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Taxact returning user Publication 514 - Additional Material Prev  Up  Next   Home   More Online Publications
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Understanding your CP22A Notice

We made the change(s) you requested to your tax return for the tax year specified on the notice. You owe money on your taxes as a result of the change(s).

Printable samples of this notice (PDF)

Tax publications you may find useful

How to get help

Calling the toll free number listed on the top right corner of your notice is the fastest way to get your questions answered.

You can also authorize someone (such as an accountant) to contact the IRS on your behalf using this Power of Attorney and Declaration of Representative (Form 2848).

Or you may qualify for help from a Low Income Taxpayer Clinic.
 


What you need to do

  • Read your notice carefully ― it will explain why you owe money on your taxes.
  • Pay the amount owed by the date on the notice's payment coupon.
  • Make payment arrangements if you can't pay the full amount you owe.
  • Contact us if you disagree with the change(s) we made.
  • Correct the copy of your tax return that you kept for your records.

You may want to...


Answers to Common Questions

The notice says "Based on the information you provided, we changed your 200X Form 1040 to correct your:..." but I don't remember sending any change to IRS. How can I find out what IRS received to initiate this change?
Please contact us at the number listed on the top right corner of your notice for specific information about your tax return.

What do I say when I call the IRS?
Mention that you got a CP22A notice with a balance due and you need to review your account with a customer service representative. Be sure to have a copy of your notice and your tax return before you call.

What should I do if I disagree with the changes you made?
If you disagree, contact us at the toll-free number listed on the top right corner of your notice.

What happens if I can't pay the full amount I owe?
You can arrange to make a payment plan with us if you can't pay the full amount you owe.

Am I charged interest on the money I owe?
If you don't full pay the amount you owe by the date on the payment coupon, interest will accrue on the unpaid balance after that date.

Will I receive a penalty if I can't pay the full amount?
Yes, you'll receive a late payment penalty. You can contact us at the number listed on your notice if you’re unable to pay the full amount shown in your specific notice because of circumstances beyond your control. Contact us by the due date of your payment and, depending on your situation, we may be able to remove the penalty.

Can I set up a payment plan?
Yes. Call the toll-free number listed on the top right corner of your notice to discuss payment options or check out more information on payment options and how to make a payment arrangement.

There are other options, such as paying by credit card. Note: There may be a fee to pay by credit card.

What if I need to make another correction to my account?
You'll need to file Form 1040X, Amended U.S. Individual Income Tax Return.

What if I have tried to get answers and after contacting IRS several times have not been successful?
Call Taxpayer Advocate at 1-877-777-4778 or for TTY/TDD 1-800-829-4059.

What if I think I’m a victim of identity theft?
Please contact us at the number listed on the top right corner of your notice. Refer to the IRS Identity Theft resource page for more information.


Tips for next year

Consider filing your taxes electronically. Filing online can help you avoid mistakes and find credits and deductions that you may qualify for. In many cases you can file for free. Learn more about e-file.

