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2010 Federal Tax Return

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2010 Federal Tax Return

2010 federal tax return Publication 901 - Main Content Table of Contents Application of Treaties Tax Exemptions Provided by TreatiesPersonal Services Income Professors, Teachers, and Researchers Students and Apprentices Wages and Pensions Paid by a Foreign Government Explanation of TablesTable 1 Table 2 Table 3 Application of Treaties The United States has income tax treaties with a number of foreign countries. 2010 federal tax return Under these treaties, residents (not necessarily citizens) of foreign countries are taxed at a reduced rate, or are exempt from U. 2010 federal tax return S. 2010 federal tax return income taxes on certain items of income they receive from sources within the United States. 2010 federal tax return These reduced rates and exemptions vary among countries and specific items of income. 2010 federal tax return If there is no treaty between your country and the United States, you must pay tax on the income in the same way and at the same rates shown in the instructions for Form 1040NR. 2010 federal tax return Also see Publication 519. 2010 federal tax return Many of the individual states of the United States tax the income of their residents. 2010 federal tax return 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. 2010 federal tax return Tax treaties reduce the U. 2010 federal tax return S. 2010 federal tax return taxes of residents of foreign countries. 2010 federal tax return With certain exceptions, they do not reduce the U. 2010 federal tax return S. 2010 federal tax return taxes of U. 2010 federal tax return S. 2010 federal tax return citizens or residents. 2010 federal tax return U. 2010 federal tax return S. 2010 federal tax return citizens and residents are subject to U. 2010 federal tax return S. 2010 federal tax return income tax on their worldwide income. 2010 federal tax return Treaty provisions generally are reciprocal (apply to both treaty countries); therefore, a U. 2010 federal tax return S. 2010 federal tax return citizen or resident who receives income from a treaty country may refer to the tables in this publication to see if a tax treaty might affect the tax to be paid to that foreign country. 2010 federal tax return Foreign taxing authorities sometimes require certification from the U. 2010 federal tax return S. 2010 federal tax return Government that an applicant filed an income tax return as a U. 2010 federal tax return S. 2010 federal tax return citizen or resident, as part of the proof of entitlement to the treaty benefits. 2010 federal tax return See Form 8802, Application for United States Residency Certification, to request a certification. 2010 federal tax return Disclosure of a treaty-based position that reduces your tax. 2010 federal tax return   If you take the position that any U. 2010 federal tax return S. 2010 federal tax return tax is overruled or otherwise reduced by a U. 2010 federal tax return S. 2010 federal tax return treaty (a treaty-based position), you generally must disclose that position on Form 8833 and attach it to your return. 2010 federal tax 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. 2010 federal tax return 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. 2010 federal tax return For more information, see Publication 519 and the Form 8833 instructions. 2010 federal tax return   If you fail to file Form 8833, you may have to pay a $1,000 penalty. 2010 federal tax return Corporations are subject to a $10,000 penalty for each failure. 2010 federal tax return Tax Exemptions Provided by Treaties In addition to the tables in the back of this publication, this publication contains discussions of the exemptions from tax and certain other effects of the tax treaties on the following types of income. 2010 federal tax return Pay for certain personal services performed in the United States. 2010 federal tax return Pay of a professor, teacher, or researcher who teaches or performs research in the United States for a limited time. 2010 federal tax return Amounts received for maintenance and studies by a foreign student or apprentice who is here for study or experience. 2010 federal tax return Wages, salaries, and pensions paid by a foreign government. 2010 federal tax return Personal Services Income Pay for certain personal services performed in the United States is exempt from U. 2010 federal tax return S. 2010 federal tax return income tax if you are a resident of one of the countries discussed below, if you are in the United States for a limited number of days, and if you meet certain other conditions. 2010 federal tax return For this purpose, the word “day” means a day during any part of which you are physically present in the United States. 2010 federal tax return Terms defined. 2010 federal tax return   Several terms appear in many of the discussions that follow. 2010 federal tax return The exact meanings of the terms are determined by the particular tax treaty under discussion; thus, the meanings vary among treaties. 2010 federal tax return The definitions that follow are, therefore, general definitions that may not give the exact meaning intended by a particular treaty. 2010 federal tax return   The terms fixed base and permanent establishment generally mean a fixed place of business, such as a place of management, a branch, an office, a factory, a warehouse, or a mining site, through which an enterprise carries on its business. 2010 federal tax return   The term borne by generally means having ultimate financial accounting responsibility for, or providing the monetary resources for, an expenditure or payment, even if another entity in another location actually made the expenditure or payment. 2010 federal tax return Australia Income that residents of Australia receive for performing personal services as independent contractors or self-employed individuals (independent personal services) in the United States during the tax year is exempt from U. 2010 federal tax return S. 2010 federal tax return income tax if the residents: Are in the United States for no more than 183 days during the tax year, and Do not have a fixed base regularly available to them in the United States for the purpose of performing the services. 2010 federal tax return If they have a fixed base available in the United States, they are taxed on the income attributable to the fixed base. 2010 federal tax return Pay that residents of Australia receive for labor or personal services performed in the United States as employees (dependent personal services), including services as a director of a company, is exempt from U. 2010 federal tax return S. 2010 federal tax return income tax if: The residents are in the United States for no more than 183 days during the tax year, The pay is paid by, or on behalf of, an employer or company that is not a resident of the United States, and The pay is not deductible in determining the taxable income of the trade or business of the employer (or company) in the United States. 2010 federal tax return These exemptions do not apply to public entertainers (such as theater, motion picture, radio, or television entertainers, musicians, and athletes) from Australia who earn more than $10,000 in gross receipts, including reimbursed expenses, from their entertainment activities in the United States during the tax year. 2010 federal tax return Austria Income that residents of Austria receive for personal services as independent contractors or self-employed individuals (independent personal services) in the United States is exempt from U. 2010 federal tax return S. 2010 federal tax return income tax if they do not have a fixed base regularly available to them in the United States for performing the services. 2010 federal tax return If they have a fixed base available in the United States, they are taxed on the income attributable to the fixed base. 2010 federal tax return Income that residents of Austria receive for services performed in the United States as employees (dependent personal services) is exempt from U. 2010 federal tax return S. 2010 federal tax return income tax if the residents meet the following requirements. 2010 federal tax return They are in the United States for no more than 183 days in any 12-month period beginning or ending in the tax year. 2010 federal tax return Their income is paid by, or on behalf of, an employer who is not a U. 2010 federal tax return S. 2010 federal tax return resident. 2010 federal tax return Their income is not borne by a permanent establishment or a fixed base that the employer has in the United States. 2010 federal tax return These exemptions do not apply to public entertainers (such as theater, motion picture, radio, or television entertainers, musicians, and athletes) from Austria who earn more than $20,000 in gross receipts, including reimbursed expenses, from their entertainment activities in the United States during the tax year. 2010 federal tax return Income received by a resident of Austria for services performed as an employee and member of the regular complement of a ship or aircraft operated in international traffic is exempt from U. 2010 federal tax return S. 2010 federal tax return income tax. 2010 federal tax return Bangladesh Income that residents of Bangladesh receive for performing personal services as independent contractors or self-employed individuals (independent personal services) in the United States during the tax year is exempt from U. 2010 federal tax return S. 2010 federal tax return income tax if the residents: Are in the United States for no more than 183 days in any 12-month period beginning or ending in the tax year, or Do not have a fixed base regularly available to them in the United States for the purpose of performing the services. 2010 federal tax return If they have a fixed base available in the United States, they are taxed on the income attributable to the fixed base. 2010 federal tax return Income that residents of Bangladesh receive for services performed in the United States as employees (dependent personal services) is exempt from U. 2010 federal tax return S. 2010 federal tax return income tax if the residents meet the following requirements. 