luxembourg
restriction if that individual is receiving exempt
from U.S. tax. However, the exemption does
income for governmental services performed
not apply if the services are performed in the
Income, other than a pension, paid by Luxem
for Italy and that individual does not come under
United States by a U.S. resident who either:
bourg, its political subdivisions, or local authori
either of the restrictions.
Is a U.S. citizen, or
ties to an individual for services performed for
Did not become a U.S. resident solely for
Pensions paid by Italy for services per
the paying governmental body is exempt from
the purpose of performing the services.
U.S. income tax. However, the exemption does
formed for Italy are exempt from U.S. income
not apply if the services are performed in the
tax unless the recipient is both a citizen and a
These exemptions do not apply to income for
United States by a resident of the United States
resident of the United States.
services performed in connection with a busi
who either:
ness.
These exemptions do not apply to income or
Is a U.S. citizen, or
pensions for services performed in connection
Did not become a U.S. resident only to
Pensions paid by Kazakhstan, or its subdivi
with a trade or business carried on by Italy or its
perform the services.
sions or local authorities for services performed
subdivisions or local authorities.
for Kazakhstan is exempt from U.S. tax unless
Pensions paid by Luxembourg, its political
the individual is both a resident and citizen of
subdivisions, or local authorities for services
the United States.
performed for Luxembourg are exempt from
Page 30
Publication 901 (September 2016)
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