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Vita Irs Org

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Vita Irs Org

Vita irs org 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. Vita irs org Under these treaties, residents (not necessarily citizens) of foreign countries are taxed at a reduced rate, or are exempt from U. Vita irs org S. Vita irs org income taxes on certain items of income they receive from sources within the United States. Vita irs org These reduced rates and exemptions vary among countries and specific items of income. Vita irs org 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. Vita irs org Also see Publication 519. Vita irs org Many of the individual states of the United States tax the income of their residents. Vita irs org 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. Vita irs org Tax treaties reduce the U. Vita irs org S. Vita irs org taxes of residents of foreign countries. Vita irs org With certain exceptions, they do not reduce the U. Vita irs org S. Vita irs org taxes of U. Vita irs org S. Vita irs org citizens or residents. Vita irs org U. Vita irs org S. Vita irs org citizens and residents are subject to U. Vita irs org S. Vita irs org income tax on their worldwide income. Vita irs org Treaty provisions generally are reciprocal (apply to both treaty countries); therefore, a U. Vita irs org S. Vita irs org 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. Vita irs org Foreign taxing authorities sometimes require certification from the U. Vita irs org S. Vita irs org Government that an applicant filed an income tax return as a U. Vita irs org S. Vita irs org citizen or resident, as part of the proof of entitlement to the treaty benefits. Vita irs org See Form 8802, Application for United States Residency Certification, to request a certification. Vita irs org Disclosure of a treaty-based position that reduces your tax. Vita irs org   If you take the position that any U. Vita irs org S. Vita irs org tax is overruled or otherwise reduced by a U. Vita irs org S. Vita irs org treaty (a treaty-based position), you generally must disclose that position on Form 8833 and attach it to your return. Vita irs org 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. Vita irs org 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. Vita irs org For more information, see Publication 519 and the Form 8833 instructions. Vita irs org   If you fail to file Form 8833, you may have to pay a $1,000 penalty. Vita irs org Corporations are subject to a $10,000 penalty for each failure. Vita irs org 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. Vita irs org Pay for certain personal services performed in the United States. Vita irs org Pay of a professor, teacher, or researcher who teaches or performs research in the United States for a limited time. Vita irs org Amounts received for maintenance and studies by a foreign student or apprentice who is here for study or experience. Vita irs org Wages, salaries, and pensions paid by a foreign government. Vita irs org Personal Services Income Pay for certain personal services performed in the United States is exempt from U. Vita irs org S. Vita irs org 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. Vita irs org For this purpose, the word “day” means a day during any part of which you are physically present in the United States. Vita irs org Terms defined. Vita irs org   Several terms appear in many of the discussions that follow. Vita irs org The exact meanings of the terms are determined by the particular tax treaty under discussion; thus, the meanings vary among treaties. Vita irs org The definitions that follow are, therefore, general definitions that may not give the exact meaning intended by a particular treaty. Vita irs org   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. Vita irs org   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. Vita irs org 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. Vita irs org S. Vita irs org 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. Vita irs org If they have a fixed base available in the United States, they are taxed on the income attributable to the fixed base. Vita irs org 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. Vita irs org S. Vita irs org 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. Vita irs org 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. Vita irs org 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. Vita irs org S. Vita irs org income tax if they do not have a fixed base regularly available to them in the United States for performing the services. Vita irs org If they have a fixed base available in the United States, they are taxed on the income attributable to the fixed base. Vita irs org Income that residents of Austria receive for services performed in the United States as employees (dependent personal services) is exempt from U. Vita irs org S. Vita irs org income tax if the residents meet the following requirements. Vita irs org They are in the United States for no more than 183 days in any 12-month period beginning or ending in the tax year. Vita irs org Their income is paid by, or on behalf of, an employer who is not a U. Vita irs org S. Vita irs org resident. Vita irs org Their income is not borne by a permanent establishment or a fixed base that the employer has in the United States. Vita irs org 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. Vita irs org 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. Vita irs org S. Vita irs org income tax. Vita irs org 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. Vita irs org S. Vita irs org 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. Vita irs org If they have a fixed base available in the United States, they are taxed on the income attributable to the fixed base. Vita irs org Income that residents of Bangladesh receive for services performed in the United States as employees (dependent personal services) is exempt from U. Vita irs org S. Vita irs org income tax if the residents meet the following requirements. Vita irs org They are in the United States for no more than 183 days in any 12-month period beginning or ending in the tax year. Vita irs org Their income is paid by, or on behalf of, an employer who is not a U. Vita irs org S. Vita irs org resident. Vita irs org Their income is not borne by a permanent establishment or a fixed base that the employer has in the United States. Vita irs org 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. Vita irs org Regardless of these limits, income of Bangladesh entertainers is exempt from U. Vita irs org S. Vita irs org 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. Vita irs org 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. Vita irs org S. Vita irs org tax. Vita irs org If the ship or aircraft is operated by a U. Vita irs org S. Vita irs org enterprise, the income is subject to U. Vita irs org S. Vita irs org tax. Vita irs org If the resident of Bangladesh is a shareholder in a U. Vita irs org S. Vita irs org corporation, these exemptions do not apply to directors' fees received as