2010 federal tax return They are in the United States for no more than 183 days in any 12-month period beginning or ending in the tax year. 2010 federal tax return Their income is paid by, or on behalf of, an employer who is not a U. 2010 federal tax return S. 2010 federal tax return resident. 2010 federal tax return Their income is not borne by a permanent establishment or a fixed base that the employer has in the United States. 2010 federal tax return These exemptions do not apply to pubic entertainers (such as theater, motion picture, radio, or television entertainers, musicians, and athletes) from Bangladesh who earn more than $10,000 in gross receipts, including reimbursed expenses, from their entertainment activities in the United States during the tax year. 2010 federal tax return Regardless of these limits, income of Bangladesh entertainers is exempt from U. 2010 federal tax return S. 2010 federal tax return income tax if their visit to the United States is wholly or mainly supported by public funds of Bangladesh, its political subdivisions, or local authorities. 2010 federal tax return Income received from employment as a member of the regular complement of a ship or an aircraft operated by a Bangladesh enterprise in international traffic is exempt from U. 2010 federal tax return S. 2010 federal tax return tax. 2010 federal tax return If the ship or aircraft is operated by a U. 2010 federal tax return S. 2010 federal tax return enterprise, the income is subject to U. 2010 federal tax return S. 2010 federal tax return tax. 2010 federal tax return If the resident of Bangladesh is a shareholder in a U. 2010 federal tax return S. 2010 federal tax return corporation, these exemptions do not apply to directors' fees received as a member of the board of directors of the U. 2010 federal tax return S. 2010 federal tax return corporation. 2010 federal tax return The amount received by the shareholder that is more than the amount paid to a director that is not a shareholder is subject to U. 2010 federal tax return S. 2010 federal tax return tax at the rate of 15%. 2010 federal tax return Barbados Income that residents of Barbados receive for performing personal services as independent contractors or self-employed individuals (independent personal services) in the United States during the tax year is exempt from U. 2010 federal tax return S. 2010 federal tax return income tax if the residents: Are in the United States for no more than 89 days during the tax year, Earn net income for independent services provided to U. 2010 federal tax return S. 2010 federal tax return residents that is not more than $5,000 (there is no dollar limit if the contractors are not U. 2010 federal tax return S. 2010 federal tax return residents), and Do not have a regular base available in the United States for performing the services. 2010 federal tax return If they have a regular base available in the United States but otherwise meet the conditions for exemption, they are taxed only on the income attributable to the regular base. 2010 federal tax return Income that residents of Barbados receive for personal services performed in the United States as employees (dependent personal services) is exempt from U. 2010 federal tax return S. 2010 federal tax return tax if the residents meet four requirements. 2010 federal tax return They are in the United States for no more than 183 days during the calendar year. 2010 federal tax return The income earned in the calendar year in the United States is not more than $5,000. 2010 federal tax return Their income is paid by or for an employer who is not a U. 2010 federal tax return S. 2010 federal tax return resident. 2010 federal tax return The income is not borne by a permanent establishment or regular base of the employer in the United States. 2010 federal tax return Income of a Barbadian resident from employment as a member of the regular complement of a ship or aircraft operated in international traffic is exempt from U. 2010 federal tax return S. 2010 federal tax return tax. 2010 federal tax return These exemptions do not apply to Barbadian resident public entertainers (such as theater, motion picture, radio, or television artists, musicians, or athletes) who receive gross receipts of more than $250 per day or $4,000 in the tax year, not including reimbursed expenses, from their entertainment activities in the United States. 2010 federal tax return However, the exemptions do apply regardless of these limits on gross receipts if the entertainer's visit to the United States is substantially supported by Barbadian public funds or if the entertainer's services are provided to a nonprofit organization. 2010 federal tax return Belgium Income that residents of Belgium receive for personal services as independent contractors or self-employed individuals are subject to the provisions of Article 7 (Business Profits) of the treaty. 2010 federal tax return Under that provision, business profits are exempt from U. 2010 federal tax return S. 2010 federal tax return income tax unless the individual has a permanent establishment in the United States. 2010 federal tax return If they have a permanent establishment in the United States, they are taxed on the profit attributable to the permanent establishment. 2010 federal tax return Income that residents of Belgium receive for services performed in the United States as employees (dependent personal services) is exempt from U. 2010 federal tax return S. 2010 federal tax return income tax if the residents meet the following requirements. 2010 federal tax return They are in the United States for no more than 183 days in any 12-month period beginning or ending in the tax year. 2010 federal tax return Their income is paid by, or on behalf of, an employer who is not a U. 2010 federal tax return S. 2010 federal tax return resident. 2010 federal tax return Their income is not borne by a permanent establishment that the employer has in the United States. 2010 federal tax return The exemption does not apply to directors' fees and similar payments received by a resident of Belgium for services performed in the United States as a member of the board of directors of a company that is a resident of the United States. 2010 federal tax return Public entertainers (such as theater, motion picture, radio, or television artists, musicians, or athletes) from Belgium who earn more than $20,000 in gross receipts, including reimbursed expenses, from their entertainment activities in the United States during the tax year are subject to U. 2010 federal tax return S. 2010 federal tax return tax. 2010 federal tax return Income received by a resident of Belgium for services performed as an employee and member of the regular complement of a ship or aircraft operated in international traffic is exempt from U. 2010 federal tax return S. 2010 federal tax return income tax. 2010 federal tax return Bulgaria Income that residents of Bulgaria receive for personal services as independent contractors or self-employed individuals is subject to the provisions of Article 7 (Business Profits) of the treaty. 2010 federal tax return Under that provision, business profits are exempt from U. 2010 federal tax return S. 2010 federal tax return income tax unless the individual has a permanent establishment in the United States. 2010 federal tax return If they have a permanent establishment in the United States, they are taxed on the profit attributable to the permanent establishment. 2010 federal tax return Under Article 5 (Permanent Establishment), you may be considered to provide services through a permanent establishment in the United States even if you do not have a fixed place of business. 2010 federal tax return Income that residents of Bulgaria receive for services performed in the United States as employees (dependent personal services) is exempt from U. 2010 federal tax return S. 2010 federal tax return income tax if the residents meet the following requirements. 2010 federal tax return They are in the United States for no more than 183 days in any 12-month period beginning or ending in the tax year. 2010 federal tax return Their income is paid by, or on behalf of, an employer who is not a U. 2010 federal tax return S. 2010 federal tax return resident. 2010 federal tax return Their income is not borne by a permanent establishment that the employer has in the United States. 2010 federal tax return The exemption does not apply to directors' fees and similar payments received by a resident of Bulgaria as a member of the board of directors of a U. 2010 federal tax return S. 2010 federal tax return company. 2010 federal tax return Public entertainers (such as theater, motion picture, radio, or television artists, musicians, or athletes) from Bulgaria who earn more than $15,000 in gross receipts, including reimbursed expenses, from their entertainment activities in the United States during the tax year are subject to U. 2010 federal tax return S. 2010 federal tax return tax. 2010 federal tax return Income received by a resident of Bulgaria for services performed as an employee and member of the regular complement of a ship or aircraft operated in international traffic is exempt from U. 2010 federal tax return S. 2010 federal tax return income tax. 2010 federal tax return Canada Income that residents of Canada receive for personal services as independent contractors or self-employed individuals is subject to the provisions of Article VII (Business Profits) of the treaty. 2010 federal tax return Under that provision, business profits are exempt from U. 2010 federal tax return S. 2010 federal tax return income tax unless the individual has a permanent establishment in the United States. 2010 federal tax return If they have a permanent establishment in the United States, they are taxed on the profit attributable to the permanent establishment. 2010 federal tax return Under Article V (Permanent Establishment), you may be considered to provide services through a permanent establishment in the United States even if you do not have a fixed place of business. 