Page Last Reviewed or Updated: 03-Mar-2014

The Taxact Returning User

Taxact returning user 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. Taxact returning user Under these treaties, residents (not necessarily citizens) of foreign countries are taxed at a reduced rate, or are exempt from U. Taxact returning user S. Taxact returning user income taxes on certain items of income they receive from sources within the United States. Taxact returning user These reduced rates and exemptions vary among countries and specific items of income. Taxact returning user 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. Taxact returning user Also see Publication 519. Taxact returning user Many of the individual states of the United States tax the income of their residents. Taxact returning user 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. Taxact returning user Tax treaties reduce the U. Taxact returning user S. Taxact returning user taxes of residents of foreign countries. Taxact returning user With certain exceptions, they do not reduce the U. Taxact returning user S. Taxact returning user taxes of U. Taxact returning user S. Taxact returning user citizens or residents. Taxact returning user U. Taxact returning user S. Taxact returning user citizens and residents are subject to U. Taxact returning user S. Taxact returning user income tax on their worldwide income. Taxact returning user Treaty provisions generally are reciprocal (apply to both treaty countries); therefore, a U. Taxact returning user S. Taxact returning user 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. Taxact returning user Foreign taxing authorities sometimes require certification from the U. Taxact returning user S. Taxact returning user Government that an applicant filed an income tax return as a U. Taxact returning user S. Taxact returning user citizen or resident, as part of the proof of entitlement to the treaty benefits. Taxact returning user See Form 8802, Application for United States Residency Certification, to request a certification. Taxact returning user Disclosure of a treaty-based position that reduces your tax. Taxact returning user   If you take the position that any U. Taxact returning user S. Taxact returning user tax is overruled or otherwise reduced by a U. Taxact returning user S. Taxact returning user treaty (a treaty-based position), you generally must disclose that position on Form 8833 and attach it to your return. Taxact returning user 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. Taxact returning user 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. Taxact returning user For more information, see Publication 519 and the Form 8833 instructions. Taxact returning user   If you fail to file Form 8833, you may have to pay a $1,000 penalty. Taxact returning user Corporations are subject to a $10,000 penalty for each failure. Taxact returning user 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. Taxact returning user Pay for certain personal services performed in the United States. Taxact returning user Pay of a professor, teacher, or researcher who teaches or performs research in the United States for a limited time. Taxact returning user Amounts received for maintenance and studies by a foreign student or apprentice who is here for study or experience. Taxact returning user Wages, salaries, and pensions paid by a foreign government. Taxact returning user Personal Services Income Pay for certain personal services performed in the United States is exempt from U. Taxact returning user S. Taxact returning user 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. Taxact returning user For this purpose, the word “day” means a day during any part of which you are physically present in the United States. Taxact returning user Terms defined. Taxact returning user   Several terms appear in many of the discussions that follow. Taxact returning user The exact meanings of the terms are determined by the particular tax treaty under discussion; thus, the meanings vary among treaties. Taxact returning user The definitions that follow are, therefore, general definitions that may not give the exact meaning intended by a particular treaty. Taxact returning user   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. Taxact returning user   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. Taxact returning user 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. Taxact returning user S. Taxact returning user 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. Taxact returning user If they have a fixed base available in the United States, they are taxed on the income attributable to the fixed base. Taxact returning user 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. Taxact returning user S. Taxact returning user 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. Taxact returning user 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. Taxact returning user 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. Taxact returning user S. Taxact returning user income tax if they do not have a fixed base regularly available to them in the United States for performing the services. Taxact returning user If they have a fixed base available in the United States, they are taxed on the income attributable to the fixed base. Taxact returning user Income that residents of Austria receive for services performed in the United States as employees (dependent personal services) is exempt from U. Taxact returning user S. Taxact returning user income tax if the residents meet the following requirements. Taxact returning user They are in the United States for no more than 183 days in any 12-month period beginning or ending in the tax year. Taxact returning user Their income is paid by, or on behalf of, an employer who is not a U. Taxact returning user S. Taxact returning user resident. Taxact returning user Their income is not borne by a permanent establishment or a fixed base that the employer has in the United States. Taxact returning user 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. Taxact returning user 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. Taxact returning user S. Taxact returning user income tax. Taxact returning user 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. Taxact returning user S. Taxact returning user 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. Taxact returning user If they have a fixed base available in the United States, they are taxed on the income attributable to the fixed base. Taxact returning user Income that residents of Bangladesh receive for services performed in the United States as employees (dependent personal services) is exempt from U. Taxact returning user S. Taxact returning user income tax if the residents meet the following requirements. Taxact returning user They are in the United States for no more than 183 days in any 12-month period beginning or ending in the tax year. Taxact returning user Their income is paid by, or on behalf of, an employer who is not a U. Taxact returning user S. Taxact returning user resident. Taxact returning user Their income is not borne by a permanent establishment or a fixed base that the employer has in the United States. Taxact returning user 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. Taxact returning user Regardless of these limits, income of Bangladesh entertainers is exempt from U. Taxact