a member of the board of directors of the U. Vita irs org S. Vita irs org corporation. Vita irs org 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. Vita irs org S. Vita irs org tax at the rate of 15%. Vita irs org 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. Vita irs org S. Vita irs org 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. Vita irs org S. Vita irs org residents that is not more than $5,000 (there is no dollar limit if the contractors are not U. Vita irs org S. Vita irs org residents), and Do not have a regular base available in the United States for performing the services. Vita irs org 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. Vita irs org Income that residents of Barbados receive for personal services performed in the United States as employees (dependent personal services) is exempt from U. Vita irs org S. Vita irs org tax if the residents meet four requirements. Vita irs org They are in the United States for no more than 183 days during the calendar year. Vita irs org The income earned in the calendar year in the United States is not more than $5,000. Vita irs org Their income is paid by or for an employer who is not a U. Vita irs org S. Vita irs org resident. Vita irs org The income is not borne by a permanent establishment or regular base of the employer in the United States. Vita irs org 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. Vita irs org S. Vita irs org tax. Vita irs org 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. Vita irs org 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. Vita irs org 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. Vita irs org Under that provision, business profits are exempt from U. Vita irs org S. Vita irs org income tax unless the individual has a permanent establishment in the United States. Vita irs org If they have a permanent establishment in the United States, they are taxed on the profit attributable to the permanent establishment. Vita irs org Income that residents of Belgium receive for services performed in the United States as employees (dependent personal services) is exempt from U. Vita irs org S. Vita irs org income tax if the residents meet the following requirements. Vita irs org They are in the United States for no more than 183 days in any 12-month period beginning or ending in the tax year. Vita irs org Their income is paid by, or on behalf of, an employer who is not a U. Vita irs org S. Vita irs org resident. Vita irs org Their income is not borne by a permanent establishment that the employer has in the United States. Vita irs org 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. Vita irs org 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. Vita irs org S. Vita irs org tax. Vita irs org 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. Vita irs org S. Vita irs org income tax. Vita irs org 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. Vita irs org Under that provision, business profits are exempt from U. Vita irs org S. Vita irs org income tax unless the individual has a permanent establishment in the United States. Vita irs org If they have a permanent establishment in the United States, they are taxed on the profit attributable to the permanent establishment. Vita irs org 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. Vita irs org Income that residents of Bulgaria receive for services performed in the United States as employees (dependent personal services) is exempt from U. Vita irs org S. Vita irs org income tax if the residents meet the following requirements. Vita irs org They are in the United States for no more than 183 days in any 12-month period beginning or ending in the tax year. Vita irs org Their income is paid by, or on behalf of, an employer who is not a U. Vita irs org S. Vita irs org resident. Vita irs org Their income is not borne by a permanent establishment that the employer has in the United States. Vita irs org 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. Vita irs org S. Vita irs org company. Vita irs org 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. Vita irs org S. Vita irs org tax. Vita irs org 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. Vita irs org S. Vita irs org income tax. Vita irs org 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. Vita irs org Under that provision, business profits are exempt from U. Vita irs org S. Vita irs org income tax unless the individual has a permanent establishment in the United States. Vita irs org If they have a permanent establishment in the United States, they are taxed on the profit attributable to the permanent establishment. Vita irs org 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. Vita irs org Income that residents of Canada receive for personal services performed as employees (dependent personal services) in the United States is exempt from U. Vita irs org S. Vita irs org tax if it is not more than $10,000 for the year. Vita irs org 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. Vita irs org S. Vita irs org resident, and is not borne by a permanent establishment in the United States. Vita irs org 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. Vita irs org S. Vita irs org tax. Vita irs org 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. Vita irs org 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. Vita irs org S. Vita irs org tax. Vita irs org 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. Vita irs org S. Vita irs org 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. Vita irs org If they have a fixed base available in the United States, they are taxable on the income attributable to the fixed base. Vita irs org 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. Vita irs org S. Vita irs org 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. Vita irs org S. Vita irs org resident, and The pay is not borne by a permanent establishment or fixed base that the employer has in the United States. Vita irs org These exemptions do not apply to directors' fees for service on the board of directors of a U. Vita irs org S. Vita irs org corporation. Vita irs org 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). Vita irs org However, income of athletes or public entertainers from China participating in a cultural exchange program agreed upon by the U. Vita irs org S. Vita irs org and Chinese governments is exempt from U. Vita irs org S. Vita irs org tax. Vita irs org Commonwealth of Independent States Income that residents of a C. Vita irs org I. Vita irs org S. Vita irs org member receive for performing personal services in the United States is exempt from U. Vita irs org S. Vita irs org income tax if those residents are in the United States for no more than 183 days during the tax year. Vita irs org 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. Vita irs org I. Vita irs org S. Vita irs org member or a resident of a C. Vita irs org I. Vita irs org S. Vita irs org member is exempt from U. Vita irs org S. Vita irs org tax. Vita irs org 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. Vita irs org S. Vita irs org 