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IRS Pub 901: USA Tax Treaties

IRS Pub 901: USA Tax Treaties

This page contains excerpts from IRS Publication 901 US Tax Treaties(November 1995 Revision). Pages 14-21 of this publication provide information of interest to foreign students. This document has been prepared as a public service, and may be missing sections from the original. All sections of this publication that are not directly relevant to the topic of student financial aid have been omitted, so we strongly suggest that you refer to the original publication for official information. It is not intended to act as a substitute for the official version available from the IRS, but rather to provide a convenient online reference. The information on this page is not guaranteed to be correct. It has not been reviewed or approved by the IRS, so we strongly suggest that you refer to the original publication for official information. To order IRS publications and forms, call 1-800-TAX-FORM (1-800-829-3676) or visit the IRS web site.

Introduction

The USA (USA) has income tax treaties (conventions) with a number of foreign countries. Under these treaties, residents of foreign countries are taxed at a reduced rate, or are exempt from USA income taxes on certain items of income they receive from sources within the USA. These reduced rates and exemptions vary among countries and specific items of income.

This publication will tell you whether a tax treaty between the USA and a particular country offers a reduced rate of, or possibly a complete exemption from, USA income tax for residents of that particular country.

You should use this publication only for quick reference. It is not a complete guide to all provisions of every income tax treaty.

If the treaty does not cover a particular kind of income, or if there is no treaty between your country and the USA, you must pay tax on the income in the same way and at the same rates shown in the instructions for Form 1040NR. Also see Publication 519, USA Tax Guide for Aliens.

Tax treaties reduce the USA taxes of residents of foreign countries. With certain exceptions, they do not reduce the USA taxes of USA citizens or residents. USA citizens and residents are subject to USA income tax on their worldwide income.

Many of the individual states of the USA tax the income of their residents. Therefore, you should consult the tax authorities of the state in which you live to find out if that state taxes the income of individuals and, if so, whether the tax applies to any of your income.

Disclosure of a treaty-based position that reduces your tax

If you take the position that any USA tax is overruled or otherwise reduced by a USA treaty (a treaty-based position), you generally must disclose that position on Form 8833, Treaty-Based Return Position Disclosure Under Section 6114 or 7701(b), and attach it to your return. If you are not required to file a return because of your treaty-based position, you must file a return anyway to report your position. The filing of Form 8833 does not apply to a reduced rate of withholding tax on noneffectively connected income, such as dividends, interest, rents or royalties, or to a reduced rate of tax on pay received for services performed as an employee, including pensions, annuities, and social security. For more information, get Publication 519, USA Tax Guide for Aliens.

If you fail to file Form 8833, you may have to pay a $1,000 penalty. Corporations are subject to a $10,000 penalty for each failure.

Tax Exemptions Provided by Treaties

This publication contains discussions of the exemptions from tax and certain other effects of the tax treaties on the following types of income:

Students and Apprentices

Residents of the following countries who are in the USA to study or acquire technical experience are exempt from USA income tax, under certain conditions, on amounts received from abroad for their maintenance and studies.

This exemption does not apply to the salary paid by a foreign corporation to one of its executives, a citizen and resident of a foreign country who is temporarily in the USA to study a particular industry for an employer. That amount is a continuation of salary and is not received to study or acquire experience.

For each country listed there is a statement of the conditions under which the exemption applies to students and apprentices from that country.

Amounts received from the National Institutes of Health (NIH) under provisions of the Visiting Fellows Program by residents of the following countries are exempt from USA income tax to the extent provided for in the respective countries’ current tax treaties with the USA: Belgium, China, Cyprus, the Czech Republic, Egypt, France, Iceland, Indonesia, Japan, Korea, Morocco, the Netherlands, Norway, Pakistan, the Philippines, Poland, Romania, Russia, the Slovak Republic, Spain, Trinidad and Tobago, and Tunisia.

However, amounts received from NIH under the Visiting Associate Program and Visiting Scientist Program are not exempt from USA tax as a grant, allowance, or award.