returning user S. Taxact returning user 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. Taxact returning user 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. Taxact returning user S. Taxact returning user tax. Taxact returning user If the ship or aircraft is operated by a U. Taxact returning user S. Taxact returning user enterprise, the income is subject to U. Taxact returning user S. Taxact returning user tax. Taxact returning user If the resident of Bangladesh is a shareholder in a U. Taxact returning user S. Taxact returning user corporation, these exemptions do not apply to directors' fees received as a member of the board of directors of the U. Taxact returning user S. Taxact returning user corporation. Taxact returning user 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. Taxact returning user S. Taxact returning user tax at the rate of 15%. Taxact returning user 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. Taxact returning user S. Taxact returning user 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. Taxact returning user S. Taxact returning user residents that is not more than $5,000 (there is no dollar limit if the contractors are not U. Taxact returning user S. Taxact returning user residents), and Do not have a regular base available in the United States for performing the services. Taxact returning user 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. Taxact returning user Income that residents of Barbados receive for personal services performed in the United States as employees (dependent personal services) is exempt from U. Taxact returning user S. Taxact returning user tax if the residents meet four requirements. Taxact returning user They are in the United States for no more than 183 days during the calendar year. Taxact returning user The income earned in the calendar year in the United States is not more than $5,000. Taxact returning user Their income is paid by or for an employer who is not a U. Taxact returning user S. Taxact returning user resident. Taxact returning user The income is not borne by a permanent establishment or regular base of the employer in the United States. Taxact returning user 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. Taxact returning user S. Taxact returning user tax. Taxact returning user 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. Taxact returning user 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. Taxact returning user 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. Taxact returning user Under that provision, business profits are exempt from U. Taxact returning user S. Taxact returning user income tax unless the individual has a permanent establishment in the United States. Taxact returning user If they have a permanent establishment in the United States, they are taxed on the profit attributable to the permanent establishment. Taxact returning user Income that residents of Belgium receive for services performed in the United States as employees (dependent personal services) is exempt from U. Taxact returning user S. Taxact returning user income tax if the residents meet the following requirements. Taxact returning user They are in the United States for no more than 183 days in any 12-month period beginning or ending in the tax year. Taxact returning user Their income is paid by, or on behalf of, an employer who is not a U. Taxact returning user S. Taxact returning user resident. Taxact returning user Their income is not borne by a permanent establishment that the employer has in the United States. Taxact returning user 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. Taxact returning user 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. Taxact returning user S. Taxact returning user tax. Taxact returning user 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. Taxact returning user S. Taxact returning user income tax. Taxact returning user 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. Taxact returning user Under that provision, business profits are exempt from U. Taxact returning user S. Taxact returning user income tax unless the individual has a permanent establishment in the United States. Taxact returning user If they have a permanent establishment in the United States, they are taxed on the profit attributable to the permanent establishment. Taxact returning user 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. Taxact returning user Income that residents of Bulgaria receive for services performed in the United States as employees (dependent personal services) is exempt from U. Taxact returning user S. Taxact returning user income tax if the residents meet the following requirements. Taxact returning user They are in the United States for no more than 183 days in any 12-month period beginning or ending in the tax year. Taxact returning user Their income is paid by, or on behalf of, an employer who is not a U. Taxact returning user S. Taxact returning user resident. Taxact returning user Their income is not borne by a permanent establishment that the employer has in the United States. Taxact returning user 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. Taxact returning user S. Taxact returning user company. Taxact returning user 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. Taxact returning user S. Taxact returning user tax. Taxact returning user 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. Taxact returning user S. Taxact returning user income tax. Taxact returning user 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. Taxact returning user Under that provision, business profits are exempt from U. Taxact returning user S. Taxact returning user income tax unless the individual has a permanent establishment in the United States. Taxact returning user If they have a permanent establishment in the United States, they are taxed on the profit attributable to the permanent establishment. Taxact returning user 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. Taxact returning user Income that residents of Canada receive for personal services performed as employees (dependent personal services) in the United States is exempt from U. Taxact returning user S. Taxact returning user tax if it is not more than $10,000 for the year. Taxact returning user 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. Taxact returning user S. Taxact returning user resident, and is not borne by a permanent establishment in the United States. Taxact returning user 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. Taxact returning user S. Taxact returning user tax. Taxact returning user 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. Taxact returning user 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. Taxact returning user S. Taxact returning user tax. Taxact returning user 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. Taxact returning user S. Taxact returning user 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. Taxact returning user If they have a fixed base available in the United States, they are taxable on the income attributable to the fixed base. Taxact returning user 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. Taxact returning user S. Taxact returning user 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. Taxact returning user S. Taxact returning user resident, and The pay is not borne by a permanent