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. Vita irs org If they have a fixed base available in the United States, they are taxable on the income attributable to the fixed base. Vita irs org 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. Vita irs org S. Vita irs org 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. Vita irs org S. Vita irs org 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. Vita irs org 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. Vita irs org S. Vita irs org tax. Vita irs org 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. Vita irs org Directors' fees received by residents of Cyprus for service on the board of directors of a U. Vita irs org S. Vita irs org corporation are exempt from U. Vita irs org S. Vita irs org 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. Vita irs org 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. Vita irs org S. Vita irs org 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. Vita irs org If they have a fixed base available, they are taxed only on income attributable to the fixed base. Vita irs org Income that residents of the Czech Republic receive for employment in the United States (dependent personal services) is exempt from U. Vita irs org S. Vita irs org income tax if the following three requirements are met. Vita irs org The resident is present in the United States for no more than 183 days in any 12-month period. Vita irs org The income is paid by, or on behalf of, an employer who is not a U. Vita irs org S. Vita irs org resident. Vita irs org The income is not borne by a permanent establishment or a fixed base that the employer has in the United States. Vita irs org 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. Vita irs org Regardless of these limits, income of Czech entertainers and sportsmen is exempt from U. Vita irs org S. Vita irs org 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. Vita irs org 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. Vita irs org 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. Vita irs org S. Vita irs org income tax. Vita irs org If the ship or aircraft is operated by a U. Vita irs org S. Vita irs org enterprise, the income is subject to U. Vita irs org S. Vita irs org tax. Vita irs org 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. Vita irs org S. Vita irs org income tax if they do not have a fixed base regularly available to them in the United States for performing the services. Vita irs org If they have a fixed base available in the United States, they are taxed on the income attributable to the fixed base. Vita irs org Income that residents of Denmark receive for services performed in the United States as employees (dependent personal services) is exempt from U. Vita irs org S. Vita irs org income tax if the residents meet the following requirements. Vita irs org They are in the United States for no more than 183 days in any 12-month period beginning or ending in the tax year. Vita irs org Their income is paid by, or on behalf of, an employer who is not a U. Vita irs org S. Vita irs org resident. Vita irs org Their income is not borne by a permanent establishment or a fixed base that the employer has in the United States. Vita irs org 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. Vita irs org 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. Vita irs org 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. Vita irs org S. Vita irs org income tax. Vita irs org 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. Vita irs org S. Vita irs org income tax if they are in the United States for no more than 89 days during the tax year. Vita irs org 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. Vita irs org S. Vita irs org income tax if the residents meet four requirements. Vita irs org They are in the United States for no more than 89 days during the tax year. Vita irs org They are employees of a resident of, or a permanent establishment in, Egypt. Vita irs org Their income is not borne by a permanent establishment that the employer has in the United States. Vita irs org Their income is subject to Egyptian tax. Vita irs org 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. Vita irs org 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. Vita irs org 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. Vita irs org S. Vita irs org 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. Vita irs org If they have a fixed base available, they are taxed on the income attributable to the fixed base. Vita irs org Income that residents of Estonia receive for services performed in the United States as employees (dependent personal services) is exempt from U. Vita irs org S. Vita irs org income tax if the following requirements are met. Vita irs org 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. Vita irs org The income is paid by, or on behalf of, an employer who is not a U. Vita irs org S. Vita irs org resident. Vita irs org The income is not borne by a permanent establishment or a fixed base that the employer has in the United States. Vita irs org 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. Vita irs org S. Vita irs org resident. Vita irs org 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. Vita irs org S. Vita irs org tax. Vita irs org 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. Vita irs org Regardless of these limits, income of Estonian entertainers or athletes is exempt from U. Vita irs org S. Vita irs org 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. Vita irs org 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. Vita irs org S. Vita irs org income tax if they do not have a fixed base regularly available to them in the United States for performing the services. Vita irs org If they have a fixed base available in the United States, they are taxed on the income attributable to the fixed base. Vita irs org 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. Vita irs org S. Vita irs org income tax if the residents meet three requirements. Vita irs org They are in the United States for no more than 183 days during any 12-month period. Vita irs org Their income is paid by, or on behalf of, an employer who is not a resident of the United States. Vita irs org Their income is not borne by a permanent establishment, fixed base, or trade or business that the employer has in the United States. Vita irs org 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. Vita irs org 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. Vita irs org 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. Vita irs org S. Vita irs org income tax if they do not have a fixed base regularly available to them in the United States for performing the services. Vita irs org If they have a fixed base available in the United States, they are taxed on the income attributable to the fixed base. Vita irs org 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. Vita irs org S. Vita irs org income tax if the residents meet three requirements. Vita irs org They are in the United States for no more than 183 days in any 12-month period. Vita