2010 federal tax return Income that residents of Canada receive for personal services performed as employees (dependent personal services) in the United States is exempt from U. 2010 federal tax return S. 2010 federal tax return tax if it is not more than $10,000 for the year. 2010 federal tax return If the income is more than $10,000 for the year, it is exempt only if: The residents are present in the United States for no more than 183 days in any 12-month period beginning or ending in the tax year, and The income is not paid by, or on behalf of, a U. 2010 federal tax return S. 2010 federal tax return resident, and is not borne by a permanent establishment in the United States. 2010 federal tax return Public entertainers (such as theater, motion picture, radio, or television artists, musicians, or athletes) from Canada who derive more than $15,000 in gross receipts, including reimbursed expenses, from their entertainment activities in the United States during the calendar year are subject to U. 2010 federal tax return S. 2010 federal tax return tax. 2010 federal tax return However, this article does not apply to athletes participating in team sports in leagues with regularly scheduled games in both Canada and the United States. 2010 federal tax return Pay received by a resident of Canada for employment regularly done in more than one country on a ship, aircraft, motor vehicle, or train operated by a Canadian resident is exempt from U. 2010 federal tax return S. 2010 federal tax return tax. 2010 federal tax return China, People's Republic of Income that residents of the People's Republic of China receive for personal services as independent contractors or self-employed individuals (independent personal services) that they perform during the tax year in the United States is exempt from U. 2010 federal tax return S. 2010 federal tax return income tax if the residents: Are present in the United States for no more than 183 days in the calendar year, and Do not have a fixed base regularly available in the United States for performing the services. 2010 federal tax return If they have a fixed base available in the United States, they are taxable on the income attributable to the fixed base. 2010 federal tax return Pay received by residents of the People's Republic of China for services performed as employees (dependent personal services) in the United States is exempt from U. 2010 federal tax return S. 2010 federal tax return tax if: The residents are present in the United States for no more than 183 days in the calendar year, The pay is paid by or for an employer who is not a U. 2010 federal tax return S. 2010 federal tax return resident, and The pay is not borne by a permanent establishment or fixed base that the employer has in the United States. 2010 federal tax return These exemptions do not apply to directors' fees for service on the board of directors of a U. 2010 federal tax return S. 2010 federal tax return corporation. 2010 federal tax return These exemptions generally do not apply to income received as a public entertainer (such as a theater, motion picture, radio, or television artist, musician, or athlete). 2010 federal tax return However, income of athletes or public entertainers from China participating in a cultural exchange program agreed upon by the U. 2010 federal tax return S. 2010 federal tax return and Chinese governments is exempt from U. 2010 federal tax return S. 2010 federal tax return tax. 2010 federal tax return Commonwealth of Independent States Income that residents of a C. 2010 federal tax return I. 2010 federal tax return S. 2010 federal tax return member receive for performing personal services in the United States is exempt from U. 2010 federal tax return S. 2010 federal tax return income tax if those residents are in the United States for no more than 183 days during the tax year. 2010 federal tax return Pay received by an employee who is a member of the regular complement of a ship or aircraft operated in international traffic by a C. 2010 federal tax return I. 2010 federal tax return S. 2010 federal tax return member or a resident of a C. 2010 federal tax return I. 2010 federal tax return S. 2010 federal tax return member is exempt from U. 2010 federal tax return S. 2010 federal tax return tax. 2010 federal tax return Cyprus Income that residents of Cyprus receive for performing personal services as independent contractors or self-employed individuals (independent personal services) in the United States during the tax year is exempt from U. 2010 federal tax return S. 2010 federal tax return income tax if the residents: Are present in the United States for less than 183 days in the tax year, and Do not have a fixed base regularly available to them in the United States for performing the services. 2010 federal tax return If they have a fixed base available in the United States, they are taxable on the income attributable to the fixed base. 2010 federal tax return Pay received by residents of Cyprus from services performed as employees (dependent personal services), including services as an officer of a corporation, is exempt from U. 2010 federal tax return S. 2010 federal tax return income tax if: The residents are in the United States for less than 183 days during the tax year, The pay is paid by or for an employer who is not a U. 2010 federal tax return S. 2010 federal tax return resident, and The pay is not borne by a permanent establishment, fixed base, or trade or business that the employer has in the United States. 2010 federal tax return Pay received by a Cyprus resident for performing personal services as an employee and member of the regular complement of a ship or aircraft operated in international traffic by a resident of Cyprus is exempt from U. 2010 federal tax return S. 2010 federal tax return tax. 2010 federal tax return These exemptions do not apply to Cyprus resident public entertainers (theater, motion picture, radio, or television artists, musicians, or athletes) who receive gross receipts of more than $500 per day or $5,000 for the tax year, not including reimbursed expenses, from their entertainment activities in the United States. 2010 federal tax return Directors' fees received by residents of Cyprus for service on the board of directors of a U. 2010 federal tax return S. 2010 federal tax return corporation are exempt from U. 2010 federal tax return S. 2010 federal tax return income tax to the extent of a reasonable fixed amount payable to all directors for each day of attendance at directors' meetings held in the United States. 2010 federal tax return Czech Republic Income that residents of the Czech Republic receive for performing personal services as independent contractors or self-employed individuals (independent personal services) in the United States is exempt from U. 2010 federal tax return S. 2010 federal tax return income tax if the residents: Are present in the United States for no more than 183 days in any 12-month period, and Do not have a fixed base regularly available to them in the United States for performing the services. 2010 federal tax return If they have a fixed base available, they are taxed only on income attributable to the fixed base. 2010 federal tax return Income that residents of the Czech Republic receive for employment in the United States (dependent personal services) is exempt from U. 2010 federal tax return S. 2010 federal tax return income tax if the following three requirements are met. 2010 federal tax return The resident is present in the United States for no more than 183 days in any 12-month period. 2010 federal tax return The income is paid by, or on behalf of, an employer who is not a U. 2010 federal tax return S. 2010 federal tax return resident. 2010 federal tax return The income is not borne by a permanent establishment or a fixed base that the employer has in the United States. 2010 federal tax return These exemptions do not apply to income residents of the Czech Republic receive as public entertainers (such as theater, motion picture, radio, or television artists, or musicians) or sportsmen if their gross receipts, including reimbursed expenses, are more than $20,000 during the tax year. 2010 federal tax return Regardless of these limits, income of Czech entertainers and sportsmen is exempt from U. 2010 federal tax return S. 2010 federal tax return income tax if their visit to the United States is substantially supported by public funds of the Czech Republic, its political subdivisions, or local authorities, or the visit is made pursuant to a specific arrangement between the United States and the Czech Republic. 2010 federal tax return These exemptions do not apply to directors' fees and similar payments received by a resident of the Czech Republic as a member of the board of directors of a company that is a resident of the United States. 2010 federal tax return Income from employment as a member of the regular complement of a ship or aircraft operated by a Czech enterprise in international traffic is exempt from U. 2010 federal tax return S. 2010 federal tax return income tax. 2010 federal tax return If the ship or aircraft is operated by a U. 2010 federal tax return S. 2010 federal tax return enterprise, the income is subject to U. 2010 federal tax return S. 2010 federal tax return tax. 2010 federal tax return Denmark Income that residents of Denmark receive for personal services as independent contractors or self-employed individuals (independent personal services) in the United States is exempt from U. 2010 federal tax return S. 2010 federal tax return income tax if they do not have a fixed base regularly available to them in the United States for performing the services. 2010 federal tax return If they have a fixed base available in the United States, they are taxed on the income attributable to the fixed base. 2010 federal tax return Income that residents of Denmark receive for services performed in the United States as employees (dependent personal services) is exempt from U. 2010 federal tax return S. 2010 federal tax return income tax if the residents meet the following requirements. 2010 federal tax return They are in the United States for no more than 183 days in any 12-month period beginning or ending in the tax year. 2010 federal tax return Their income is paid by, or on behalf of, an employer who is not a U. 2010 federal tax return S. 2010 federal tax return resident. 