establishment or fixed base that the employer has in the United States. Taxact returning user These exemptions do not apply to directors' fees for service on the board of directors of a U. Taxact returning user S. Taxact returning user corporation. Taxact returning user 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). Taxact returning user However, income of athletes or public entertainers from China participating in a cultural exchange program agreed upon by the U. Taxact returning user S. Taxact returning user and Chinese governments is exempt from U. Taxact returning user S. Taxact returning user tax. Taxact returning user Commonwealth of Independent States Income that residents of a C. Taxact returning user I. Taxact returning user S. Taxact returning user member receive for performing personal services in the United States is exempt from U. Taxact returning user S. Taxact returning user income tax if those residents are in the United States for no more than 183 days during the tax year. Taxact returning user 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. Taxact returning user I. Taxact returning user S. Taxact returning user member or a resident of a C. Taxact returning user I. Taxact returning user S. Taxact returning user member is exempt from U. Taxact returning user S. Taxact returning user tax. Taxact returning user 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. Taxact returning user S. Taxact returning user 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. Taxact returning user If they have a fixed base available in the United States, they are taxable on the income attributable to the fixed base. Taxact returning user 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. Taxact returning user S. Taxact returning user 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. Taxact returning user S. Taxact returning user 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. Taxact returning user 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. Taxact returning user S. Taxact returning user tax. Taxact returning user 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. Taxact returning user Directors' fees received by residents of Cyprus for service on the board of directors of a U. Taxact returning user S. Taxact returning user corporation are exempt from U. Taxact returning user S. Taxact returning user 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. Taxact returning user 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. Taxact returning user S. Taxact returning user 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. Taxact returning user If they have a fixed base available, they are taxed only on income attributable to the fixed base. Taxact returning user Income that residents of the Czech Republic receive for employment in the United States (dependent personal services) is exempt from U. Taxact returning user S. Taxact returning user income tax if the following three requirements are met. Taxact returning user The resident is present in the United States for no more than 183 days in any 12-month period. Taxact returning user The income is paid by, or on behalf of, an employer who is not a U. Taxact returning user S. Taxact returning user resident. Taxact returning user The income is not borne by a permanent establishment or a fixed base that the employer has in the United States. Taxact returning user 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. Taxact returning user Regardless of these limits, income of Czech entertainers and sportsmen is exempt from U. Taxact returning user S. Taxact returning user 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. Taxact returning user 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. Taxact returning user 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. Taxact returning user S. Taxact returning user income tax. Taxact returning user If the ship or aircraft is operated by a U. Taxact returning user S. Taxact returning user enterprise, the income is subject to U. Taxact returning user S. Taxact returning user tax. Taxact returning user 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. Taxact returning user S. Taxact returning user income tax if they do not have a fixed base regularly available to them in the United States for performing the services. Taxact returning user If they have a fixed base available in the United States, they are taxed on the income attributable to the fixed base. Taxact returning user Income that residents of Denmark receive for services performed in the United States as employees (dependent personal services) is exempt from U. Taxact returning user S. Taxact returning user income tax if the residents meet the following requirements. Taxact returning user They are in the United States for no more than 183 days in any 12-month period beginning or ending in the tax year. Taxact returning user Their income is paid by, or on behalf of, an employer who is not a U. Taxact returning user S. Taxact returning user resident. Taxact returning user Their income is not borne by a permanent establishment or a fixed base that the employer has in the United States. Taxact returning user 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. Taxact returning user 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. Taxact returning user 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. Taxact returning user S. Taxact returning user income tax. Taxact returning user 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. Taxact returning user S. Taxact returning user income tax if they are in the United States for no more than 89 days during the tax year. Taxact returning user 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. Taxact returning user S. Taxact returning user income tax if the residents meet four requirements. Taxact returning user They are in the United States for no more than 89 days during the tax year. Taxact returning user They are employees of a resident of, or a permanent establishment in, Egypt. Taxact returning user Their income is not borne by a permanent establishment that the employer has in the United States. Taxact returning user Their income is subject to Egyptian tax. Taxact returning user 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. Taxact returning user 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. Taxact returning user 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. Taxact returning user S. Taxact returning user 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. Taxact returning user If they have a fixed base available, they are taxed on the income attributable to the fixed base. Taxact returning user Income that residents of Estonia receive for services performed in the United States as employees (dependent personal services) is exempt from U. Taxact returning user S. Taxact returning user income tax if the following requirements are met. Taxact returning user 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. Taxact returning user The income is paid by, or on behalf of, an employer who is not a U. Taxact returning user S. Taxact returning user resident. Taxact returning user The income is not borne by a permanent establishment or a fixed base that the employer has in the United States. Taxact returning user 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. Taxact returning user S. Taxact returning user