irs org Their income is paid by, or on behalf of, an employer who is not a resident of the United States. Vita irs org Their income is not borne by a permanent establishment or a fixed base that the employer has in the United States. Vita irs org 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. Vita irs org 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. Vita irs org Regardless of these limits, income of French entertainers or sportsmen is exempt from U. Vita irs org S. Vita irs org tax if their visit is principally supported by public funds of France. Vita irs org 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. Vita irs org 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. Vita irs org Under that provision, business profits are exempt from U. Vita irs org S. Vita irs org income tax unless the individual has a permanent establishment in the United States. Vita irs org If they have a permanent establishment in the United States, they are taxed on the profit attributable to the permanent establishment. Vita irs org 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. Vita irs org S. Vita irs org tax if the residents meet three requirements. Vita irs org They are in the United States for no more than 183 days during the calendar year. Vita irs org The income is paid by, or on behalf of, an employer who is not a resident of the United States. Vita irs org The income is not borne by a permanent establishment that the employer has in the United States. Vita irs org 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. Vita irs org S. Vita irs org tax. Vita irs org 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. Vita irs org 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. Vita irs org S. Vita irs org 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. Vita irs org Income of German entertainers or athletes is exempt from U. Vita irs org S. Vita irs org tax if their visit to the United States is substantially supported by public funds of Germany, its political subdivisions, or local authorities. Vita irs org Greece Income that residents of Greece receive for labor or personal services (including practicing liberal and artistic professions) is exempt from U. Vita irs org S. Vita irs org 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. Vita irs org The pay, regardless of amount, is exempt from U. Vita irs org S. Vita irs org 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. Vita irs org 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. Vita irs org S. Vita irs org 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. Vita irs org If they have a fixed base available in the United States, they are taxed on the income attributable to the fixed base. Vita irs org 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. Vita irs org S. Vita irs org income tax if the residents meet three requirements. Vita irs org They are in the United States for no more than 183 days during the tax year. Vita irs org Their income is paid by or on behalf of an employer who is not a resident of the United States. Vita irs org Their income is not borne by a permanent establishment or a fixed base that the employer has in the United States. Vita irs org 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. Vita irs org S. Vita irs org tax. Vita irs org If the ship or aircraft is operated by a U. Vita irs org S. Vita irs org enterprise, the pay is subject to U. Vita irs org S. Vita irs org tax. Vita irs org 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. Vita irs org Under that provision, business profits are exempt from U. Vita irs org S. Vita irs org income tax unless the individual has a permanent establishment in the United States. Vita irs org If they have a permanent establishment in the United States, they are taxed on the profit attributable to the permanent establishment. Vita irs org Income that residents of Iceland receive for services performed in the United States as employees (dependent personal services) is exempt from U. Vita irs org S. Vita irs org income tax if the residents meet the following requirements. Vita irs org They are in the United States for no more than 183 days in any 12-month period beginning or ending in the tax year. Vita irs org Their income is paid by, or on behalf of, an employer who is not a U. Vita irs org S. Vita irs org resident. Vita irs org Their income is not borne by a permanent establishment that the employer has in the United States. Vita irs org 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. Vita irs org S. Vita irs org company. Vita irs org 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. Vita irs org S. Vita irs org tax. Vita irs org 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. Vita irs org S. Vita irs org income tax. Vita irs org 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. Vita irs org S. Vita irs org 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. Vita irs org If they have a fixed base available, they are taxed only on income attributable to the fixed base. Vita irs org Income that residents of India receive for personal services performed in the United States as employees (dependent personal services) is exempt from U. Vita irs org S. Vita irs org income tax if the residents meet three requirements. Vita irs org They are present in the United States for no more than 183 days during the tax year. Vita irs org The income is paid by, or on behalf of, an employer who is not a resident of the United States. Vita irs org The income is not borne by a permanent establishment, fixed base, or trade or business the employer has in the United States. Vita irs org 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. Vita irs org S. Vita irs org enterprise. Vita irs org 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. Vita irs org S. Vita irs org resident. Vita irs org 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. Vita irs org Regardless of this limit, the income of Indian entertainers and athletes is exempt from U. Vita irs org S. Vita irs org 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. Vita irs org 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. Vita irs org S. Vita irs org 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. Vita irs org If they have a fixed base available, they are taxed only on the income attributable to the fixed base. Vita irs org Income that residents of Indonesia receive for personal services performed in the United States as employees (dependent personal services) is exempt from U. Vita irs org S. Vita irs org income tax if the residents meet three requirements. Vita irs org They are present in the United States no more than 119 days during any consecutive 12-month period. Vita irs org The income is paid by, or on behalf of, an employer who is not a resident of the United States. Vita irs org The income is not borne or reimbursed by a permanent establishment the employer has in the United States. Vita irs org 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. Vita irs org S. Vita irs org tax if the individual is a member of the regular complement of the ship or