2010 federal tax return Their income is not borne by a permanent establishment or a fixed base that the employer has in the United States. 2010 federal tax return These exemptions do not apply to directors' fees and similar payments received by a resident of Denmark as a member of the board of directors of a company that is a resident of the United States. 2010 federal tax return These exemptions do not apply to public entertainers (such as theater, motion picture, radio, or television artists, musicians, and athletes) from Denmark who earn more than $20,000 in gross receipts, including reimbursed expenses, from their entertainment activities in the United States during the tax year. 2010 federal tax return Income received by a resident of Denmark for services performed as an employee and member of the regular complement of a ship or aircraft operated in international traffic is exempt from U. 2010 federal tax return S. 2010 federal tax return income tax. 2010 federal tax return Egypt Income that residents of Egypt receive for performing personal services as independent contractors or as self-employed individuals (independent personal services) in the United States during the tax year is exempt from U. 2010 federal tax return S. 2010 federal tax return income tax if they are in the United States for no more than 89 days during the tax year. 2010 federal tax return Income that residents of Egypt receive for labor or personal services performed in the United States as employees (dependent personal services), including income for services performed by an officer of a corporation or company, is exempt from U. 2010 federal tax return S. 2010 federal tax return income tax if the residents meet four requirements. 2010 federal tax return They are in the United States for no more than 89 days during the tax year. 2010 federal tax return They are employees of a resident of, or a permanent establishment in, Egypt. 2010 federal tax return Their income is not borne by a permanent establishment that the employer has in the United States. 2010 federal tax return Their income is subject to Egyptian tax. 2010 federal tax return This exemption does not apply to pay received by a resident of Egypt who is an employee and member of the regular complement of a ship or an aircraft operated in international traffic by a resident of the United States. 2010 federal tax return These exemptions do not apply to Egyptian resident public entertainers (theater, motion picture, radio, or television artists, musicians, or athletes), who earn income for services as public entertainers if the gross amount of the income is more than $400 for each day they are in the United States performing the services. 2010 federal tax return Estonia Income that residents of Estonia receive for performing personal services as independent contractors or self-employed individuals (independent personal services) in the United States is exempt from U. 2010 federal tax return S. 2010 federal tax return income tax if the residents: Are in the United States for no more than 183 days in any 12-month period beginning or ending in the tax year, and Do not have a fixed base regularly available to them in the United States for performing the services. 2010 federal tax return If they have a fixed base available, they are taxed on the income attributable to the fixed base. 2010 federal tax return Income that residents of Estonia receive for services performed in the United States as employees (dependent personal services) is exempt from U. 2010 federal tax return S. 2010 federal tax return income tax if the following requirements are met. 2010 federal tax return The resident is in the United States for no more than 183 days in any 12-month period beginning or ending in the tax year. 2010 federal tax return The income is paid by, or on behalf of, an employer who is not a U. 2010 federal tax return S. 2010 federal tax return resident. 2010 federal tax return The income is not borne by a permanent establishment or a fixed base that the employer has in the United States. 2010 federal tax return These exemptions do not apply to directors' fees and similar payments received by a resident of Estonia as a member of the board of directors or similar body of a company that is a U. 2010 federal tax return S. 2010 federal tax return resident. 2010 federal tax return Pay received for employment as a member of the regular complement of a ship or an aircraft operated in international traffic by a United States enterprise is subject to U. 2010 federal tax return S. 2010 federal tax return tax. 2010 federal tax return These exemptions do not apply to income residents of Estonia receive as public entertainers (such as theater, motion picture, radio, or television artists, or musicians) or sportsmen if their gross receipts, including reimbursed expenses, are more than $20,000 for their personal activities in the United States during the tax year. 2010 federal tax return Regardless of these limits, income of Estonian entertainers or athletes is exempt from U. 2010 federal tax return S. 2010 federal tax return income tax if their visit to the United States is wholly or mainly supported by public funds of Estonia, its political subdivisions, or local authorities. 2010 federal tax return Finland Income that residents of Finland receive for performing personal services as independent contractors or self-employed individuals (independent personal services) in the United States is exempt from U. 2010 federal tax return S. 2010 federal tax return income tax if they do not have a fixed base regularly available to them in the United States for performing the services. 2010 federal tax return If they have a fixed base available in the United States, they are taxed on the income attributable to the fixed base. 2010 federal tax return Income that residents of Finland receive for labor or personal services performed in the United States as employees (dependent personal services) is exempt from U. 2010 federal tax return S. 2010 federal tax return income tax if the residents meet three requirements. 2010 federal tax return They are in the United States for no more than 183 days during any 12-month period. 2010 federal tax return Their income is paid by, or on behalf of, an employer who is not a resident of the United States. 2010 federal tax return Their income is not borne by a permanent establishment, fixed base, or trade or business that the employer has in the United States. 2010 federal tax return The exemption does not apply to pay received by a resident of Finland who is an employee and member of the regular complement of a ship or aircraft operated in international traffic by a resident of the United States. 2010 federal tax return These exemptions do not apply to income residents of Finland receive as public entertainers or sportsmen if the gross income, including reimbursed expenses, is more than $20,000 for their personal activities in the United States during the calendar year. 2010 federal tax return France Income that residents of France receive for performing personal services as independent contractors or self-employed individuals (independent personal services) in the United States is exempt from U. 2010 federal tax return S. 2010 federal tax return income tax if they do not have a fixed base regularly available to them in the United States for performing the services. 2010 federal tax return If they have a fixed base available in the United States, they are taxed on the income attributable to the fixed base. 2010 federal tax return Income that residents of France receive for labor or personal services performed in the United States as employees (dependent personal services) is exempt from U. 2010 federal tax return S. 2010 federal tax return income tax if the residents meet three requirements. 2010 federal tax return They are in the United States for no more than 183 days in any 12-month period. 2010 federal tax return Their income is paid by, or on behalf of, an employer who is not a resident of the United States. 2010 federal tax return Their income is not borne by a permanent establishment or a fixed base that the employer has in the United States. 2010 federal tax return Income for services performed by a resident of France as an employee and member of the regular complement of a ship or an aircraft operated in international traffic is exempt from tax in the United States. 2010 federal tax return These exemptions do not apply to public entertainers (such as theater, motion picture, radio, or television artists, or musicians), or sportsmen from France who earn more than $10,000 in gross receipts, including reimbursed expenses, from their entertainment activities in the United States during the tax year. 2010 federal tax return Regardless of these limits, income of French entertainers or sportsmen is exempt from U. 2010 federal tax return S. 2010 federal tax return tax if their visit is principally supported by public funds of France. 2010 federal tax return These exemptions do not apply to directors' fees and similar payments received by a resident of France as a member of the board of directors of a company that is a resident of the United States. 2010 federal tax return Germany Income that residents of Germany receive for personal services as independent contractors or self-employed individuals are subject to the provisions of Article 7 (Business Profits) of the treaty. 2010 federal tax return Under that provision, business profits are exempt from U. 2010 federal tax return S. 2010 federal tax return income tax unless the individual has a permanent establishment in the United States. 2010 federal tax return If they have a permanent establishment in the United States, they are taxed on the profit attributable to the permanent establishment. 2010 federal tax return Income that residents of Germany receive for labor or personal services performed in the United States as employees (dependent personal services) is exempt from U. 2010 federal tax return S. 2010 federal tax return tax if the residents meet three requirements. 2010 federal tax return They are in the United States for no more than 183 days during the calendar year. 2010 federal tax return The income is paid by, or on behalf of, an employer who is not a resident of the United States. 