resident. Taxact returning user 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. Taxact returning user S. Taxact returning user tax. Taxact returning user 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. Taxact returning user Regardless of these limits, income of Estonian entertainers or athletes is exempt from U. Taxact returning user S. Taxact returning user 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. Taxact returning user 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. Taxact returning user S. Taxact returning user income tax if they do not have a fixed base regularly available to them in the United States for performing the services. Taxact returning user If they have a fixed base available in the United States, they are taxed on the income attributable to the fixed base. Taxact returning user 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. Taxact returning user S. Taxact returning user income tax if the residents meet three requirements. Taxact returning user They are in the United States for no more than 183 days during any 12-month period. Taxact returning user Their income is paid by, or on behalf of, an employer who is not a resident of the United States. Taxact returning user Their income is not borne by a permanent establishment, fixed base, or trade or business that the employer has in the United States. Taxact returning user 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. Taxact returning user 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. Taxact returning user 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. Taxact returning user S. Taxact returning user income tax if they do not have a fixed base regularly available to them in the United States for performing the services. Taxact returning user If they have a fixed base available in the United States, they are taxed on the income attributable to the fixed base. Taxact returning user 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. Taxact returning user S. Taxact returning user income tax if the residents meet three requirements. Taxact returning user They are in the United States for no more than 183 days in any 12-month period. Taxact returning user Their income is paid by, or on behalf of, an employer who is not a resident of the United States. Taxact returning user Their income is not borne by a permanent establishment or a fixed base that the employer has in the United States. Taxact returning user 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. Taxact returning user 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. Taxact returning user Regardless of these limits, income of French entertainers or sportsmen is exempt from U. Taxact returning user S. Taxact returning user tax if their visit is principally supported by public funds of France. Taxact returning user 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. Taxact returning user 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. Taxact returning user Under that provision, business profits are exempt from U. Taxact returning user S. Taxact returning user income tax unless the individual has a permanent establishment in the United States. Taxact returning user If they have a permanent establishment in the United States, they are taxed on the profit attributable to the permanent establishment. Taxact returning user 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. Taxact returning user S. Taxact returning user tax if the residents meet three requirements. Taxact returning user They are in the United States for no more than 183 days during the calendar year. Taxact returning user The income is paid by, or on behalf of, an employer who is not a resident of the United States. Taxact returning user The income is not borne by a permanent establishment that the employer has in the United States. Taxact returning user 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. Taxact returning user S. Taxact returning user tax. Taxact returning user 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. Taxact returning user 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. Taxact returning user S. Taxact returning user 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. Taxact returning user Income of German entertainers or athletes is exempt from U. Taxact returning user S. Taxact returning user tax if their visit to the United States is substantially supported by public funds of Germany, its political subdivisions, or local authorities. Taxact returning user Greece Income that residents of Greece receive for labor or personal services (including practicing liberal and artistic professions) is exempt from U. Taxact returning user S. Taxact returning user 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. Taxact returning user The pay, regardless of amount, is exempt from U. Taxact returning user S. Taxact returning user 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. Taxact returning user 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. Taxact returning user S. Taxact returning user 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. Taxact returning user If they have a fixed base available in the United States, they are taxed on the income attributable to the fixed base. Taxact returning user 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. Taxact returning user S. Taxact returning user income tax if the residents meet three requirements. Taxact returning user They are in the United States for no more than 183 days during the tax year. Taxact returning user Their income is paid by or on behalf of an employer who is not a resident of the United States. Taxact returning user Their income is not borne by a permanent establishment or a fixed base that the employer has in the United States. Taxact returning user 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. Taxact returning user S. Taxact returning user tax. Taxact returning user If the ship or aircraft is operated by a U. Taxact returning user S. Taxact returning user enterprise, the pay is subject to U. Taxact returning user S. Taxact returning user tax. Taxact returning user 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. Taxact returning user Under that provision, business profits are exempt from U. Taxact returning user S. Taxact returning user income tax unless the individual has a permanent establishment in the United States. Taxact returning user If they have a permanent establishment in the United States, they are taxed on the profit attributable to the permanent establishment. Taxact returning user Income that residents of Iceland receive for services performed in the United States as employees (dependent personal services) is exempt from U. Taxact returning user S. Taxact returning user income tax if the residents meet the following requirements. Taxact returning user They are in the United States for no more than 183 days in any 12-month period beginning or ending in the tax year. Taxact returning user Their income is paid by, or on behalf of, an employer who is not a U. Taxact returning user S. Taxact returning user resident. Taxact returning user Their income is not borne by a permanent establishment that the employer has in the United States. Taxact returning user 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. Taxact returning user S. Taxact returning user company. Taxact returning user 