aircraft. Vita irs org 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. Vita irs org Regardless of these limits, income of Indonesian entertainers and athletes is exempt from U. Vita irs org S. Vita irs org 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. Vita irs org 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. Vita irs org S. Vita irs org income tax if they do not have a fixed base regularly available to them in the United States for performing the services. Vita irs org If they have a fixed base available in the United States, they are taxed on the income attributable to the fixed base. Vita irs org Income that residents of Ireland receive for services performed in the United States as employees (dependent personal services) is exempt from U. Vita irs org S. Vita irs org income tax if the residents meet the following requirements. Vita irs org They are in the United States for no more than 183 days in any 12-month period beginning or ending in the tax year. Vita irs org Their income is paid by, or on behalf of, an employer who is not a U. Vita irs org S. Vita irs org resident. Vita irs org Their income is not borne by a permanent establishment or a fixed base that the employer has in the United States. Vita irs org 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. Vita irs org However, amounts received for attending meetings in Ireland are not subject to U. Vita irs org S. Vita irs org income tax. Vita irs org 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. Vita irs org S. Vita irs org income tax. Vita irs org 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. Vita irs org 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. Vita irs org S. Vita irs org income tax if they are in the United States for no more than 182 days during the tax year. Vita irs org 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. Vita irs org S. Vita irs org income tax if the residents meet four requirements. Vita irs org They are in the United States for no more than 182 days during the tax year. Vita irs org They are employees of a resident of, or a permanent establishment in, Israel. Vita irs org Their income is not borne by a permanent establishment that the employer has in the United States. Vita irs org Their income is subject to Israeli tax. Vita irs org 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. Vita irs org S. Vita irs org resident. Vita irs org 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. Vita irs org 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. Vita irs org S. Vita irs org income tax if they do not have a fixed base regularly available to them in the United States for performing the services. Vita irs org If they have a fixed base available in the United States, they are taxed on the income attributable to the fixed base. Vita irs org 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. Vita irs org S. Vita irs org income tax if the following requirements are met. Vita irs org The residents are in the United States for no more than 183 days during the tax year. Vita irs org The income is paid by, or on behalf of, an employer who is not a resident of the United States. Vita irs org The income is not borne by a permanent establishment or a fixed base that the employer has in the United States. Vita irs org 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. Vita irs org S. Vita irs org resident. Vita irs org Pay received for employment regularly exercised aboard a ship or aircraft operated by a U. Vita irs org S. Vita irs org enterprise is subject to U. Vita irs org S. Vita irs org tax. Vita irs org 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. Vita irs org 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. Vita irs org S. Vita irs org 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. Vita irs org S. Vita irs org contractor. Vita irs org 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. Vita irs org There is no dollar limit for condition (3) if the contractor is from a country other than the United States. Vita irs org Income that residents of Jamaica receive for personal services performed in the United States as employees (dependent personal services) is exempt from U. Vita irs org S. Vita irs org income tax if the residents meet four requirements. Vita irs org They are in the United States for no more than 183 days during the tax year. Vita irs org Their income is paid by or for an employer who is not a resident of the United States. Vita irs org Their income is not borne by a permanent establishment or a fixed base that the employer has in the United States. Vita irs org Their net income received for the services is not more than $5,000 during the tax year. Vita irs org 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. Vita irs org S. Vita irs org tax. Vita irs org If the ship or aircraft is operated by a U. Vita irs org S. Vita irs org enterprise, the pay is subject to U. Vita irs org S. Vita irs org tax. Vita irs org 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. Vita irs org Directors' fees received by residents of Jamaica for services performed in the United States as members of boards of directors of U. Vita irs org S. Vita irs org corporations are exempt from U. Vita irs org S. Vita irs org 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. Vita irs org 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. Vita irs org Under that provision, business profits are exempt from U. Vita irs org S. Vita irs org income tax unless the individual has a permanent establishment in the United States. Vita irs org If they have a permanent establishment in the United States, they are taxed on the profits attributable to the permanent establishment. Vita irs org Income that residents of Japan receive for services performed in the United States as employees (dependent personal services) is exempt from U. Vita irs org S. Vita irs org income tax if the residents meet the following requirements. Vita irs org They are in the United States for no more than 183 days in any 12-month period beginning or ending in the tax year. Vita irs org Their income is paid by, or on behalf of, an employer who is not a U. Vita irs org S. Vita irs org resident. Vita irs org Their income is not borne by a permanent establishment that the employer has in the United States. Vita irs org 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. Vita irs org 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. Vita irs org S. Vita irs org resident. Vita irs org 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. Vita irs org S. Vita irs org tax. Vita irs org 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. Vita irs org S. Vita irs org 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. Vita irs org If the residents have a fixed base available, they are taxed only on the income attributable to the fixed base. Vita irs org Income that residents of Kazakhstan receive for employment in the United States (dependent personal services) is exempt from U. Vita irs org S. Vita irs org income tax if the following three requirements are met. Vita irs org The resident is in the United