Australia

A resident of Australia or an individual who was a resident of Australia immediately before visiting the USA who is temporarily here for full-time education is exempt from USA income tax on payments received from outside the USA for the individual’s maintenance or education.

Austria

A resident of Austria who is temporarily in the USA only as a student at a university, college, school, or other educational institution is exempt from USA income tax on amounts received from abroad for study and maintenance. An apprentice (including Volontaere and Praktikanten) who is a resident of Austria and is temporarily in the USA only to acquire business or technical experience is also exempt from USA income tax on amounts received from abroad for study and maintenance.

A resident of Austria who receives a grant, allowance, or award from a nonprofit religious, scientific, literary, or educational organization is exempt from USA income tax on the payments from that organization. Pay for personal services is not exempt.

A resident of Austria who is an employee of an Austrian enterprise, or an organization of the kind mentioned in the preceding paragraph, is exempt from USA income tax on pay from abroad paid by that enterprise or organization if:

Barbados

A student or business apprentice who is a resident of Barbados on the date of arrival in the USA and is here for full-time education or training is exempt from USA income tax on payments received from outside the USA for the individual’s maintenance, education, or training.

Nevertheless, an individual who qualifies for this exemption may instead choose to be treated as a resident alien of the USA for all USA income tax purposes. Once made, this choice applies for the entire period that the individual remains qualified for exemption and may not be revoked without the permission of the USA competent authority.

Belgium

An individual who is a resident of Belgium on the date of arrival in the USA and who is temporarily in the USA primarily to study at a university or other recognized educational institution in the USA, obtain professional training, or study or do research as a recipient of a grant, allowance, or award from a governmental, religious, charitable, scientific, literary, or educational organization is exempt from USA income tax on the following amounts:

An individual is entitled to the benefit of this exemption for a maximum of 5 years.

An individual who is a resident of Belgium on the date of arrival in the USA and who is in the USA as an employee of, or under contract with, a resident of Belgium is exempt from USA income tax for a period of 12 consecutive months on up to $5,000 received for personal services if the individual is in the USA primarily to:

An individual who is a resident of Belgium on the date of arrival in the USA and who is temporarily present in the USA for not longer than one year as a participant in a program sponsored by the USA Government primarily to train, research, or study is exempt from USA income tax on income received for personal services for the training, research, or study in the amount of $10,000.

Canada

A full-time student, trainee, or business apprentice who is or was a Canadian resident immediately before visiting the USA is exempt from USA income tax on amounts received from sources outside the USA for maintenance, education, or training.

Also see Publication 597, Information on the USA-Canada Income Tax Treaty.

China, People’s Republic of

A student, business apprentice, or trainee who is a resident of the People’s Republic of China on the date of arrival in the USA and who is present in the USA solely to obtain training, education, or special technical experience is exempt from USA income tax on the following amounts:

An individual is entitled to this exemption only for the time reasonably necessary to complete the education or training.

Commonwealth of Independent States

An individual who is a resident of a C.I.S. member and who is temporarily in the USA primarily to study at an educational or scientific research institution or to obtain training for qualification in a profession or specialty is exempt from USA income tax on amounts received as stipends, scholarships, or other substitute allowances necessary to provide ordinary living expenses. An individual is entitled to the benefit of this exemption for a maximum of 5 years and for less than $10,000 in each tax year.

An individual who is a resident of a C.I.S. member and who is temporarily in the USA primarily to acquire technical, professional, or commercial experience or perform technical services and who is an employee of, or under contract with, a resident of a C.I.S. member is exempt from USA income tax on the amounts received from that resident. Also exempt is an amount received from USA sources, of not more than $10,000, that is necessary to provide for ordinary living expenses. The exemption contained in this paragraph is limited to one year.

An individual who is a resident of a C.I.S. member and who is temporarily present in the USA under an exchange program provided for by an agreement between governments on cooperation in various fields of science and technology is exempt from USA income tax on all income received in connection with the exchange program for a period not longer than one year.