2010 federal tax return The income is not borne by a permanent establishment that the employer has in the United States. 2010 federal tax return Pay received by a resident of Germany for services performed as an employee and member of the regular complement of a ship or aircraft operated in international traffic is exempt from U. 2010 federal tax return S. 2010 federal tax return tax. 2010 federal tax return The exemption does not apply to directors' fees and other similar payments received by a resident of Germany for services performed in the United States as a member of the board of directors of a company resident in the United States. 2010 federal tax return Income residents of Germany receive as public entertainers (such as theater, motion picture, radio, or television artists, or musicians) or athletes is subject to U. 2010 federal tax return S. 2010 federal tax return tax if their gross receipts, including reimbursed expenses, from their entertainment activities in the United States are more than $20,000 during the calendar year. 2010 federal tax return Income of German entertainers or athletes is exempt from U. 2010 federal tax return S. 2010 federal tax return tax if their visit to the United States is substantially supported by public funds of Germany, its political subdivisions, or local authorities. 2010 federal tax return Greece Income that residents of Greece receive for labor or personal services (including practicing liberal and artistic professions) is exempt from U. 2010 federal tax return S. 2010 federal tax return income tax if they are in the United States for no more than 183 days during the tax year and the pay is not more than $10,000. 2010 federal tax return The pay, regardless of amount, is exempt from U. 2010 federal tax return S. 2010 federal tax return income tax if it is for labor or personal services performed as employees of, or under contract with, a resident of Greece or a Greek corporation or other entity of Greece, and if the residents are in the United States for no more than 183 days during the tax year. 2010 federal tax return Hungary Income that residents of Hungary receive for performing personal services as independent contractors or self-employed individuals (independent personal services) in the United States during the tax year is exempt from U. 2010 federal tax return S. 2010 federal tax return tax if the residents: Are in the United States for no more than 183 days during the tax year, and Do not have a fixed base regularly available in the United States. 2010 federal tax return If they have a fixed base available in the United States, they are taxed on the income attributable to the fixed base. 2010 federal tax return Income that residents of Hungary receive for labor or personal services performed in the United States as employees (dependent personal services) is exempt from U. 2010 federal tax return S. 2010 federal tax return income tax if the residents meet three requirements. 2010 federal tax return They are in the United States for no more than 183 days during the tax year. 2010 federal tax return Their income is paid by or on behalf of an employer who is not a resident of the United States. 2010 federal tax return Their income is not borne by a permanent establishment or a fixed base that the employer has in the United States. 2010 federal tax return Pay received by an employee who is a member of the regular complement of a ship or aircraft operated by a Hungarian enterprise in international traffic is exempt from U. 2010 federal tax return S. 2010 federal tax return tax. 2010 federal tax return If the ship or aircraft is operated by a U. 2010 federal tax return S. 2010 federal tax return enterprise, the pay is subject to U. 2010 federal tax return S. 2010 federal tax return tax. 2010 federal tax return Iceland Income that residents of Iceland receive for personal services as independent contractors or self-employed individuals is subject to the provisions of Article 7 (Business Profits) of the treaty. 2010 federal tax return Under that provision, business profits are exempt from U. 2010 federal tax return S. 2010 federal tax return income tax unless the individual has a permanent establishment in the United States. 2010 federal tax return If they have a permanent establishment in the United States, they are taxed on the profit attributable to the permanent establishment. 2010 federal tax return Income that residents of Iceland receive for services performed in the United States as employees (dependent personal services) is exempt from U. 2010 federal tax return S. 2010 federal tax return income tax if the residents meet the following requirements. 2010 federal tax return They are in the United States for no more than 183 days in any 12-month period beginning or ending in the tax year. 2010 federal tax return Their income is paid by, or on behalf of, an employer who is not a U. 2010 federal tax return S. 2010 federal tax return resident. 2010 federal tax return Their income is not borne by a permanent establishment that the employer has in the United States. 2010 federal tax return The exemption does not apply to directors' fees and similar payments received by a resident of Iceland as a member of the board of directors of a U. 2010 federal tax return S. 2010 federal tax return company. 2010 federal tax return Public entertainers (such as theater, motion picture, radio, or television artists, musicians, or athletes) from Iceland who earn more than $20,000 in gross receipts, including reimbursed expenses, from their entertainment activities in the United States during the tax year are subject to U. 2010 federal tax return S. 2010 federal tax return tax. 2010 federal tax return Income received by a resident of Iceland for services performed as an employee and member of the regular complement of a ship or aircraft operated in international traffic is exempt from U. 2010 federal tax return S. 2010 federal tax return income tax. 2010 federal tax return India Income that residents of India receive for performing personal services in the United States during the tax year as independent contractors or self-employed individuals (independent personal services) is exempt from U. 2010 federal tax return S. 2010 federal tax return income tax if the residents: Are present in the United States for no more than 89 days during the tax year, and Do not have a fixed base regularly available to them in the United States for performing the services. 2010 federal tax return If they have a fixed base available, they are taxed only on income attributable to the fixed base. 2010 federal tax return Income that residents of India receive for personal services performed in the United States as employees (dependent personal services) is exempt from U. 2010 federal tax return S. 2010 federal tax return income tax if the residents meet three requirements. 2010 federal tax return They are present in the United States for no more than 183 days during the tax year. 2010 federal tax return The income is paid by, or on behalf of, an employer who is not a resident of the United States. 2010 federal tax return The income is not borne by a permanent establishment, fixed base, or trade or business the employer has in the United States. 2010 federal tax return The exemption does not apply to pay received by a resident of India for services performed as an employee aboard a ship or aircraft operated in international traffic by a U. 2010 federal tax return S. 2010 federal tax return enterprise. 2010 federal tax return These exemptions do not apply to directors' fees and similar payments received by an Indian resident as a member of the board of directors of a company that is a U. 2010 federal tax return S. 2010 federal tax return resident. 2010 federal tax return These exemptions do not apply to income residents of India receive as public entertainers (such as theater, motion picture, radio, or television artists, or musicians) or athletes if their net income is more than $1,500 during the tax year for their entertainment activities in the United States. 2010 federal tax return Regardless of this limit, the income of Indian entertainers and athletes is exempt from U. 2010 federal tax return S. 2010 federal tax return tax if their visit to the United States is wholly or substantially supported from the public funds of the Indian Government, its political subdivisions, or local authorities. 2010 federal tax return Indonesia Income that residents of Indonesia receive for performing personal services as individual contractors or self-employed individuals (independent personal services) in the United States during the tax year is exempt from U. 2010 federal tax return S. 2010 federal tax return income tax if the residents: Are present in the United States for no more than 119 days during any consecutive 12-month period, and Do not have a fixed base regularly available to them in the United States for performing the services. 2010 federal tax return If they have a fixed base available, they are taxed only on the income attributable to the fixed base. 2010 federal tax return Income that residents of Indonesia receive for personal services performed in the United States as employees (dependent personal services) is exempt from U. 2010 federal tax return S. 2010 federal tax return income tax if the residents meet three requirements. 2010 federal tax return They are present in the United States no more than 119 days during any consecutive 12-month period. 2010 federal tax return The income is paid by, or on behalf of, an employer who is not a resident of the United States. 2010 federal tax return The income is not borne or reimbursed by a permanent establishment the employer has in the United States. 2010 federal tax return Pay received by an individual for services performed as an employee aboard a ship or aircraft operated by an Indonesian resident in international traffic is exempt from U. 2010 federal tax return S. 2010 federal tax return tax if the individual is a member of the regular complement of the ship or aircraft. 