Publication 901 - U.s. Tax Treaties - Internal Revenue Service Page 4
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34Their income is not borne by a permanent
aircraft operated in international traffic is
employees (dependent personal services) in
establishment that the employer has in the
exempt from U.S. income tax.
the United States is exempt from U.S. tax if:
United States.
The residents are present in the United
States for no more than 183 days in the
Canada
calendar year,
The exemption does not apply to directors'
The pay is paid by or for an employer who
fees and similar payments received by a resi
Income that residents of Canada receive for
is not a U.S. resident, and
dent of Belgium for services performed in the
personal services as independent contractors
The pay is not borne by a permanent es
United States as a member of the board of di
or selfemployed individuals is subject to the
tablishment or fixed base that the em
rectors of a company that is a resident of the
provisions of Article VII (Business Profits) of the
ployer has in the United States.
United States.
treaty. Under that provision, business profits are
exempt from U.S. income tax unless the individ
These exemptions do not apply to directors'
Public entertainers (such as theater, motion
ual has a permanent establishment in the Uni
fees for service on the board of directors of a
picture, radio, or television artists, musicians, or
ted States. If they have a permanent establish
U.S. corporation.
athletes) from Belgium who earn more than
ment in the United States, they are taxed on the
$20,000 in gross receipts, including reimbursed
profit attributable to the permanent establish
These exemptions generally do not apply to
expenses, from their entertainment activities in
ment. Under Article V (Permanent Establish
income received as a public entertainer (such
the United States during the tax year are sub
ment), you may be considered to provide serv
as a theater, motion picture, radio, or television
ject to U.S. tax.
ices through a permanent establishment in the
artist, musician, or athlete). However, income of
United States even if you do not have a fixed
athletes or public entertainers from China par
place of business.
Income received by a resident of Belgium
ticipating in a cultural exchange program
for services performed as an employee and
agreed upon by the U.S. and Chinese govern
member of the regular complement of a ship or
Income that residents of Canada receive for
ments is exempt from U.S. tax.
aircraft operated in international traffic is ex
personal services performed as employees (de
empt from U.S. income tax.
pendent personal services) in the United States
Commonwealth of
is exempt from U.S. tax if it is not more than
Independent States
Bulgaria
$10,000 for the year. If the income is more than
$10,000 for the year, it is exempt only if:
Income that residents of a C.I.S. member re
The residents are present in the United
Income that residents of Bulgaria receive for
ceive for performing personal services in the
States for no more than 183 days in any
personal services as independent contractors
United States is exempt from U.S. income tax if
12month period beginning or ending in the
or selfemployed individuals is subject to the
those residents are in the United States for no
tax year, and
provisions of Article 7 (Business Profits) of the
more than 183 days during the tax year.
The income is not paid by, or on behalf of,
treaty. Under that provision, business profits are
a U.S. resident, and is not borne by a per
exempt from U.S. income tax unless the individ
Pay received by an employee who is a
manent establishment in the United States.
ual has a permanent establishment in the Uni
member of the regular complement of a ship or
ted States. If they have a permanent establish
aircraft operated in international traffic by a
ment in the United States, they are taxed on the
Public entertainers (such as theater, motion
C.I.S. member or a resident of a C.I.S. member
profit attributable to the permanent establish
picture, radio, or television artists, musicians, or
is exempt from U.S. tax.
ment. Under Article 5 (Permanent Establish
athletes) from Canada who derive more than
ment), you may be considered to provide serv
$15,000 in gross receipts, including reimbursed
Cyprus
ices through a permanent establishment in the
expenses, from their entertainment activities in
United States even if you do not have a fixed
the United States during the calendar year are
place of business.
Income that residents of Cyprus receive for per
subject to U.S. tax. However, this article does
forming personal services as independent con
not apply to athletes participating in team sports
tractors or selfemployed individuals (independ
Income that residents of Bulgaria receive for
in leagues with regularly scheduled games in
ent personal services) in the United States
services performed in the United States as em
both Canada and the United States.
during the tax year is exempt from U.S. income
ployees (dependent personal services) is ex
tax if the residents:
empt from U.S. income tax if the residents meet
Pay received by a resident of Canada for
Are present in the United States for less
the following requirements.
employment regularly done in more than one
than 183 days in the tax year, and
They are in the United States for no more
country on a ship, aircraft, motor vehicle, or
Do not have a fixed base regularly availa
than 183 days in any 12month period be
train operated by a Canadian resident is ex
ble to them in the United States for per
ginning or ending in the tax year.
empt from U.S. tax.
forming the services.
Their income is paid by, or on behalf of, an
employer who is not a U.S. resident.
If they have a fixed base available in the United
China, People's Republic of
Their income is not borne by a permanent
States, they are taxable on the income attributa
establishment that the employer has in the
ble to the fixed base.
Income that residents of the People's Republic
United States.
of China receive for personal services as inde
Pay received by residents of Cyprus from
pendent contractors or selfemployed individu
The exemption does not apply to directors'
services performed as employees (dependent
als (independent personal services) that they
fees and similar payments received by a resi
personal services), including services as an offi
perform during the tax year in the United States
dent of Bulgaria as a member of the board of di
cer of a corporation, is exempt from U.S. in
is exempt from U.S. income tax if the residents:
rectors of a U.S. company.
come tax if:
Are present in the United States for no
The residents are in the United States for
more than 183 days in the calendar year,
Public entertainers (such as theater, motion
less than 183 days during the tax year,
and
picture, radio, or television artists, musicians, or
The pay is paid by or for an employer who
Do not have a fixed base regularly availa
athletes) from Bulgaria who earn more than
is not a U.S. resident, and
ble in the United States for performing the
$15,000 in gross receipts, including reimbursed
The pay is not borne by a permanent es
services.
expenses, from their entertainment activities in
tablishment, fixed base, or trade or busi
If they have a fixed base available in the United
the United States during the tax year are sub
ness that the employer has in the United
States, they are taxable on the income attributa
ject to U.S. tax.
States.
ble to the fixed base.
Income received by a resident of Bulgaria
Pay received by a Cyprus resident for per
Pay received by residents of the People's
for services performed as an employee and
forming personal services as an employee and
Republic of China for services performed as
member of the regular complement of a ship or
member of the regular complement of a ship or
Page 4
Publication 901 (September 2016)
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