States for no more than 183 days in any 12-month period. Vita irs org The income is paid by, or on behalf of, an employer who is not a resident of the United States. Vita irs org The income is not borne by a permanent establishment or a fixed base that the employer has in the United States. Vita irs org 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. Vita irs org S. Vita irs org tax. Vita irs org 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. Vita irs org S. Vita irs org resident. Vita irs org 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. Vita irs org S. Vita irs org 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. Vita irs org 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. Vita irs org 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. Vita irs org S. Vita irs org tax if the residents meet four requirements. Vita irs org They are in the United States for no more than 182 days during the tax year. Vita irs org They are employees of a resident of Korea or of a permanent establishment maintained in Korea. Vita irs org Their compensation is not borne by a permanent establishment that the employer has in the United States. Vita irs org Their income for those services is not more than $3,000. Vita irs org 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. Vita irs org 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. Vita irs org S. Vita irs org 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. Vita irs org If they have a fixed base available, they are taxed only on the income attributable to the fixed base. Vita irs org Income that residents of Latvia receive for services performed in the United States as employees (dependent personal services) is exempt from U. Vita irs org S. Vita irs org income tax if the following requirements are met. Vita irs org 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. Vita irs org The income is paid by, or on behalf of, an employer who is not a U. Vita irs org S. Vita irs org resident. Vita irs org The income is not borne by a permanent establishment or a fixed base that the employer has in the United States. Vita irs org 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. Vita irs org S. Vita irs org enterprise. Vita irs org 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. Vita irs org S. Vita irs org resident. Vita irs org 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. Vita irs org Regardless of these limits, income of Latvian entertainers or athletes is exempt from U. Vita irs org S. Vita irs org 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. Vita irs org 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. Vita irs org S. Vita irs org 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. Vita irs org If they have a fixed base available, they are taxed only on the income attributable to the fixed base. Vita irs org Income that residents of Lithuania receive for services performed in the United States as employees (dependent personal services) is exempt from U. Vita irs org S. Vita irs org income tax if the following requirements are met. Vita irs org 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. Vita irs org The income is paid by, or on behalf of, an employer who is not a U. Vita irs org S. Vita irs org resident. Vita irs org The income is not borne by a permanent establishment or a fixed base that the employer has in the United States. Vita irs org 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. Vita irs org S. Vita irs org enterprise. Vita irs org 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. Vita irs org S. Vita irs org resident. Vita irs org 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. Vita irs org Regardless of these limits, income of Lithuanian entertainers or athletes is exempt from U. Vita irs org S. Vita irs org 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. Vita irs org 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. Vita irs org S. Vita irs org income tax if they do not have a fixed base regularly available to them in the United States for performing the services. Vita irs org If they have a fixed base available in the United States, they are taxed on the income attributable to the fixed base. Vita irs org Income that residents of Luxembourg receive for services performed in the United States as employees (dependent personal services) is exempt from U. Vita irs org S. Vita irs org income tax if the residents meet the following requirements. Vita irs org They are in the United States for no more than 183 days in any 12-month period beginning or ending in the tax year. Vita irs org Their income is paid by, or on behalf of, an employer who is not a U. Vita irs org S. Vita irs org resident. Vita irs org Their income is not borne by a permanent establishment or a fixed base that the employer has in the United States. Vita irs org 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. Vita irs org S. Vita irs org enterprise. Vita irs org 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. Vita irs org 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. Vita irs org 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. Vita irs org Under that provision, business profits are exempt from U. Vita irs org S. Vita irs org income tax unless the individual has a permanent establishment in the United States. Vita irs org If they have a permanent establishment in the United States, they are taxed on the profits attributable to the permanent establishment. Vita irs org Income that residents of Malta receive for services performed in the United States as employees (dependent personal services) is exempt from U. Vita irs org S. Vita irs org income tax if the residents meet the following requirements. Vita irs org They are in the United States for no more than 183 days in any 12-month period beginning or ending in the tax year. Vita irs org Their income is paid by, or on behalf of, an employer who is not a U. Vita irs org S. Vita irs org resident. Vita irs org Their income is not borne by a permanent establishment that the employer has in the United States. Vita irs org 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. Vita irs org 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. Vita irs org S. Vita irs org tax. Vita irs org Income received by a resident of Malta for employment aboard a ship or an aircraft operated in international traffic is exempt from U. Vita irs org S. Vita irs org income tax if the individual is a member of the regular complement of the ship or aircraft. Vita irs org 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. Vita irs org S. Vita irs org 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. Vita irs org If they have a fixed base available, they are taxed only on income attributable to the fixed base. Vita irs org Income that residents of Mexico receive for employment in the United States (dependent personal services) is exempt from U. Vita irs org S. Vita irs org tax if the following three requirements are met. Vita irs org The resident is present in the United States for no more than 183 days in a 12-month period. Vita irs org The income