2010 federal tax return These exemptions do not apply to income residents of Indonesia receive as public entertainers (such as theater, motion picture, radio, or television artists, or musicians) or athletes if their gross receipts, including reimbursed expenses, are more than $2,000 during any consecutive 12-month period. 2010 federal tax return Regardless of these limits, income of Indonesian entertainers and athletes is exempt from U. 2010 federal tax return S. 2010 federal tax return tax if their visit to the United States is substantially supported or sponsored by the Indonesian Government and the Indonesian competent authority certifies that the entertainers or athletes qualify for this exemption. 2010 federal tax return Ireland Income that residents of Ireland receive for personal services as independent contractors or self-employed individuals (independent personal services) in the United States is exempt from U. 2010 federal tax return S. 2010 federal tax return income tax if they do not have a fixed base regularly available to them in the United States for performing the services. 2010 federal tax return If they have a fixed base available in the United States, they are taxed on the income attributable to the fixed base. 2010 federal tax return Income that residents of Ireland receive for services performed in the United States as employees (dependent personal services) is exempt from U. 2010 federal tax return S. 2010 federal tax return income tax if the residents meet the following requirements. 2010 federal tax return They are in the United States for no more than 183 days in any 12-month period beginning or ending in the tax year. 2010 federal tax return Their income is paid by, or on behalf of, an employer who is not a U. 2010 federal tax return S. 2010 federal tax return resident. 2010 federal tax return Their income is not borne by a permanent establishment or a fixed base that the employer has in the United States. 2010 federal tax return These exemptions do not apply to directors' fees and similar payments received by a resident of Ireland as a member of the board of directors of a company that is a resident of the United States. 2010 federal tax return However, amounts received for attending meetings in Ireland are not subject to U. 2010 federal tax return S. 2010 federal tax return income tax. 2010 federal tax return Income received by a resident of Ireland for services performed as an employee and member of the regular complement of a ship or aircraft operated in international traffic is exempt from U. 2010 federal tax return S. 2010 federal tax return income tax. 2010 federal tax return These exemptions do not apply to public entertainers (such as theater, motion picture, radio, or television entertainers, musicians, and athletes) from Ireland who earn more than $20,000 in gross receipts, including reimbursed expenses, from their entertainment activities in the United States during the tax year. 2010 federal tax return Israel Income that residents of Israel receive for performing personal services as independent contractors or as self-employed individuals (independent personal services) in the United States during the tax year is exempt from U. 2010 federal tax return S. 2010 federal tax return income tax if they are in the United States for no more than 182 days during the tax year. 2010 federal tax return Income that residents of Israel receive for labor or personal services performed in the United States as employees (dependent personal services), including income for services performed by an officer of a corporation or company, is exempt from U. 2010 federal tax return S. 2010 federal tax return income tax if the residents meet four requirements. 2010 federal tax return They are in the United States for no more than 182 days during the tax year. 2010 federal tax return They are employees of a resident of, or a permanent establishment in, Israel. 2010 federal tax return Their income is not borne by a permanent establishment that the employer has in the United States. 2010 federal tax return Their income is subject to Israeli tax. 2010 federal tax return The exemption does not apply to pay received by an employee for labor or personal services performed as a member of the regular complement of a ship or an aircraft operated in international traffic by a U. 2010 federal tax return S. 2010 federal tax return resident. 2010 federal tax return These exemptions do not apply to income that residents of Israel receive as public entertainers (such as theater, motion picture, radio, or television artists, musicians, or athletes), if the gross amount of the income is more than $400 for each day they are in the United States performing the services. 2010 federal tax return Italy Income that residents of Italy receive for personal services as independent contractors or self-employed individuals (independent personal services) in the United States is exempt from U. 2010 federal tax return S. 2010 federal tax return income tax if they do not have a fixed base regularly available to them in the United States for performing the services. 2010 federal tax return If they have a fixed base available in the United States, they are taxed on the income attributable to the fixed base. 2010 federal tax return Income that residents of Italy receive for labor or personal services performed in the United States as employees (dependent personal services) is exempt from U. 2010 federal tax return S. 2010 federal tax return income tax if the following requirements are met. 2010 federal tax return The residents are in the United States for no more than 183 days during the tax year. 2010 federal tax return The income is paid by, or on behalf of, an employer who is not a resident of the United States. 2010 federal tax return The income is not borne by a permanent establishment or a fixed base that the employer has in the United States. 2010 federal tax return These exemptions do not apply to directors' fees and similar payments received by a resident of Italy for services performed in the United States as a member of the board of directors of a company that is a U. 2010 federal tax return S. 2010 federal tax return resident. 2010 federal tax return Pay received for employment regularly exercised aboard a ship or aircraft operated by a U. 2010 federal tax return S. 2010 federal tax return enterprise is subject to U. 2010 federal tax return S. 2010 federal tax return tax. 2010 federal tax return These exemptions do not apply to income residents of Italy receive as public entertainers (such as theater, motion picture, radio, or television artists, musicians, or athletes) if they are present in the United States for more than 90 days during the tax year or their gross receipts, including reimbursed expenses, are more than $20,000 during the tax year for their entertainment activities in the United States. 2010 federal tax return Jamaica Income that residents of Jamaica receive for the performance of personal services as independent contractors or self-employed individuals (independent personal services) in the United States during the tax year is exempt from U. 2010 federal tax return S. 2010 federal tax return income tax if the residents: Are in the United States for no more than 89 days during the tax year, Do not have a fixed base regularly available to them in the United States for performing their services, and Earn net income for those services that is not more than $5,000 during the tax year if the income is from a U. 2010 federal tax return S. 2010 federal tax return contractor. 2010 federal tax return If they have a fixed base available in the United States, they are taxed only on the income that is attributable to the fixed base. 2010 federal tax return There is no dollar limit for condition (3) if the contractor is from a country other than the United States. 2010 federal tax return Income that residents of Jamaica receive for personal services performed in the United States as employees (dependent personal services) is exempt from U. 2010 federal tax return S. 2010 federal tax return income tax if the residents meet four requirements. 2010 federal tax return They are in the United States for no more than 183 days during the tax year. 2010 federal tax return Their income is paid by or for an employer who is not a resident of the United States. 2010 federal tax return Their income is not borne by a permanent establishment or a fixed base that the employer has in the United States. 2010 federal tax return Their net income received for the services is not more than $5,000 during the tax year. 2010 federal tax return Pay received from employment as a member of the regular complement of a ship or an aircraft operated in international traffic by a Jamaican enterprise is exempt from U. 2010 federal tax return S. 2010 federal tax return tax. 2010 federal tax return If the ship or aircraft is operated by a U. 2010 federal tax return S. 2010 federal tax return enterprise, the pay is subject to U. 2010 federal tax return S. 2010 federal tax return tax. 2010 federal tax return These exemptions do not apply to income that residents of Jamaica receive for performing services in the United States as entertainers, such as theater, motion picture, radio, or television artists, musicians, or athletes, if the gross receipts (excluding reimbursements for expenses) from the services are more than $400 a day or $5,000 for the tax year. 2010 federal tax return Directors' fees received by residents of Jamaica for services performed in the United States as members of boards of directors of U. 2010 federal tax return S. 2010 federal tax return corporations are exempt from U. 2010 federal tax return S. 2010 federal tax return tax if the fees (excluding reimbursed expenses) are not more than $400 per day for each day the directors are present in the United States to perform the services. 2010 federal tax return Japan Income that residents of Japan receive for personal services as independent contractors or self-employed individuals is subject to the provisions of Article 7 (business profits) of the treaty. 2010 federal tax return Under that provision, business profits are exempt from U. 2010 federal tax return S. 2010 federal tax return income tax unless the individual has a permanent establishment in the United States. 