Cyprus

An individual who is a resident of Cyprus on the date of arrival in the USA and who is temporarily here primarily to study at a university or other recognized educational institution in the USA, obtain professional training, or study or do research as a recipient of a grant, allowance, or award from a governmental, religious, charitable, scientific, literary, or educational organization is exempt from USA income tax on the following amounts:

An individual is entitled to this exemption for up to 5 tax years and for an additional period as is necessary to complete, as a full-time student, educational requirements for a postgraduate or professional degree from a recognized educational institution.

An individual who is a resident of Cyprus on the date of arrival in the USA and who is temporarily here as an employee of, or under contract with, a resident of Cyprus is exempt from USA income tax for not more than one year on income from personal services for a maximum of $7,500 if the individual is in the USA primarily to either:

An individual who is a resident of Cyprus on the date of arrival in the USA and who is temporarily here for a period of not more than one year as a participant in a program sponsored by the USA Government primarily to train, research, or study is exempt from USA income tax on income for personal services for the training, research, or study. This exemption is limited to $10,000.

Czech Republic

An individual who is a resident of the Czech Republic at the beginning of his or her visit to the USA and who is temporarily present in the USA is exempt from USA income tax on certain amounts for a period of up to 5 years. To be entitled to the exemption, the individual must be in the USA for the primary purpose of:

If the individual meets any of these requirements, the following amounts are exempt from USA tax:

An individual who is a Czech resident at the beginning of the visit to the USA and who is temporarily present in the USA as an employee of, or under contract with, a Czech resident is exempt from USA income tax for a period of 12 consecutive months on up to $8,000 received for personal services if the individual is in the USA primarily to:

An individual who is a Czech resident at the time he or she becomes temporarily present in the USA and who is temporarily present in the USA for a period not longer than 1 year as a participant in a program sponsored by the USA government for the primary purpose of training, research, or study, is exempt from USA income tax on up to $10,000 of income from personal services for that training, research, or study.

These exemptions do not apply to income from research undertaken primarily for the private benefit of a specific person or persons.

Denmark

A student or apprentice who is a citizen of Denmark and lives in the USA only to study or acquire business experience is exempt from USA income tax on amounts (other than the student’s own income) received from abroad for maintenance and studies.

Egypt

An individual who is a resident of Egypt on the date of arrival in the USA and who is temporarily in the USA primarily to study at a university or other recognized educational institution in the USA, obtain professional training, or study or do research as a recipient of a grant, allowance, or award from a governmental, religious, charitable, scientific, literary, or educational organization is exempt from USA income tax on the following amounts:

An individual is entitled to the benefit of this exemption for a maximum of 5 tax years and for any additional period of time needed to complete, as a full-time student, educational requirements as a candidate for a postgraduate or professional degree from a recognized educational institution.

An individual who is a resident of Egypt on the date of arrival in the USA and who is temporarily in the USA as an employee of, or under contract with, a resident of Egypt is exempt from USA income tax for a period of 12 consecutive months on up to $7,500 received for personal services if the individual is in the USA primarily to:

An individual who is a resident of Egypt on the date of arrival in the USA and who is temporarily in the USA for no more than one year as a participant in a program sponsored by the USA Government primarily to train, research, or study is exempt from USA income tax on income received for personal services for the training, research, or study for a maximum of $10,000.

Finland

A full-time student, trainee, or business apprentice who is a resident of Finland immediately before visiting the USA is exempt from USA income tax on amounts received from sources outside the USA for maintenance, education, or training.

France

An individual who is a resident of France on the date of arrival in the USA and who is temporarily in the USA primarily to study at a university or other accredited educational institution in the USA, obtain professional training, or study, or do research as a recipient of a grant, allowance, or award from a governmental, religious, charitable, scientific, literary, or educational organization is exempt from USA income tax on the following amounts:

An individual is entitled to the benefit of this exemption for a maximum of 5 tax years.

An individual who is a resident of France on the date of arrival in the USA and who is in the USA as an employee of, or under contract with, a resident of France is exempt from USA income tax for one tax year on up to $5,000 received for personal services if the individual is in the USA primarily to:

Germany

A student or business apprentice (including Volontaere and Praktikanten) who is or was immediately before visiting the USA a resident of Germany and who is present in the USA for full-time education or training is exempt from USA income tax on amounts from sources outside the USA for maintenance, education, or training.