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. Taxact returning user S. Taxact returning user tax. Taxact returning user 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. Taxact returning user S. Taxact returning user income tax. Taxact returning user 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. Taxact returning user S. Taxact returning user 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. Taxact returning user If they have a fixed base available, they are taxed only on income attributable to the fixed base. Taxact returning user Income that residents of India receive for personal services performed in the United States as employees (dependent personal services) is exempt from U. Taxact returning user S. Taxact returning user income tax if the residents meet three requirements. Taxact returning user They are present in the United States for no more than 183 days during the tax year. Taxact returning user The income is paid by, or on behalf of, an employer who is not a resident of the United States. Taxact returning user The income is not borne by a permanent establishment, fixed base, or trade or business the employer has in the United States. Taxact returning user 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. Taxact returning user S. Taxact returning user enterprise. Taxact returning user 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. Taxact returning user S. Taxact returning user resident. Taxact returning user 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. Taxact returning user Regardless of this limit, the income of Indian entertainers and athletes is exempt from U. Taxact returning user S. Taxact returning user 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. Taxact returning user 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. Taxact returning user S. Taxact returning user 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. Taxact returning user If they have a fixed base available, they are taxed only on the income attributable to the fixed base. Taxact returning user Income that residents of Indonesia receive for personal services performed in the United States as employees (dependent personal services) is exempt from U. Taxact returning user S. Taxact returning user income tax if the residents meet three requirements. Taxact returning user They are present in the United States no more than 119 days during any consecutive 12-month period. Taxact returning user The income is paid by, or on behalf of, an employer who is not a resident of the United States. Taxact returning user The income is not borne or reimbursed by a permanent establishment the employer has in the United States. Taxact returning user 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. Taxact returning user S. Taxact returning user tax if the individual is a member of the regular complement of the ship or aircraft. Taxact returning user 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. Taxact returning user Regardless of these limits, income of Indonesian entertainers and athletes is exempt from U. Taxact returning user S. Taxact returning user 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. Taxact returning user 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. Taxact returning user S. Taxact returning user income tax if they do not have a fixed base regularly available to them in the United States for performing the services. Taxact returning user If they have a fixed base available in the United States, they are taxed on the income attributable to the fixed base. Taxact returning user Income that residents of Ireland receive for services performed in the United States as employees (dependent personal services) is exempt from U. Taxact returning user S. Taxact returning user income tax if the residents meet the following requirements. Taxact returning user They are in the United States for no more than 183 days in any 12-month period beginning or ending in the tax year. Taxact returning user Their income is paid by, or on behalf of, an employer who is not a U. Taxact returning user S. Taxact returning user resident. Taxact returning user Their income is not borne by a permanent establishment or a fixed base that the employer has in the United States. Taxact returning user 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. Taxact returning user However, amounts received for attending meetings in Ireland are not subject to U. Taxact returning user S. Taxact returning user income tax. Taxact returning user 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. Taxact returning user S. Taxact returning user income tax. Taxact returning user 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. Taxact returning user 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. Taxact returning user S. Taxact returning user income tax if they are in the United States for no more than 182 days during the tax year. Taxact returning user 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. Taxact returning user S. Taxact returning user income tax if the residents meet four requirements. Taxact returning user They are in the United States for no more than 182 days during the tax year. Taxact returning user They are employees of a resident of, or a permanent establishment in, Israel. Taxact returning user Their income is not borne by a permanent establishment that the employer has in the United States. Taxact returning user Their income is subject to Israeli tax. Taxact returning user 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. Taxact returning user S. Taxact returning user resident. Taxact returning user 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. Taxact returning user 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. Taxact returning user S. Taxact returning user income tax if they do not have a fixed base regularly available to them in the United States for performing the services. Taxact returning user If they have a fixed base available in the United States, they are taxed on the income attributable to the fixed base. Taxact returning user 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. Taxact returning user S. Taxact returning user income tax if the following requirements are met. Taxact returning user The residents are in the United States for no more than 183 days during the tax year. Taxact returning user The income is paid by, or on behalf of, an employer who is not a resident of the United States. Taxact returning user The income is not borne by a permanent establishment or a fixed base that the employer has in the United States. Taxact returning user 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. Taxact returning user S. Taxact returning user resident. Taxact returning user Pay received for employment regularly exercised aboard a ship or aircraft operated by a U. Taxact returning user S. Taxact returning user enterprise is subject to U. Taxact returning user S. Taxact returning user tax. Taxact returning user 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. Taxact returning user 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. Taxact returning user S. Taxact returning user 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. Taxact returning user S. Taxact returning user contractor. Taxact returning user 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. Taxact returning user There is no dollar limit for condition (3) if