is paid by, or on behalf of, an employer who is not a resident of the United States. Vita irs org The income is not borne by a permanent establishment or fixed base that the employer has in the United States. Vita irs org 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. Vita irs org S. Vita irs org resident. Vita irs org 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. Vita irs org This includes income from activities performed in the United States relating to the entertainer or athlete's reputation, such as endorsements of commercial products. Vita irs org Regardless of this limit, the income of Mexican entertainers and athletes is exempt from U. Vita irs org S. Vita irs org tax if their visit to the United States is substantially supported by public funds of Mexico, its political subdivisions, or local authorities. Vita irs org 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. Vita irs org S. Vita irs org 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. Vita irs org 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. Vita irs org 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. Vita irs org S. Vita irs org income tax if the residents meet three requirements. Vita irs org They are in the United States for less than 183 days during the tax year. Vita irs org 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. Vita irs org Their income is not borne by a permanent establishment that the employer has in the United States. Vita irs org Compensation received for services performed by a member of the board of directors of a corporation does not qualify for this exemption. Vita irs org 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. Vita irs org S. Vita irs org income tax if the individual is a member of the regular complement of the ship or aircraft. Vita irs org 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. Vita irs org 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. Vita irs org S. Vita irs org income tax if the income is not attributable to a fixed base in the United States that is regularly available for performing the services. Vita irs org Income that residents of the Netherlands receive for employment in the United States (dependent personal services) is exempt from U. Vita irs org S. Vita irs org income tax if the following three requirements are met. Vita irs org The resident is in the United States for no more than 183 days during the tax year. Vita irs org The income is paid by, or on behalf of, an employer who is not a U. Vita irs org S. Vita irs org resident. Vita irs org The income is not borne by a permanent establishment or fixed base the employer has in the United States. Vita irs org Income received by a Netherlands resident for employment as a member of the regular complement of a ship or
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Vita irs org Internal Revenue Bulletin:  2012-14  April 2, 2012  Rev. Vita irs org Proc. Vita irs org 2012-23 Table of Contents SECTION 1. Vita irs org PURPOSE SECTION 2. Vita irs org BACKGROUND SECTION 3. Vita irs org SCOPE SECTION 4. Vita irs org APPLICATION. Vita irs org 01 Limitations on Depreciation Deductions for Certain Automobiles. Vita irs org . Vita irs org 02 Inclusions in Income of Lessees of Passenger Automobiles. Vita irs org SECTION 5. Vita irs org EFFECTIVE DATE SECTION 6. Vita irs org DRAFTING INFORMATION SECTION 1. Vita irs org PURPOSE This revenue procedure provides: (1) limitations on depreciation deductions for owners of passenger automobiles first placed in service by the taxpayer during calendar year 2012, including separate tables of limitations on depreciation deductions for trucks and vans; and (2) the amounts that must be included in income by lessees of passenger automobiles first leased by the taxpayer during calendar year 2012, including a separate table of inclusion amounts for lessees of trucks and vans. Vita irs org The tables detailing these depreciation limitations and lessee inclusion amounts reflect the automobile price inflation adjustments required by § 280F(d)(7) of the Internal Revenue Code. Vita irs org SECTION 2. Vita irs org BACKGROUND . Vita irs org 01 For owners of passenger automobiles, § 280F(a) imposes dollar limitations on the depreciation deduction for the year the taxpayer places the passenger automobile in service and for each succeeding year. Vita irs org For passenger automobiles placed in service after 1988, § 280F(d)(7) requires the Internal Revenue Service to increase the amounts allowable as depreciation deductions by a price inflation adjustment amount. Vita irs org The method of calculating this price inflation amount for trucks and vans placed in service in or after calendar year 2003 uses a different CPI “automobile component” (the “new trucks” component) than that used in the price inflation amount calculation for other passenger automobiles (the “new cars” component), resulting in somewhat higher depreciation deductions for trucks and vans. Vita irs org This change reflects the higher rate of price inflation for trucks and vans since 1988. Vita irs org . Vita irs org 02 Section 401(a) of the Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act of 2010, Pub. Vita irs org L. Vita irs org No. Vita irs org 111-312, 124 Stat. Vita irs org 3296 (Dec. Vita irs org 17, 2010) (the “Act”) extended the 50 percent additional first year depreciation deduction under § 168(k) to qualified property acquired by the taxpayer after December 31, 2007, and before January 1, 2013, if no written binding contract for the acquisition of the property existed before January 1, 2008, and if the taxpayer places the property in service generally before January 1, 2013. Vita irs org Section 168(k)(2)(F)(i) increases the first year depreciation allowed under § 280F(a)(1)(A)(i) by $8,000 for passenger automobiles to which the additional first year depreciation deduction under § 168(k) (hereinafter, referred to as “§ 168(k) additional first year depreciation deduction”) applies. Vita irs org . Vita irs org 03 Section 168(k)(2)(D)(i) provides that the § 168(k) additional first year depreciation deduction does not apply to any property required to be depreciated under the alternative depreciation system of § 168(g), including property described in § 280F(b)(1). Vita irs org Section 168(k)(2)(D)(iii) permits a taxpayer to elect out of the § 168(k) additional first year depreciation deduction for any class of property. Vita irs org Section 168(k)(4), as amended by the Act, permits a corporation to elect to increase the alternative minimum tax (“AMT”) credit limitation under § 53(c), instead of claiming the § 168(k) additional first year depreciation deduction for all eligible qualified property placed in service after December 31, 2010, that is round 2 extension property (as defined in § 168(k)(4)(I)(iv)). Vita irs org Accordingly, this revenue procedure provides tables for passenger automobiles for which the § 168(k) additional first year depreciation deduction applies. Vita irs org This revenue procedure also provides tables for passenger automobiles for which the § 168(k) additional first year depreciation deduction