An individual who is or was immediately before visiting the USA a resident of Germany is exempt from USA tax on amounts received as a grant, allowance, or award from a nonprofit religious, charitable, scientific, literary, or educational organization.

Individuals described in the previous two paragraphs are also exempt from USA tax on compensation for dependent personal services of up to $5,000 per year if:

If the individual’s visit exceeds 4 years, the exemption is lost for the entire visit unless the competent authorities of Germany and the USA agree otherwise.

An individual who is a resident of Germany and who is employed by a German enterprise or by a nonprofit religious, charitable, scientific, literary, or educational organization is exempt from USA tax on compensation paid by the employer from outside the USA if:

If the compensation is more than $10,000, none of the income is exempt.

Greece

A student or business apprentice who is a resident of Greece and is temporarily in the USA only to study or acquire business experience is exempt from USA income tax on amounts received from sources outside the USA for maintenance or studies.

Hungary

An individual who is a resident of Hungary immediately before arrival in the USA and is here for full-time education or training is exempt from USA income tax on payments received from outside the USA for the individual’s maintenance, education, or training.

The full-time student or trainee may instead choose to be treated as a resident alien of the USA for USA income tax purposes. Once made, the choice applies for the entire period that the individual remains qualified for exemption as a full-time student or trainee and may not be changed unless permission is obtained from the USA competent authority.

Iceland

An individual who is a resident of Iceland on the date of arrival in the USA and who is temporarily in the USA primarily to study at a university or other recognized educational institution in the USA, obtain professional training, or study or do research as a recipient of a grant, allowance, or award from a governmental, religious, charitable, scientific, literary, or educational organization is exempt from USA income tax on the following amounts:

An individual is entitled to the benefit of this exemption for a maximum of 5 years.

An individual who is a resident of Iceland on the date of arrival in the USA and who is temporarily in the USA as an employee of, or under contract with, a resident of Iceland is exempt from USA income tax for a period of 12 consecutive months on up to $5,000 received for personal services if the individual is in the USA primarily to:

An individual who is a resident of Iceland on the date of arrival in the USA and who is temporarily present in the USA for not longer than one year as a participant in a program sponsored by the USA Government primarily to train, research, or study is exempt from USA income tax on income received for personal services for the training, research, or study for a maximum of $10,000.

India

An individual who is a resident of India immediately before visiting the USA and who is temporarily in the USA primarily for studying or training is exempt from USA income tax on payments from abroad for maintenance, study, or training. The exemption does not apply to payments borne by a permanent establishment in the USA or paid by a USA citizen or resident, the USA Government, or any of its agencies, instrumentalities, political subdivisions, or local authorities.

Under the treaty, if the payments are not exempt under the rule described above, an individual described in the previous paragraph may be eligible to deduct exemptions for his or her spouse and dependents and the standard deduction. The individual must file Form 1040NR or Form 1040NR-EZ to claim these amounts. For information on how to claim these amounts, see Chapter 5 in Publication 519.

The individual is entitled to these benefits only for a period of time considered reasonable or customarily required to complete studying or training.

Indonesia

An individual who is a resident of Indonesia immediately before visiting the USA and who is temporarily in the USA is exempt from USA income tax on certain amounts for a period of up to 5 years. To be entitled to the exemption, the individual must be temporarily in the USA for full-time study at a USA university, school, or other recognized educational institution, or for full-time study, research, or training as a recipient of a grant, allowance, or award from either the USA or Indonesian Government, a scientific, educational, religious, or charitable organization, or under a technical assistance program entered into by either the USA or Indonesian Government. If the individual meets any of these requirements, the following amounts are exempt from tax:

An individual who is a resident of Indonesia immediately before visiting the USA and is temporarily in the USA only as a business or technical apprentice is exempt from USA income tax for a period of 12 consecutive months on up to $7,500 received for personal services.