2010 federal tax return If they have a permanent establishment in the United States, they are taxed on the profits attributable to the permanent establishment. 2010 federal tax return Income that residents of Japan receive for services performed in the United States as employees (dependent personal services) is exempt from U. 2010 federal tax return S. 2010 federal tax return income tax if the residents meet the following requirements. 2010 federal tax return They are in the United States for no more than 183 days in any 12-month period beginning or ending in the tax year. 2010 federal tax return Their income is paid by, or on behalf of, an employer who is not a U. 2010 federal tax return S. 2010 federal tax return resident. 2010 federal tax return Their income is not borne by a permanent establishment that the employer has in the United States. 2010 federal tax return The exemption does not apply to directors' fees and similar payments received by a resident of Japan for services performed as a member of the board of directors of a company that is a resident of the United States. 2010 federal tax return The exemption does not apply to a resident of Japan who performs services as an employee aboard a ship or an aircraft operated in international traffic by a U. 2010 federal tax return S. 2010 federal tax return resident. 2010 federal tax return Public entertainers (such as theater, motion picture, radio, or television artists, musicians, or athletes) from Japan who earn more than $10,000 in gross receipts, including reimbursed expenses, from their entertainment activities in the United States during the tax year are subject to U. 2010 federal tax return S. 2010 federal tax return tax. 2010 federal tax return Kazakhstan Income that residents of Kazakhstan receive for performing personal services as independent contractors or self-employed individuals (independent personal services) in the United States is exempt from U. 2010 federal tax return S. 2010 federal tax return income tax if: The residents are in the United States for no more than 183 days in any consecutive 12-month period, and The income is not attributable to a fixed base in the United States which is regularly available to the residents. 2010 federal tax return If the residents have a fixed base available, they are taxed only on the income attributable to the fixed base. 2010 federal tax return Income that residents of Kazakhstan receive for employment in the United States (dependent personal services) is exempt from U. 2010 federal tax return S. 2010 federal tax return income tax if the following three requirements are met. 2010 federal tax return The resident is in the United States for no more than 183 days in any 12-month period. 2010 federal tax return The income is paid by, or on behalf of, an employer who is not a resident of the United States. 2010 federal tax return The income is not borne by a permanent establishment or a fixed base that the employer has in the United States. 2010 federal tax return Income derived by a resident of Kazakhstan from employment as a member of the regular complement of a ship or aircraft operated in international traffic is exempt from U. 2010 federal tax return S. 2010 federal tax return tax. 2010 federal tax return These exemptions do not apply to directors' fees and similar payments received by a resident of Kazakhstan as a member of the board of directors or similar body of a company that is a U. 2010 federal tax return S. 2010 federal tax return resident. 2010 federal tax return Korea, South Income that residents of South Korea receive for performing personal services as independent contractors or self-employed individuals (independent personal services) in the United States during the tax year is exempt from U. 2010 federal tax return S. 2010 federal tax return tax if the residents: Are in the United States for no more than 182 days during the tax year, Earn income for those services that is not more than $3,000 during the tax year, and Do not maintain a fixed base in the United States for more than 182 days during the tax year. 2010 federal tax return If they maintain a fixed base in the United States for more than 182 days, they are taxed on the income attributable to the fixed base. 2010 federal tax return Income that residents of Korea receive for labor or personal services performed in the United States as employees (dependent personal services), including pay for services performed as an officer of a corporation, is exempt from U. 2010 federal tax return S. 2010 federal tax return tax if the residents meet four requirements. 2010 federal tax return They are in the United States for no more than 182 days during the tax year. 2010 federal tax return They are employees of a resident of Korea or of a permanent establishment maintained in Korea. 2010 federal tax return Their compensation is not borne by a permanent establishment that the employer has in the United States. 2010 federal tax return Their income for those services is not more than $3,000. 2010 federal tax return Pay received by employees who are members of the regular complement of a ship or aircraft operated by a resident of Korea in international traffic is exempt. 2010 federal tax return Latvia Income that residents of Latvia receive for performing personal services as independent contractors or self-employed individuals (independent personal services) in the United States is exempt from U. 2010 federal tax return S. 2010 federal tax return income tax if the residents: Are in the United States for no more than 183 days in any 12-month period beginning or ending in the tax year, and Do not have a fixed base regularly available to them in the United States for performing the services. 2010 federal tax return If they have a fixed base available, they are taxed only on the income attributable to the fixed base. 2010 federal tax return Income that residents of Latvia receive for services performed in the United States as employees (dependent personal services) is exempt from U. 2010 federal tax return S. 2010 federal tax return income tax if the following requirements are met. 2010 federal tax return The resident is in the United States for no more than 183 days in any 12-month period beginning or ending in the tax year. 2010 federal tax return The income is paid by, or on behalf of, an employer who is not a U. 2010 federal tax return S. 2010 federal tax return resident. 2010 federal tax return The income is not borne by a permanent establishment or a fixed base that the employer has in the United States. 2010 federal tax return The exemption does not apply to pay received for employment as a member of the regular complement of a ship or an aircraft operated in international traffic by a U. 2010 federal tax return S. 2010 federal tax return enterprise. 2010 federal tax return The exemptions do not apply to directors' fees and similar payments received by a resident of Latvia as a member of the board of directors or similar body of a company that is a U. 2010 federal tax return S. 2010 federal tax return resident. 2010 federal tax return The exemptions do not apply to income residents of Latvia receive as public entertainers (such as theater, motion picture, radio, or television artists, or musicians) or sportsmen if their gross receipts, including reimbursed expenses, are more than $20,000 for their personal activities in the United States during the tax year. 2010 federal tax return Regardless of these limits, income of Latvian entertainers or athletes is exempt from U. 2010 federal tax return S. 2010 federal tax return income tax if their visit to the United States is wholly or mainly supported by public funds of Latvia, its political subdivisions, or local authorities. 2010 federal tax return Lithuania Income that residents of Lithuania receive for performing personal services as independent contractors or self-employed individuals (independent personal services) in the United States is exempt from U. 2010 federal tax return S. 2010 federal tax return income tax if the residents: Are in the United States for no more than 183 days in any 12-month period beginning or ending in the tax year, and Do not have a fixed base regularly available to them in the United States for performing the services. 2010 federal tax return If they have a fixed base available, they are taxed only on the income attributable to the fixed base. 2010 federal tax return Income that residents of Lithuania receive for services performed in the United States as employees (dependent personal services) is exempt from U. 2010 federal tax return S. 2010 federal tax return income tax if the following requirements are met. 2010 federal tax return The resident is in the United States for no more than 183 days in any 12-month period beginning or ending in the tax year. 2010 federal tax return The income is paid by, or on behalf of, an employer who is not a U. 2010 federal tax return S. 2010 federal tax return resident. 2010 federal tax return The income is not borne by a permanent establishment or a fixed base that the employer has in the United States. 2010 federal tax return The exemption does not apply to pay received for employment as a member of the regular complement of a ship or an aircraft operated in international traffic by a U. 2010 federal tax return S. 2010 federal tax return enterprise. 2010 federal tax return The exemptions do not apply to directors' fees and similar payments received by a resident of Lithuania as a member of the board of directors or similar body of a company that is a U. 2010 federal tax return S. 2010 federal tax return resident. 2010 federal tax return The exemptions do not apply to income residents of Lithuania receive as public entertainers (such as theater, motion picture, radio, or television artists, or musicians) or sportsmen if their gross receipts, including reimbursed expenses, are more than $20,000 for their personal activities in the United States during the tax year. 2010 federal tax return Regardless of these limits, income of Lithuanian entertainers or athletes is exempt from U. 2010 federal tax return S. 2010 federal tax return income tax if their visit to the United States is wholly or mainly supported by public funds of Lithuania, its political subdivisions, or local authorities. 