Publication 901 - U.s. Tax Treaties - Internal Revenue Service Page 8
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34complement of a ship or an aircraft operated in
Earn net income for those services that is
Their income is not borne by a permanent
international traffic by a U.S. resident.
not more than $5,000 during the tax year if
establishment that the employer has in the
the income is from a U.S. contractor.
United States.
These exemptions do not apply to income
If they have a fixed base available in the United
The exemption does not apply to directors'
that residents of Israel receive as public enter
States, they are taxed only on the income that is
fees and similar payments received by a resi
tainers (such as theater, motion picture, radio,
attributable to the fixed base. There is no dollar
dent of Japan for services performed as a mem
or television artists, musicians, or athletes), if
limit for condition (3) if the contractor is from a
ber of the board of directors of a company that
the gross amount of the income is more than
country other than the United States.
is a resident of the United States.
$400 for each day they are in the United States
performing the services.
Income that residents of Jamaica receive for
The exemption does not apply to a resident
personal services performed in the United
Italy
of Japan who performs services as an em
States as employees (dependent personal
ployee aboard a ship or an aircraft operated in
services) is exempt from U.S. income tax if the
international traffic by a U.S. resident.
residents meet four requirements.
Income that residents of Italy receive for per
They are in the United States for no more
sonal services as independent contractors or
than 183 days during the tax year.
selfemployed individuals (independent per
Public entertainers (such as theater, motion
Their income is paid by or for an employer
sonal services) in the United States is exempt
picture, radio, or television artists, musicians, or
who is not a resident of the United States.
from U.S. income tax if they do not have a fixed
athletes) from Japan who earn more than
Their income is not borne by a permanent
base regularly available to them in the United
$10,000 in gross receipts, including reimbursed
establishment or a fixed base that the em
States for performing the services. If they have
expenses, from their entertainment activities in
a fixed base available in the United States, they
ployer has in the United States.
the United States during the tax year are sub
are taxed on the income attributable to the fixed
Their net income received for the services
ject to U.S. tax.
base.
is not more than $5,000 during the tax
year.
Kazakhstan
Income that residents of Italy receive for la
Pay received from employment as a mem
bor or personal services performed in the Uni
Income that residents of Kazakhstan receive for
ber of the regular complement of a ship or an
ted States as employees (dependent personal
performing personal services as independent
aircraft operated in international traffic by a Ja
services) is exempt from U.S. income tax if the
contractors or selfemployed individuals (inde
maican enterprise is exempt from U.S. tax. If
following requirements are met.
pendent personal services) in the United States
the ship or aircraft is operated by a U.S. enter
The residents are in the United States for
is exempt from U.S. income tax if:
prise, the pay is subject to U.S. tax.
no more than 183 days during the tax year.
The residents are in the United States for
The income is paid by, or on behalf of, an
no more than 183 days in any consecutive
These exemptions do not apply to income
employer who is not a resident of the Uni
12month period, and
that residents of Jamaica receive for performing
ted States.
The income is not attributable to a fixed
services in the United States as entertainers,
The income is not borne by a permanent
base in the United States which is regularly
such as theater, motion picture, radio, or televi
establishment or a fixed base that the em
available to the residents.
sion artists, musicians, or athletes, if the gross
ployer has in the United States.
If the residents have a fixed base available, they
receipts (excluding reimbursements for expen
are taxed only on the income attributable to the
ses) from the services are more than $400 a
These exemptions do not apply to directors'
fixed base.
day or $5,000 for the tax year.
fees and similar payments received by a resi
dent of Italy for services performed in the United
Income that residents of Kazakhstan receive
Directors' fees received by residents of Ja
States as a member of the board of directors of
for employment in the United States (depend
maica for services performed in the United
a company that is a U.S. resident.
ent personal services) is exempt from U.S. in
States as members of boards of directors of
come tax if the following three requirements are
U.S. corporations are exempt from U.S. tax if
Pay received for employment regularly exer
met.
the fees (excluding reimbursed expenses) are
cised aboard a ship or aircraft operated by a
The resident is in the United States for no
not more than $400 per day for each day the di
U.S. enterprise is subject to U.S. tax.
more than 183 days in any 12month pe
rectors are present in the United States to per
riod.
form the services.
The income is paid by, or on behalf of, an
These exemptions do not apply to income
employer who is not a resident of the Uni
residents of Italy receive as public entertainers
Japan
ted States.
(such as theater, motion picture, radio, or televi
The income is not borne by a permanent
sion artists, musicians, or athletes) if they are
Income that residents of Japan receive for per
establishment or a fixed base that the em
present in the United States for more than 90
sonal services as independent contractors or
ployer has in the United States.
days during the tax year or their gross receipts,
selfemployed individuals is subject to the provi
including reimbursed expenses, are more than
sions of Article 7 (business profits) of the treaty.
$20,000 during the tax year for their entertain
Income derived by a resident of Kazakhstan
Under that provision, business profits are ex
ment activities in the United States.
from employment as a member of the regular
empt from U.S. income tax unless the individual
complement of a ship or aircraft operated in in
has a permanent establishment in the United
Jamaica
ternational traffic is exempt from U.S. tax.
States. If they have a permanent establishment
in the United States, they are taxed on the prof
Income that residents of Jamaica receive for
These exemptions do not apply to directors'
its attributable to the permanent establishment.
the performance of personal services as inde
fees and similar payments received by a resi
pendent contractors or selfemployed individu
dent of Kazakhstan as a member of the board
Income that residents of Japan receive for
als (independent personal services) in the Uni
of directors or similar body of a company that is
services performed in the United States as em
ted States during the tax year is exempt from
a U.S. resident.
ployees (dependent personal services) is ex
U.S. income tax if the residents:
empt from U.S. income tax if the residents meet
Are in the United States for no more than
Korea, South
the following requirements.
89 days during the tax year,
They are in the United States for no more
Do not have a fixed base regularly availa
than 183 days in any 12month period be
Income that residents of South Korea receive
ble to them in the United States for per
ginning or ending in the tax year.
for performing personal services as independ
forming their services, and
Their income is paid by, or on behalf of, an
ent contractors or selfemployed individuals (in
employer who is not a U.S. resident.
dependent personal services) in the United
Page 8
Publication 901 (September 2016)
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