Ireland

A student or business apprentice from Ireland who is receiving full-time education or training in the USA is exempt from USA income tax on payments received from persons in Ireland for maintenance, education, or training.

Israel

An individual who is a resident of Israel on the date of arrival in the USA and who is temporarily in the USA primarily to study at a university or other recognized educational institution in the USA, obtain professional training, or study or do research as a recipient of a grant, allowance, or award from a governmental, religious, charitable, scientific, literary, or educational organization is exempt from USA income tax on the following amounts:

An individual is entitled to the benefit of this exemption for a maximum of 5 tax years.

An individual who is a resident of Israel on the date of arrival in the USA and who is temporarily in the USA as an employee of, or under contract with, a resident of Israel is exempt from USA income tax for a period of 12 consecutive months on up to $7,500 received for personal services if the individual is in the USA primarily to:

An individual who is a resident of Israel on the date of arrival in the USA and who is temporarily in the USA for no more than one year as a participant in a program sponsored by the USA Government primarily to train, research, or study is exempt from USA income tax on income received for personal services for the training, research, or study for a maximum of $10,000.

Italy

A student or business apprentice (trainee) who is a resident of Italy on the date of arrival in the USA and who is temporarily in the USA only for education or training is exempt from USA income tax on amounts received from outside the USA for maintenance, education, and training.

Jamaica

A student who is a resident of Jamaica on the date of arrival in the USA and is here for full-time education or training is exempt from USA income tax on payments received from outside the USA for the student’s maintenance, education, or training.

An individual who is a resident of Jamaica on the date of arrival in the USA and who is temporarily in the USA as an employee of, or under contract with, a resident of Jamaica is exempt from USA income tax for a period of 12 consecutive months on up to $7,500 of net income from personal services if the individual is in the USA primarily to:

An individual who qualifies for one of the exemptions discussed above may instead choose to be treated as a resident alien of the USA for all USA income tax purposes. Once made, the choice applies for the entire period that the individual remains qualified for exemption and may not be revoked unless permission is obtained from the USA competent authority.

Japan

An individual who is a resident of Japan on the date of arrival in the USA and who is temporarily in the USA primarily to study at a university or other accredited educational institution in the USA, obtain professional training, or study or do research as a recipient of a grant, allowance, or award from a governmental, religious, charitable, scientific, literary, or educational organization is exempt from USA income tax on the following amounts:

An individual is entitled to the benefit of this exemption for a maximum of 5 years.

An individual who is a resident of Japan on the date of arrival in the USA and who is in the USA as an employee of, or under contract with, a resident of Japan is exempt from USA income tax for a period of 12 consecutive months on up to $5,000 received for personal services if the individual is in the USA primarily to:

An individual who is a resident of Japan on the date of arrival in the USA and who is temporarily present in the USA for not longer than one year as a participant in a program sponsored by the USA Government primarily to train, research, or study is exempt from USA income tax on income received for personal services for the training, research, or study in the amount of $10,000.

Korea, Republic of

An individual who is a resident of the Republic of Korea on the date of arrival in the USA and who is temporarily in the USA primarily to study at a university or other recognized educational institution in the USA, obtain professional training, or study or do research as a recipient of a grant, allowance, or award from a governmental, religious, charitable, scientific, literary, or educational organization is exempt from USA income tax on the following amounts:

An individual is entitled to the benefit of this exemption for a maximum of 5 years.

An individual who is a resident of Korea on the date of arrival in the USA and who is temporarily in the USA as an employee of, or under contract with, a resident of Korea is exempt from USA income tax for one year on up to $5,000 received for personal services if the individual is in the USA primarily to:

An individual who is a resident of Korea on the date of arrival in the USA and who is temporarily present in the USA for not longer than one year as a participant in a program sponsored by the USA Government primarily to train, research, or study is exempt from USA income tax on income received for personal services for the training, research, or study for a maximum of $10,000.