the contractor is from a country other than the United States. Taxact returning user Income that residents of Jamaica receive for personal services performed in the United States as employees (dependent personal services) is exempt from U. Taxact returning user S. Taxact returning user income tax if the residents meet four requirements. Taxact returning user They are in the United States for no more than 183 days during the tax year. Taxact returning user Their income is paid by or for an employer who is not a resident of the United States. Taxact returning user Their income is not borne by a permanent establishment or a fixed base that the employer has in the United States. Taxact returning user Their net income received for the services is not more than $5,000 during the tax year. Taxact returning user 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. Taxact returning user S. Taxact returning user tax. Taxact returning user If the ship or aircraft is operated by a U. Taxact returning user S. Taxact returning user enterprise, the pay is subject to U. Taxact returning user S. Taxact returning user tax. Taxact returning user 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. Taxact returning user Directors' fees received by residents of Jamaica for services performed in the United States as members of boards of directors of U. Taxact returning user S. Taxact returning user corporations are exempt from U. Taxact returning user S. Taxact returning user 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. Taxact returning user 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. Taxact returning user Under that provision, business profits are exempt from U. Taxact returning user S. Taxact returning user income tax unless the individual has a permanent establishment in the United States. Taxact returning user If they have a permanent establishment in the United States, they are taxed on the profits attributable to the permanent establishment. Taxact returning user Income that residents of Japan receive for services performed in the United States as employees (dependent personal services) is exempt from U. Taxact returning user S. Taxact returning user income tax if the residents meet the following requirements. Taxact returning user They are in the United States for no more than 183 days in any 12-month period beginning or ending in the tax year. Taxact returning user Their income is paid by, or on behalf of, an employer who is not a U. Taxact returning user S. Taxact returning user resident. Taxact returning user Their income is not borne by a permanent establishment that the employer has in the United States. Taxact returning user 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. Taxact returning user 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. Taxact returning user S. Taxact returning user resident. Taxact returning user 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. Taxact returning user S. Taxact returning user tax. Taxact returning user 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. Taxact returning user S. Taxact returning user 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. Taxact returning user If the residents have a fixed base available, they are taxed only on the income attributable to the fixed base. Taxact returning user Income that residents of Kazakhstan receive for employment in the United States (dependent personal services) is exempt from U. Taxact returning user S. Taxact returning user income tax if the following three requirements are met. Taxact returning user The resident is in the United States for no more than 183 days in any 12-month period. Taxact returning user The income is paid by, or on behalf of, an employer who is not a resident of the United States. Taxact returning user The income is not borne by a permanent establishment or a fixed base that the employer has in the United States. Taxact returning user 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. Taxact returning user S. Taxact returning user tax. Taxact returning user 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. Taxact returning user S. Taxact returning user resident. Taxact returning user 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. Taxact returning user S. Taxact returning user 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. Taxact returning user 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. Taxact returning user 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. Taxact returning user S. Taxact returning user tax if the residents meet four requirements. Taxact returning user They are in the United States for no more than 182 days during the tax year. Taxact returning user They are employees of a resident of Korea or of a permanent establishment maintained in Korea. Taxact returning user Their compensation is not borne by a permanent establishment that the employer has in the United States. Taxact returning user Their income for those services is not more than $3,000. Taxact returning user 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. Taxact returning user 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. Taxact returning user S. Taxact returning user 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. Taxact returning user If they have a fixed base available, they are taxed only on the income attributable to the fixed base. Taxact returning user Income that residents of Latvia receive for services performed in the United States as employees (dependent personal services) is exempt from U. Taxact returning user S. Taxact returning user income tax if the following requirements are met. Taxact returning user 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. Taxact returning user The income is paid by, or on behalf of, an employer who is not a U. Taxact returning user S. Taxact returning user resident. Taxact returning user The income is not borne by a permanent establishment or a fixed base that the employer has in the United States. Taxact returning user 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. Taxact returning user S. Taxact returning user enterprise. Taxact returning user 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. Taxact returning user S. Taxact returning user resident. Taxact returning user 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. Taxact returning user Regardless of these limits, income of Latvian entertainers or athletes is exempt from U. Taxact returning user S. Taxact returning user 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. Taxact returning user 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. Taxact returning user S. Taxact returning user 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. Taxact returning user If they have a fixed base available, they are taxed only on the income attributable to the fixed base. Taxact returning user Income that residents of Lithuania receive for services performed in the United States as employees (dependent personal services) is exempt from U. Taxact returning user S. Taxact returning user income tax if the following requirements are met. Taxact returning user 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. Taxact returning user The income is paid by, or on behalf of, an employer who is not a U. Taxact returning user S. Taxact returning user resident. Taxact returning user The income is not borne by a permanent