2010 federal tax return Luxembourg Income that residents of Luxembourg receive for personal services as independent contractors or self-employed individuals (independent personal services) in the United States is exempt from U. 2010 federal tax return S. 2010 federal tax return income tax if they do not have a fixed base regularly available to them in the United States for performing the services. 2010 federal tax return If they have a fixed base available in the United States, they are taxed on the income attributable to the fixed base. 2010 federal tax return Income that residents of Luxembourg receive for services performed in the United States as employees (dependent personal services) is exempt from U. 2010 federal tax return S. 2010 federal tax return income tax if the residents meet the following requirements. 2010 federal tax return They are in the United States for no more than 183 days in any 12-month period beginning or ending in the tax year. 2010 federal tax return Their income is paid by, or on behalf of, an employer who is not a U. 2010 federal tax return S. 2010 federal tax return resident. 2010 federal tax return Their income is not borne by a permanent establishment or a fixed base that the employer has in the United States. 2010 federal tax return The exemption does not apply to pay received for employment exercised continuously or predominantly aboard a ship or aircraft operated in international traffic by a U. 2010 federal tax return S. 2010 federal tax return enterprise. 2010 federal tax return The exemptions do not apply to directors' fees and similar payments received by a resident of Luxembourg for services performed in the United States as a member of the board of directors of a company that is a resident of the United States. 2010 federal tax return The exemptions do not apply to public entertainers (such as theater, motion picture, radio, or television artists, musicians, or athletes) from Luxembourg who earn more than $10,000 in gross receipts, including reimbursed expenses, from their entertainment activities in the United States during the tax year. 2010 federal tax return Malta Income that residents of Malta receive for personal services as independent contractors or self-employed individuals is subject to the provisions of Article 7 (Business Profits) of the treaty. 2010 federal tax return Under that provision, business profits are exempt from U. 2010 federal tax return S. 2010 federal tax return income tax unless the individual has a permanent establishment in the United States. 2010 federal tax return If they have a permanent establishment in the United States, they are taxed on the profits attributable to the permanent establishment. 2010 federal tax return Income that residents of Malta receive for services performed in the United States as employees (dependent personal services) is exempt from U. 2010 federal tax return S. 2010 federal tax return income tax if the residents meet the following requirements. 2010 federal tax return They are in the United States for no more than 183 days in any 12-month period beginning or ending in the tax year. 2010 federal tax return Their income is paid by, or on behalf of, an employer who is not a U. 2010 federal tax return S. 2010 federal tax return resident. 2010 federal tax return Their income is not borne by a permanent establishment that the employer has in the United States. 2010 federal tax return The exemption does not apply to directors' fees and similar payments received by a resident of Malta for services performed in the United States as a member of the board of directors of a company that is a resident of the United States. 2010 federal tax return Public entertainers (such as theater, motion picture, radio, or television artists, musicians, or athletes) from Malta who earn more than $20,000 in gross receipts, including reimbursed expenses, from their entertainment activities in the United States during the tax year are subject to U. 2010 federal tax return S. 2010 federal tax return tax. 2010 federal tax return Income received by a resident of Malta for employment aboard a ship or an aircraft operated in international traffic is exempt from U. 2010 federal tax return S. 2010 federal tax return income tax if the individual is a member of the regular complement of the ship or aircraft. 2010 federal tax return Mexico Income that residents of Mexico receive for performing personal services as independent contractors or self-employed individuals (independent personal services) in the United States is exempt from U. 2010 federal tax return S. 2010 federal tax return income tax if the residents: Are in the United States for no more than 182 days in a 12-month period, and Do not have a fixed base that they regularly use for performing the services. 2010 federal tax return If they have a fixed base available, they are taxed only on income attributable to the fixed base. 2010 federal tax return Income that residents of Mexico receive for employment in the United States (dependent personal services) is exempt from U. 2010 federal tax return S. 2010 federal tax return tax if the following three requirements are met. 2010 federal tax return The resident is present in the United States for no more than 183 days in a 12-month period. 2010 federal tax return The income is paid by, or on behalf of, an employer who is not a resident of the United States. 2010 federal tax return The income is not borne by a permanent establishment or fixed base that the employer has in the United States. 2010 federal tax return These exemptions do not apply to directors' fees and similar payments received by a resident of Mexico for services performed outside Mexico as a director or overseer of a company that is a U. 2010 federal tax return S. 2010 federal tax return resident. 2010 federal tax return These exemptions do not apply to income residents of Mexico receive as public entertainers (such as theater, motion picture, radio, or television artists, or musicians) or athletes if the income, including reimbursed expenses, is more than $3,000 during the tax year for their entertainment activities in the United States. 2010 federal tax return This includes income from activities performed in the United States relating to the entertainer or athlete's reputation, such as endorsements of commercial products. 2010 federal tax return Regardless of this limit, the income of Mexican entertainers and athletes is exempt from U. 2010 federal tax return S. 2010 federal tax return tax if their visit to the United States is substantially supported by public funds of Mexico, its political subdivisions, or local authorities. 2010 federal tax return Morocco Income that residents of Morocco receive for performing personal services as independent contractors or as self-employed persons (independent personal services) in the United States during the tax year is exempt from U. 2010 federal tax return S. 2010 federal tax return income tax if the residents: Are in the United States for no more than 182 days during the tax year, Do not maintain a fixed base in the United States for more than 89 days during the tax year, and Earn total income for those services that is not more than $5,000. 2010 federal tax return If they have a fixed base in the United States for more than 89 days, they are taxed only on the income attributable to the fixed base. 2010 federal tax return Income that residents of Morocco receive for labor or personal services performed in the United States as employees (dependent personal services) is exempt from U. 2010 federal tax return S. 2010 federal tax return income tax if the residents meet three requirements. 2010 federal tax return They are in the United States for less than 183 days during the tax year. 2010 federal tax return They are employees of a resident of Morocco or of a permanent establishment of a resident of a country other than Morocco if the permanent establishment is located in Morocco. 2010 federal tax return Their income is not borne by a permanent establishment that the employer has in the United States. 2010 federal tax return Compensation received for services performed by a member of the board of directors of a corporation does not qualify for this exemption. 2010 federal tax return Income received by an individual for performing labor or personal services as an employee aboard a ship or an aircraft operated in international traffic by a Moroccan resident is exempt from U. 2010 federal tax return S. 2010 federal tax return income tax if the individual is a member of the regular complement of the ship or aircraft. 2010 federal tax return These exemptions do not apply to income received for services performed in the United States by professional entertainers, including theater, film, radio, and television performers, musicians, and athletes, unless the services are performed by, or for the account of, a Moroccan nonprofit organization. 2010 federal tax return Netherlands Income that residents of the Netherlands receive for performing personal services as independent contractors or self-employed individuals (independent personal services) in the United States is exempt from U. 2010 federal tax return S. 2010 federal tax return income tax if the income is not attributable to a fixed base in the United States that is regularly available for performing the services. 2010 federal tax return Income that residents of the Netherlands receive for employment in the United States (dependent personal services) is exempt from U. 2010 federal tax return S. 2010 federal tax return income tax if the following three requirements are met. 2010 federal tax return The resident is in the United States for no more than 183 days during the tax year. 2010 federal tax return The income is paid by, or on behalf of, an employer who is not a U. 2010 federal tax return S. 2010 federal tax return resident. 2010 federal tax return The income is not borne by a permanent establishment or fixed base the employer has in the United States. 2010 federal tax return Income received by a Netherlands resident for employment as a member of the regular complement of a ship or
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The 2010 Federal Tax Return

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