Publication 901 - U.s. Tax Treaties - Internal Revenue Service Page 5
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34aircraft operated in international traffic by a resi
Income from employment as a member of
They are employees of a resident of, or a
dent of Cyprus is exempt from U.S. tax.
the regular complement of a ship or aircraft op
permanent establishment in, Egypt.
erated by a Czech enterprise in international
Their income is not borne by a permanent
traffic is exempt from U.S. income tax. If the
establishment that the employer has in the
These exemptions do not apply to Cyprus
ship or aircraft is operated by a U.S. enterprise,
United States.
resident public entertainers (theater, motion pic
the income is subject to U.S. tax.
Their income is subject to Egyptian tax.
ture, radio, or television artists, musicians, or
athletes) who receive gross receipts of more
This exemption does not apply to pay re
Denmark
than $500 per day or $5,000 for the tax year,
ceived by a resident of Egypt who is an em
not including reimbursed expenses, from their
ployee and member of the regular complement
entertainment activities in the United States.
Income that residents of Denmark receive for
of a ship or an aircraft operated in international
personal services as independent contractors
traffic by a resident of the United States.
or selfemployed individuals (independent per
Directors' fees received by residents of Cy
sonal services) in the United States is exempt
prus for service on the board of directors of a
These exemptions do not apply to Egyptian
from U.S. income tax if they do not have a fixed
U.S. corporation are exempt from U.S. income
resident public entertainers (theater, motion pic
base regularly available to them in the United
tax to the extent of a reasonable fixed amount
ture, radio, or television artists, musicians, or
States for performing the services. If they have
payable to all directors for each day of attend
athletes), who earn income for services as pub
a fixed base available in the United States, they
ance at directors' meetings held in the United
lic entertainers if the gross amount of the in
are taxed on the income attributable to the fixed
States.
come is more than $400 for each day they are
base.
in the United States performing the services.
Czech Republic
Income that residents of Denmark receive
Estonia
for services performed in the United States as
Income that residents of the Czech Republic re
employees (dependent personal services) is
ceive for performing personal services as inde
exempt from U.S. income tax if the residents
Income that residents of Estonia receive for per
pendent contractors or selfemployed individu
meet the following requirements.
forming personal services as independent con
als (independent personal services) in the
They are in the United States for no more
tractors or selfemployed individuals (independ
United States is exempt from U.S. income tax if
than 183 days in any 12month period be
ent personal services) in the United States is
the residents:
ginning or ending in the tax year.
exempt from U.S. income tax if the residents:
Are present in the United States for no
Their income is paid by, or on behalf of, an
Are in the United States for no more than
more than 183 days in any 12month pe
employer who is not a U.S. resident.
183 days in any 12month period begin
riod, and
Their income is not borne by a permanent
ning or ending in the tax year, and
Do not have a fixed base regularly availa
establishment or a fixed base that the em
Do not have a fixed base regularly availa
ble to them in the United States for per
ployer has in the United States.
ble to them in the United States for per
forming the services.
forming the services.
If they have a fixed base available, they are
These exemptions do not apply to directors'
If they have a fixed base available, they are
taxed only on income attributable to the fixed
fees and similar payments received by a resi
taxed on the income attributable to the fixed
base.
dent of Denmark as a member of the board of
base.
directors of a company that is a resident of the
Income that residents of the Czech Republic
United States.
Income that residents of Estonia receive for
receive for employment in the United States
services performed in the United States as em
(dependent personal services) is exempt from
These exemptions do not apply to public en
ployees (dependent personal services) is ex
U.S. income tax if the following three require
tertainers (such as theater, motion picture, ra
empt from U.S. income tax if the following re
ments are met.
dio, or television artists, musicians, and ath
quirements are met.
The resident is present in the United
letes) from Denmark who earn more than
The resident is in the United States for no
States for no more than 183 days in any
$20,000 in gross receipts, including reimbursed
more than 183 days in any 12month pe
12month period.
expenses, from their entertainment activities in
riod beginning or ending in the tax year.
The income is paid by, or on behalf of, an
the United States during the tax year.
The income is paid by, or on behalf of, an
employer who is not a U.S. resident.
employer who is not a U.S. resident.
The income is not borne by a permanent
Income received by a resident of Denmark
The income is not borne by a permanent
establishment or a fixed base that the em
for services performed as an employee and
establishment or a fixed base that the em
ployer has in the United States.
member of the regular complement of a ship or
ployer has in the United States.
aircraft operated in international traffic is ex
These exemptions do not apply to income
empt from U.S. income tax.
These exemptions do not apply to directors'
residents of the Czech Republic receive as pub
fees and similar payments received by a resi
lic entertainers (such as theater, motion picture,
Egypt
dent of Estonia as a member of the board of di
radio, or television artists, or musicians) or
rectors or similar body of a company that is a
sportsmen if their gross receipts, including re
Income that residents of Egypt receive for per
U.S. resident.
imbursed expenses, are more than $20,000
forming personal services as independent con
during the tax year. Regardless of these limits,
tractors or as selfemployed individuals (inde
Pay received for employment as a member
income of Czech entertainers and sportsmen is
pendent personal services) in the United States
of the regular complement of a ship or an air
exempt from U.S. income tax if their visit to the
during the tax year is exempt from U.S. income
craft operated in international traffic by a United
United States is substantially supported by pub
tax if they are in the United States for no more
States enterprise is subject to U.S. tax.
lic funds of the Czech Republic, its political sub
than 89 days during the tax year.
divisions, or local authorities, or the visit is
These exemptions do not apply to income
made pursuant to a specific arrangement be
Income that residents of Egypt receive for
residents of Estonia receive as public entertain
tween the United States and the Czech Repub
labor or personal services performed in the Uni
ers (such as theater, motion picture, radio, or
lic.
ted States as employees (dependent personal
television artists, or musicians) or sportsmen if
services), including income for services per
their gross receipts, including reimbursed ex
These exemptions do not apply to directors'
formed by an officer of a corporation or com
penses, are more than $20,000 for their per
fees and similar payments received by a resi
pany, is exempt from U.S. income tax if the resi
sonal activities in the United States during the
dent of the Czech Republic as a member of the
dents meet four requirements.
tax year. Regardless of these limits, income of
board of directors of a company that is a resi
They are in the United States for no more
Estonian entertainers or athletes is exempt from
dent of the United States.
than 89 days during the tax year.
U.S. income tax if their visit to the United States
Publication 901 (September 2016)
Page 5
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