Luxembourg

Certain residents of Luxembourg are exempt from USA income tax on income received from abroad for employment or amounts received from abroad for their maintenance, education, or training if they are temporarily in the USA. To qualify for this exemption they must be temporarily in the USA only as:

Certain other residents of Luxembourg who are temporarily in the USA for no more than one year are exempt from USA income tax for that period on pay, including pay from an employer abroad, of not more than $5,000. To qualify for this exemption they must be employees of, or under contract with, a Luxembourg enterprise or a Luxembourg religious, charitable, scientific, literary, or educational organization and be in the USA only to acquire technical, professional, or business experience from a person other than that enterprise or organization.

Residents of Luxembourg are also exempt from USA income tax on certain income if they are in the USA for no more than one year only for training, research, or study under an arrangement with the USA Government. The income that is exempt in this case is that received for services directly related to this training, research, or study and includes pay from their employer abroad. The amount exempt may not be more than $10,000.

Malta

A student, apprentice, or business trainee who is or was a resident of Malta immediately before arrival in the USA and is here for full-time education or training is exempt from USA income tax on payments received from outside the USA for the individual’s maintenance, education, or training.

An individual who qualifies for the exemption discussed above may instead choose to be treated as a resident alien of the USA for USA income tax purposes. Once made, the choice applies for the entire period the individual remains qualified for exemption and may not be changed unless permission is obtained from the USA competent authority.

Mexico

A student or business apprentice who is a resident of Mexico immediately before visiting the USA and is in the USA solely for the purpose of education or training is exempt from USA tax on amounts received from sources outside the USA for the individual’s maintenance, education, or training.

Morocco

An individual who is a resident of Morocco on the date of arrival in the USA and who is temporarily in the USA primarily to study at a university or other recognized educational institution in the USA, obtain professional training, or study or do research as a recipient of a grant, allowance, or award from a governmental, religious, charitable, scientific, literary, or educational organization is exempt from USA income tax on the following amounts:

An individual is entitled to the benefit of this exemption for a maximum of 5 years.

Netherlands

An individual who immediately before visiting the USA is a resident of the Netherlands and who is present in the USA primarily for full-time study at a recognized university, college, or school or securing training as a business apprentice is exempt from USA income tax on the following amounts:

The individual is entitled to this exemption only for a period of time considered reasonable or customarily required to complete studying or training.

An individual who immediately before visiting the USA is a resident of the Netherlands and is temporarily present in the USA for a period not exceeding 3 years for the purpose of study, research, or training solely as a recipient of a grant, allowance, or award from a scientific, educational, religious, or charitable organization or under a technical assistance program entered into by either the Netherlands or the USA, or its political subdivisions or local authorities is exempt from USA income tax on the following amounts:

An individual is not entitled to these exemptions if, during the immediately preceding period, the individual claimed the exemption discussed earlier under Professors, Teachers, and Researchers.

New Zealand

A resident of New Zealand or an individual who was a resident of New Zealand immediately before visiting the USA who is in the USA for full-time education is exempt from USA income tax on amounts received from abroad for maintenance or education.

Norway

An individual who is a resident of Norway on the date of arrival in the USA and who is temporarily in the USA primarily to study at a university or other recognized educational institution in the USA, obtain professional training, or study or do research as a recipient of a grant, allowance, or award from a governmental, religious, charitable, scientific, literary, or educational organization is exempt from USA income tax on the following amounts:

An individual is entitled to the benefit of this exemption for a maximum of 5 tax years.

An individual who is a resident of Norway on the date of arrival in the USA and who is in the USA as an employee of, or under contract with, a resident of Norway is exempt from USA income tax for a period of 12 consecutive months on up to $5,000 received for personal services if the individual is in the USA primarily to:

Also exempt is a resident of Norway who is present in the USA for not longer than one year as a participant in a program sponsored by the Government of the USA primarily to train, research, or study. The individual is exempt from tax on income from personal services performed in the USA and received for the training, research, or study, for a maximum of $10,000.

Pakistan

Residents of Pakistan temporarily in the USA are exempt from USA income tax on certain income they may receive. To be entitled to this exemption, they must be in the USA only as students at a recognized university, college, or school, or as recipients of grants, allowances, or awards from religious, charitable, scientific, or educational organizations of Pakistan primarily to study or research. The income exempt in these cases is any payment from abroad for maintenance, education, or training, and any pay for personal services of not more than $5,000 for any tax year.

