Publication 901 - U.s. Tax Treaties - Internal Revenue Service Page 7
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34exempt from U.S. income tax if the residents
These exemptions do not apply to income
selfemployed individuals (independent per
meet the following requirements.
residents of India receive as public entertainers
sonal services) in the United States is exempt
They are in the United States for no more
(such as theater, motion picture, radio, or televi
from U.S. income tax if they do not have a fixed
than 183 days in any 12month period be
sion artists, or musicians) or athletes if their net
base regularly available to them in the United
ginning or ending in the tax year.
income is more than $1,500 during the tax year
States for performing the services. If they have
Their income is paid by, or on behalf of, an
for their entertainment activities in the United
a fixed base available in the United States, they
employer who is not a U.S. resident.
States. Regardless of this limit, the income of
are taxed on the income attributable to the fixed
Their income is not borne by a permanent
Indian entertainers and athletes is exempt from
base.
establishment that the employer has in the
U.S. tax if their visit to the United States is
United States.
wholly or substantially supported from the pub
Income that residents of Ireland receive for
lic funds of the Indian Government, its political
services performed in the United States as em
subdivisions, or local authorities.
ployees (dependent personal services) is ex
The exemption does not apply to directors'
empt from U.S. income tax if the residents meet
fees and similar payments received by a resi
the following requirements.
dent of Iceland as a member of the board of di
Indonesia
They are in the United States for no more
rectors of a U.S. company.
than 183 days in any 12month period be
Income that residents of Indonesia receive for
ginning or ending in the tax year.
Public entertainers (such as theater, motion
performing personal services as individual con
Their income is paid by, or on behalf of, an
picture, radio, or television artists, musicians, or
tractors or selfemployed individuals (independ
employer who is not a U.S. resident.
athletes) from Iceland who earn more than
ent personal services) in the United States dur
Their income is not borne by a permanent
$20,000 in gross receipts, including reimbursed
ing the tax year is exempt from U.S. income tax
establishment or a fixed base that the em
expenses, from their entertainment activities in
if the residents:
ployer has in the United States.
the United States during the tax year are sub
Are present in the United States for no
ject to U.S. tax.
more than 119 days during any consecu
These exemptions do not apply to directors'
tive 12month period, and
fees and similar payments received by a resi
Do not have a fixed base regularly availa
Income received by a resident of Iceland for
dent of Ireland as a member of the board of di
ble to them in the United States for per
services performed as an employee and mem
rectors of a company that is a resident of the
forming the services.
ber of the regular complement of a ship or air
United States. However, amounts received for
craft operated in international traffic is exempt
attending meetings in Ireland are not subject to
from U.S. income tax.
If they have a fixed base available, they are
U.S. income tax.
taxed only on the income attributable to the
fixed base.
India
Income received by a resident of Ireland for
services performed as an employee and mem
Income that residents of Indonesia receive
Income that residents of India receive for per
ber of the regular complement of a ship or air
for personal services performed in the United
forming personal services in the United States
craft operated in international traffic is exempt
States as employees (dependent personal
during the tax year as independent contractors
from U.S. income tax.
services) is exempt from U.S. income tax if the
or selfemployed individuals (independent per
residents meet three requirements.
sonal services) is exempt from U.S. income tax
These exemptions do not apply to public en
They are present in the United States no
if the residents:
tertainers (such as theater, motion picture, ra
more than 119 days during any consecu
Are present in the United States for no
dio, or television entertainers, musicians, and
tive 12month period.
more than 89 days during the tax year, and
athletes) from Ireland who earn more than
The income is paid by, or on behalf of, an
Do not have a fixed base regularly availa
$20,000 in gross receipts, including reimbursed
employer who is not a resident of the Uni
ble to them in the United States for per
expenses, from their entertainment activities in
ted States.
forming the services.
the United States during the tax year.
The income is not borne or reimbursed by
a permanent establishment the employer
If they have a fixed base available, they are
Israel
has in the United States.
taxed only on income attributable to the fixed
base.
Income that residents of Israel receive for per
Pay received by an individual for services
forming personal services as independent con
performed as an employee aboard a ship or air
Income that residents of India receive for
tractors or as selfemployed individuals (inde
craft operated by an Indonesian resident in in
personal services performed in the United
pendent personal services) in the United States
ternational traffic is exempt from U.S. tax if the
States as employees (dependent personal
during the tax year is exempt from U.S. income
individual is a member of the regular comple
services) is exempt from U.S. income tax if the
tax if they are in the United States for no more
ment of the ship or aircraft.
residents meet three requirements.
than 182 days during the tax year.
They are present in the United States for
no more than 183 days during the tax year.
These exemptions do not apply to income
Income that residents of Israel receive for la
The income is paid by, or on behalf of, an
residents of Indonesia receive as public enter
bor or personal services performed in the Uni
employer who is not a resident of the Uni
tainers (such as theater, motion picture, radio,
ted States as employees (dependent personal
ted States.
or television artists, or musicians) or athletes if
services), including income for services per
The income is not borne by a permanent
their gross receipts, including reimbursed ex
formed by an officer of a corporation or com
establishment, fixed base, or trade or busi
penses, are more than $2,000 during any con
pany, is exempt from U.S. income tax if the resi
ness the employer has in the United
secutive 12month period. Regardless of these
dents meet four requirements.
States.
limits, income of Indonesian entertainers and
They are in the United States for no more
athletes is exempt from U.S. tax if their visit to
than 182 days during the tax year.
the United States is substantially supported or
The exemption does not apply to pay re
They are employees of a resident of, or a
sponsored by the Indonesian Government and
ceived by a resident of India for services per
permanent establishment in, Israel.
the Indonesian competent authority certifies
formed as an employee aboard a ship or aircraft
Their income is not borne by a permanent
that the entertainers or athletes qualify for this
operated in international traffic by a U.S. enter
establishment that the employer has in the
exemption.
prise.
United States.
Their income is subject to Israeli tax.
Ireland
These exemptions do not apply to directors'
fees and similar payments received by an In
The exemption does not apply to pay re
dian resident as a member of the board of di
Income that residents of Ireland receive for per
ceived by an employee for labor or personal
rectors of a company that is a U.S. resident.
sonal services as independent contractors or
services performed as a member of the regular
Publication 901 (September 2016)
Page 7
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