Publication 901 - U.s. Tax Treaties - Internal Revenue Service Page 9
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34Luxembourg
States during the tax year is exempt from U.S.
resident of Latvia as a member of the board of
tax if the residents:
directors or similar body of a company that is a
Are in the United States for no more than
U.S. resident.
Income that residents of Luxembourg receive
182 days during the tax year,
for personal services as independent contrac
Earn income for those services that is not
tors or selfemployed individuals (independent
The exemptions do not apply to income resi
more than $3,000 during the tax year, and
personal services) in the United States is ex
dents of Latvia receive as public entertainers
Do not maintain a fixed base in the United
empt from U.S. income tax if they do not have a
(such as theater, motion picture, radio, or televi
States for more than 182 days during the
fixed base regularly available to them in the Uni
sion artists, or musicians) or sportsmen if their
tax year.
ted States for performing the services. If they
gross receipts, including reimbursed expenses,
have a fixed base available in the United
are more than $20,000 for their personal activi
If they maintain a fixed base in the United
States, they are taxed on the income attributa
ties in the United States during the tax year. Re
States for more than 182 days, they are taxed
ble to the fixed base.
gardless of these limits, income of Latvian en
on the income attributable to the fixed base.
tertainers or athletes is exempt from U.S.
income tax if their visit to the United States is
Income that residents of Luxembourg re
Income that residents of Korea receive for
wholly or mainly supported by public funds of
ceive for services performed in the United
labor or personal services performed in the Uni
Latvia, its political subdivisions, or local authori
States as employees (dependent personal
ted States as employees (dependent personal
ties.
services) is exempt from U.S. income tax if the
services), including pay for services performed
residents meet the following requirements.
as an officer of a corporation, is exempt from
Lithuania
They are in the United States for no more
U.S. tax if the residents meet four requirements.
than 183 days in any 12month period be
They are in the United States for no more
ginning or ending in the tax year.
Income that residents of Lithuania receive for
than 182 days during the tax year.
Their income is paid by, or on behalf of, an
performing personal services as independent
They are employees of a resident of Korea
employer who is not a U.S. resident.
contractors or selfemployed individuals (inde
or of a permanent establishment main
Their income is not borne by a permanent
pendent personal services) in the United States
tained in Korea.
establishment or a fixed base that the em
is exempt from U.S. income tax if the residents:
Their compensation is not borne by a per
ployer has in the United States.
Are in the United States for no more than
manent establishment that the employer
183 days in any 12month period begin
has in the United States.
ning or ending in the tax year, and
The exemption does not apply to pay re
Their income for those services is not more
Do not have a fixed base regularly availa
ceived for employment exercised continuously
than $3,000.
ble to them in the United States for per
or predominantly aboard a ship or aircraft oper
forming the services.
ated in international traffic by a U.S. enterprise.
Pay received by employees who are mem
bers of the regular complement of a ship or air
If they have a fixed base available, they are
craft operated by a resident of Korea in interna
The exemptions do not apply to directors'
taxed only on the income attributable to the
tional traffic is exempt.
fees and similar payments received by a resi
fixed base.
dent of Luxembourg for services performed in
Latvia
the United States as a member of the board of
Income that residents of Lithuania receive
directors of a company that is a resident of the
for services performed in the United States as
United States.
Income that residents of Latvia receive for per
employees (dependent personal services) is
forming personal services as independent con
exempt from U.S. income tax if the following re
tractors or selfemployed individuals (independ
The exemptions do not apply to public en
quirements are met.
ent personal services) in the United States is
tertainers (such as theater, motion picture, ra
The resident is in the United States for no
exempt from U.S. income tax if the residents:
dio, or television artists, musicians, or athletes)
more than 183 days in any 12month pe
Are in the United States for no more than
from Luxembourg who earn more than $10,000
riod beginning or ending in the tax year.
183 days in any 12month period begin
in gross receipts, including reimbursed expen
The income is paid by, or on behalf of, an
ning or ending in the tax year, and
ses, from their entertainment activities in the
employer who is not a U.S. resident.
Do not have a fixed base regularly availa
United States during the tax year.
The income is not borne by a permanent
ble to them in the United States for per
establishment or a fixed base that the em
forming the services.
Malta
ployer has in the United States.
If they have a fixed base available, they are
The exemption does not apply to pay re
Income that residents of Malta receive for per
taxed only on the income attributable to the
ceived for employment as a member of the reg
sonal services as independent contractors or
fixed base.
ular complement of a ship or an aircraft oper
selfemployed individuals is subject to the provi
ated in international traffic by a U.S. enterprise.
sions of Article 7 (Business Profits) of the treaty.
Income that residents of Latvia receive for
Under that provision, business profits are ex
services performed in the United States as em
empt from U.S. income tax unless the individual
The exemptions do not apply to directors'
ployees (dependent personal services) is ex
has a permanent establishment in the United
fees and similar payments received by a resi
empt from U.S. income tax if the following re
States. If they have a permanent establishment
dent of Lithuania as a member of the board of
quirements are met.
in the United States, they are taxed on the prof
directors or similar body of a company that is a
The resident is in the United States for no
its attributable to the permanent establishment.
U.S. resident.
more than 183 days in any 12month pe
riod beginning or ending in the tax year.
The income is paid by, or on behalf of, an
The exemptions do not apply to income resi
Income that residents of Malta receive for
employer who is not a U.S. resident.
dents of Lithuania receive as public entertainers
services performed in the United States as em
The income is not borne by a permanent
(such as theater, motion picture, radio, or televi
ployees (dependent personal services) is ex
establishment or a fixed base that the em
sion artists, or musicians) or sportsmen if their
empt from U.S. income tax if the residents meet
ployer has in the United States.
gross receipts, including reimbursed expenses,
the following requirements.
are more than $20,000 for their personal activi
They are in the United States for no more
The exemption does not apply to pay re
ties in the United States during the tax year. Re
than 183 days in any 12month period be
ceived for employment as a member of the reg
gardless of these limits, income of Lithuanian
ginning or ending in the tax year.
ular complement of a ship or an aircraft oper
entertainers or athletes is exempt from U.S. in
Their income is paid by, or on behalf of, an
ated in international traffic by a U.S. enterprise.
come tax if their visit to the United States is
employer who is not a U.S. resident.
wholly or mainly supported by public funds of
Their income is not borne by a permanent
The exemptions do not apply to directors'
Lithuania, its political subdivisions, or local au
establishment that the employer has in the
fees and similar payments received by a
thorities.
United States.
Publication 901 (September 2016)
Page 9
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