Other residents of Pakistan who are temporarily in the USA for no more than one year are exempt from USA income tax on pay of not more than $6,000 received for that period, including pay from the enterprise or organization of which they are employees or with which they are under contract. To qualify for this exemption, they must be employees of, or under contract with, a Pakistani enterprise or religious, charitable, scientific, or educational organization and be in the USA only to acquire technical, professional, or business experience from a person other than that enterprise or organization.

Also exempt from USA income tax on certain income are residents of Pakistan temporarily in the USA under an arrangement with the USA Government, or any of its agencies or instrumentalities, only for study, training, or orientation. They are exempt from tax on income of not more than $10,000 for services directly related to their training, study, or orientation, including income from their employer abroad.

Philippines

An individual who is a resident of the Philippines on the date of arrival in the USA and who is temporarily in the USA primarily to study at a university or other recognized educational institution in the USA, obtain professional training, or study or do research as a recipient of a grant, allowance, or award from a governmental, religious, charitable, scientific, literary, or educational organization is exempt from USA income tax on the following amounts:

An individual is entitled to the benefit of this exemption for a maximum of 5 years.

An individual who is a resident of the Philippines on the date of arrival in the USA and who is temporarily in the USA as an employee of, or under contract with, a resident of the Philippines is exempt from USA income tax for a period of 12 consecutive months on up to $7,500 received for personal services if the individual is in the USA primarily to:

An individual who is a resident of the Philippines on the date of arrival in the USA, and who is temporarily in the USA (for no more than one year as a participant in a program sponsored by the USA Government) primarily to train, research, or study, is exempt from USA income tax on income received for personal services for the training, research, or study, up to a maximum of $10,000.

Poland

An individual who is a resident of Poland on the date of arrival in the USA and who is temporarily in the USA primarily to study at a university or other recognized educational institution in the USA, obtain professional training, or study or do research as a recipient of a grant, allowance, or award from a governmental, religious, charitable, scientific, literary, or educational organization is exempt from USA income tax on the following amounts:

An individual is entitled to the benefit of this exemption for a maximum of 5 years.

An individual who is a resident of Poland on the date of arrival in the USA and who is temporarily in the USA as an employee of, or under contract with, a resident of Poland is exempt from USA income tax for one year on up to $5,000 received for personal services if the individual is in the USA primarily to:

An individual who is a resident of Poland on the date of arrival in the USA and who is temporarily in the USA for not longer than one year as a participant in a program sponsored by the USA Government primarily to train, research, or study is exempt from USA income tax on up to $10,000 of income received for personal services for the training, research, or study.

Romania

An individual who is a resident of Romania on the date of arrival in the USA and who is temporarily in the USA primarily to study at a university or other recognized educational institution in the USA, obtain professional training, or study or do research as a recipient of a grant, allowance, or award from a governmental, religious, charitable, scientific, literary, or educational organization is exempt from USA income tax on the following amounts:

An individual is entitled to the benefit of this exemption for a maximum of 5 years.

An individual who is a resident of Romania on the date of arrival in the USA and who is temporarily in the USA as an employee of, or under contract with, a resident of Romania is exempt from USA income tax for one year on up to $5,000 received for personal services if the individual is in the USA primarily to:

An individual who is a resident of Romania on the date of arrival in the USA and who is temporarily in the USA for not longer than one year as a participant in a program sponsored by the USA Government primarily to train, research, or study is exempt from USA income tax on up to $10,000 of income received for personal services for the training, research, or study.

Russia

An individual who is a resident of Russia at the beginning of his or her visit to the USA is exempt from USA tax on payments from abroad for maintenance, education, study, research, or training and on any grant, allowance, or other similar payments. To be entitled to the exemption, the individual must be temporarily present in the USA primarily to:

The individual is entitled to this exemption only for a period of time necessary to complete the study, training, or research, but the exemption for training or research may not extend for a period exceeding 5 years.