establishment or a fixed base that the employer has in the United States. Taxact returning user 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. Taxact returning user S. Taxact returning user enterprise. Taxact returning user 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. Taxact returning user S. Taxact returning user resident. Taxact returning user 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. Taxact returning user Regardless of these limits, income of Lithuanian entertainers or athletes is exempt from U. Taxact returning user S. Taxact returning user 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. Taxact returning user 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. Taxact returning user S. Taxact returning user income tax if they do not have a fixed base regularly available to them in the United States for performing the services. Taxact returning user If they have a fixed base available in the United States, they are taxed on the income attributable to the fixed base. Taxact returning user Income that residents of Luxembourg receive for services performed in the United States as employees (dependent personal services) is exempt from U. Taxact returning user S. Taxact returning user income tax if the residents meet the following requirements. Taxact returning user They are in the United States for no more than 183 days in any 12-month period beginning or ending in the tax year. Taxact returning user Their income is paid by, or on behalf of, an employer who is not a U. Taxact returning user S. Taxact returning user resident. Taxact returning user Their income is not borne by a permanent establishment or a fixed base that the employer has in the United States. Taxact returning user 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. Taxact returning user S. Taxact returning user enterprise. Taxact returning user 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. Taxact returning user 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. Taxact returning user 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. Taxact returning user Under that provision, business profits are exempt from U. Taxact returning user S. Taxact returning user income tax unless the individual has a permanent establishment in the United States. Taxact returning user If they have a permanent establishment in the United States, they are taxed on the profits attributable to the permanent establishment. Taxact returning user Income that residents of Malta receive for services performed in the United States as employees (dependent personal services) is exempt from U. Taxact returning user S. Taxact returning user income tax if the residents meet the following requirements. Taxact returning user They are in the United States for no more than 183 days in any 12-month period beginning or ending in the tax year. Taxact returning user Their income is paid by, or on behalf of, an employer who is not a U. Taxact returning user S. Taxact returning user resident. Taxact returning user Their income is not borne by a permanent establishment that the employer has in the United States. Taxact returning user 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. Taxact returning user 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. Taxact returning user S. Taxact returning user tax. Taxact returning user Income received by a resident of Malta for employment aboard a ship or an aircraft operated in international traffic is exempt from U. Taxact returning user S. Taxact returning user income tax if the individual is a member of the regular complement of the ship or aircraft. Taxact returning user 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. Taxact returning user S. Taxact returning user 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. Taxact returning user If they have a fixed base available, they are taxed only on income attributable to the fixed base. Taxact returning user Income that residents of Mexico receive for employment in the United States (dependent personal services) is exempt from U. Taxact returning user S. Taxact returning user tax if the following three requirements are met. Taxact returning user The resident is present in the United States for no more than 183 days in a 12-month period. Taxact returning user The income is paid by, or on behalf of, an employer who is not a resident of the United States. Taxact returning user The income is not borne by a permanent establishment or fixed base that the employer has in the United States. Taxact returning user 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. Taxact returning user S. Taxact returning user resident. Taxact returning user 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. Taxact returning user This includes income from activities performed in the United States relating to the entertainer or athlete's reputation, such as endorsements of commercial products. Taxact returning user Regardless of this limit, the income of Mexican entertainers and athletes is exempt from U. Taxact returning user S. Taxact returning user tax if their visit to the United States is substantially supported by public funds of Mexico, its political subdivisions, or local authorities. Taxact returning user 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. Taxact returning user S. Taxact returning user 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. Taxact returning user 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. Taxact returning user 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. Taxact returning user S. Taxact returning user income tax if the residents meet three requirements. Taxact returning user They are in the United States for less than 183 days during the tax year. Taxact returning user 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. Taxact returning user Their income is not borne by a permanent establishment that the employer has in the United States. Taxact returning user Compensation received for services performed by a member of the board of directors of a corporation does not qualify for this exemption. Taxact returning user 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. Taxact returning user S. Taxact returning user income tax if the individual is a member of the regular complement of the ship or aircraft. Taxact returning user 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. Taxact returning user 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. Taxact returning user S. Taxact returning user income tax if the income is not attributable to a fixed base in the United States that is regularly available for performing the services. Taxact returning user Income that residents of the Netherlands receive for employment in the United States (dependent personal services) is exempt from U. Taxact returning user S. Taxact returning user income tax if the following three requirements are met. Taxact returning user The resident is in the United States for no more than 183 days during the tax year. Taxact returning user The income is paid by, or on behalf of, an employer who is not a U. Taxact returning user S. Taxact returning user resident. Taxact returning user The income is not borne by a permanent establishment or fixed base the employer has in the United States. Taxact returning user Income received by a Netherlands resident for employment as a member of the regular complement of a ship or