These exemptions do not apply to income from research if it is undertaken primarily for the private benefit of a specific person or persons.

Slovak Republic

An individual who is a resident of the Slovak Republic at the beginning of his or her visit to the USA and who is temporarily present in the USA is exempt from USA income tax on certain amounts for a period of up to 5 years. To be entitled to the exemption, the individual must be in the USA for the primary purpose of:

If the individual meets any of these requirements, the following amounts are exempt from USA tax:

An individual who is a Slovak resident at the beginning of the visit to the USA and who is temporarily present in the USA as an employee of, or under contract with, a Slovak resident is exempt from USA income tax for a period of 12 consecutive months on up to $8,000 received from personal services if the individual is in the USA primarily to:

An individual who is a Slovak resident at the time he or she becomes temporarily present in the USA and who is temporarily present in the USA for a period not longer than 1 year as a participant in a program sponsored by the USA government for the primary purpose of training, research, or study, is exempt from USA income tax on up to $10,000 of income from personal services for that training, research, or study.

These exemptions do not apply to income from research undertaken primarily for the private benefit of a specific person or persons.

Spain

An individual who is a resident of Spain at the beginning of the visit to the USA and who is temporarily in the USA primarily to study at a USA university or other accredited educational institution, to obtain training to become qualified to practice a profession or professional specialty, or to study or do research as a recipient of a grant, allowance, or award from a governmental, religious, charitable, scientific, literary, or educational organization is exempt from USA income tax on the following amounts:

An individual is entitled to the benefit of this exemption for a maximum of 5 years.

An individual who is a resident of Spain at the beginning of the visit to the USA and is temporarily in the USA as an employee of, or under contract with, a resident of Spain is exempt from USA income tax for a period of 12 consecutive months on up to $8,000 received for personal services if the individual is in the USA primarily to:

Both the $5,000 and $8,000 exemptions include any amount excluded or exempted from tax under USA tax law.

These exemptions do not apply to income from research carried on mainly for the private benefit of any person rather than in the public interest.

Sweden

A resident of Sweden is exempt from USA income tax on amounts received from abroad as income for employment or payments for maintenance, education, or training if temporarily in the USA only as:

A resident of Sweden is also exempt from USA income tax on certain pay if temporarily in the USA only for training, research, or study under an arrangement with the USA Government. The pay exempt in this case is that received for services directly related to the training, research, or study and includes wages from an employer abroad. This pay is exempt only if it is not more than $10,000.

Switzerland

A student or apprentice who is a resident of Switzerland and temporarily visits the USA only to study or acquire business or technical experience is exempt from USA income tax on payments from abroad for maintenance or studies.

Trinidad and Tobago

An individual who is a resident of Trinidad and Tobago on the date of arrival in the USA and who is temporarily in the USA primarily to study at a university or other accredited educational institution in the USA, obtain professional training, or study or do research as a recipient of a grant, allowance, or award from a governmental, religious, charitable, scientific, literary, or educational organization is exempt from USA income tax on the following amounts:

An individual is entitled to the benefit of this exemption for a maximum period of 5 tax years.

An individual who is a resident of Trinidad and Tobago on the date of arrival in the USA and who is in the USA as an employee of, or under contract with, a resident or corporation of Trinidad and Tobago is exempt from USA income tax for one tax year on up to $5,000 received for personal services if the individual is in the USA primarily to:

Also exempt is a resident of Trinidad and Tobago who is present in the USA for not longer than one year as a participant in a program sponsored by the USA Government primarily to train, research, or study. The individual is exempt from tax on income from personal services performed in the USA and received for the training, research, or study for up to a maximum of $10,000.

Tunisia

An individual who is a resident of Tunisia immediately before visiting the USA and who is in the USA for full-time study or training is exempt from USA income tax on the following amounts:

The individual is entitled to this exemption for a maximum of 5 years.

United Kingdom

A student or business apprentice who is a resident of the United Kingdom at the time of arrival in the USA and who is receiving full-time education or training in the USA is exempt from USA income tax on payments received from abroad for maintenance, education, or training.