does not apply, either because taxpayer (1) purchased the passenger automobile used; (2) did not use the passenger automobile during 2012 more than 50 percent for business purposes; (3) elected out of the § 168(k) additional first year depreciation deduction pursuant to § 168(k)(2)(D)(iii); or (4) elected to increase the § 53 AMT credit limitation in lieu of claiming § 168(k) additional first year depreciation. Vita irs org . Vita irs org 04 Section 280F(c) requires a reduction in the deduction allowed to the lessee of a leased passenger automobile. Vita irs org The reduction must be substantially equivalent to the limitations on the depreciation deductions imposed on owners of passenger automobiles. Vita irs org Under § 1. Vita irs org 280F-7(a) of the Income Tax Regulations, this reduction requires a lessee to include in gross income an amount determined by applying a formula to the amount obtained from a table. Vita irs org One table applies to lessees of trucks and vans and another table applies to all other passenger automobiles. Vita irs org Each table shows inclusion amounts for a range of fair market values for each taxable year after the passenger automobile is first leased. Vita irs org SECTION 3. Vita irs org SCOPE . Vita irs org 01 The limitations on depreciation deductions in section 4. Vita irs org 01(2) of this revenue procedure apply to passenger automobiles (other than leased passenger automobiles) that are placed in service by the taxpayer in calendar year 2012, and continue to apply for each taxable year that the passenger automobile remains in service. Vita irs org . Vita irs org 02 The tables in section 4. Vita irs org 02 of this revenue procedure apply to leased passenger automobiles for which the lease term begins during calendar year 2012. Vita irs org Lessees of these passenger automobiles must use these tables to determine the inclusion amount for each taxable year during which the passenger automobile is leased. Vita irs org See Rev. Vita irs org Proc. Vita irs org 2007-30, 2007-1 C. Vita irs org B. Vita irs org 1104, for passenger automobiles first leased during calendar year 2007; Rev. Vita irs org Proc. Vita irs org 2008-22, 2008-1 C. Vita irs org B. Vita irs org 658, for passenger automobiles first leased during calendar year 2008; Rev. Vita irs org Proc. Vita irs org 2009-24, 2009-17 I. Vita irs org R. Vita irs org B. Vita irs org 885, for passenger automobiles first leased during calendar year 2009; Rev. Vita irs org Proc. Vita irs org 2010-18, 2010-9 I. Vita irs org R. Vita irs org B. Vita irs org 427, as amplified and modified by section 4. Vita irs org 03 of Rev. Vita irs org Proc. Vita irs org 2011-21, 2011-12 I. Vita irs org R. Vita irs org B. Vita irs org 560, for passenger automobiles first leased during calendar year 2010; and Rev. Vita irs org Proc. Vita irs org 2011-21, for passenger automobiles first leased during calendar year 2011. Vita irs org SECTION 4. Vita irs org APPLICATION . Vita irs org 01 Limitations on Depreciation Deductions for Certain Automobiles. Vita irs org (1) Amount of the inflation adjustment. Vita irs org (a) Passenger automobiles (other than trucks or vans). Vita irs org Under § 280F(d)(7)(B)(i), the automobile price inflation adjustment for any calendar year is the percentage (if any) by which the CPI automobile component for October of the preceding calendar year exceeds the CPI automobile component for October 1987. Vita irs org Section 280F(d)(7)(B)(ii) defines the term “CPI automobile component” as the automobile component of the Consumer Price Index for all Urban Consumers published by the Department of Labor. Vita irs org The new car component of the CPI was 115. Vita irs org 2 for October 1987 and 143. Vita irs org 419 for October 2011. Vita irs org The October 2011 index exceeded the October 1987 index by 28. Vita irs org 219. Vita irs org Therefore, the automobile price inflation adjustment for 2012 for passenger automobiles (other than trucks and vans) is 24. Vita irs org 5 percent (28. Vita irs org 219/115. Vita irs org 2 x 100%). Vita irs org The dollar limitations in § 280F(a) are multiplied by a factor of 0. Vita irs org 245, and the resulting increases, after rounding to the nearest $100, are added to the 1988 limitations to give the depreciation limitations applicable to passenger automobiles (other than trucks and vans) for calendar year 2012. Vita irs org This adjustment applies to all passenger automobiles (other than trucks and vans) that are first placed in service in calendar year 2012. Vita irs org (b) Trucks and vans. Vita irs org To determine the dollar limitations for trucks and vans first placed in service during calendar year 2012, the Service uses the new truck component of the CPI instead of the new car component. Vita irs org The new truck component of the CPI was 112. Vita irs org 4 for October 1987 and 146. Vita irs org 607 for October 2011. Vita irs org The October 2011 index exceeded the October 1987 index by 34. Vita irs org 207. Vita irs org Therefore, the automobile price inflation adjustment for 2012 for trucks and vans is 30. Vita irs org 43 percent (34. Vita irs org 207/112. Vita irs org 4 x 100%). Vita irs org The dollar limitations in § 280F(a) are multiplied by a factor of 0. Vita irs org 3043, and the resulting increases, after rounding to the nearest $100, are added to the 1988 limitations to give the depreciation limitations for trucks and vans. Vita irs org This adjustment applies to all trucks and vans that are first placed in service in calendar year 2012. Vita irs org (2) Amount of the limitation. Vita irs org Tables 1 through 4 contain the dollar amount of the depreciation limitation for each taxable year for passenger automobiles a taxpayer places in service in calendar year 2012. Vita irs org Use Table 1 for a passenger automobile (other than a truck or van), and Table 2 for a truck or van, placed in service in calendar year 2012 for which the § 168(k) additional first year depreciation deduction applies. Vita irs org Use Table 3 for a passenger automobile (other than a truck or van), and Table 4 for a truck or van, placed in service in calendar year 2012 for which the § 168(k) additional first year depreciation deduction does not apply. Vita irs org REV. Vita irs org PROC. Vita irs org 2012-23 TABLE 1 DEPRECIATION LIMITATIONS FOR PASSENGER AUTOMOBILES (THAT ARE NOT TRUCKS OR VANS) PLACED IN SERVICE IN CALENDAR YEAR 2012 FOR WHICH THE § 168(k) ADDITIONAL FIRST YEAR DEPRECIATION DEDUCTION APPLIES Tax Year Amount 1st Tax Year $11,160 2nd Tax Year $5,100 3rd Tax Year $3,050 Each Succeeding Year $1,875 REV. Vita irs org PROC. Vita irs org 2012-23 TABLE 2 DEPRECIATION LIMITATIONS FOR TRUCKS AND VANS PLACED IN SERVICE IN CALENDAR YEAR 2012 FOR WHICH THE § 168(k) ADDITIONAL FIRST YEAR DEPRECIATION DEDUCTION APPLIES Tax Year Amount 1st Tax Year $11,360 2nd Tax Year $5,300 3rd Tax Year $3,150 Each Succeeding Year $1,875 REV. Vita irs org PROC. Vita irs org 2012-23 TABLE 3 DEPRECIATION LIMITATIONS FOR PASSENGER AUTOMOBILES (THAT ARE NOT TRUCKS OR VANS) PLACED IN SERVICE IN CALENDAR YEAR 2012 FOR WHICH THE § 168(k) ADDITIONAL FIRST YEAR DEPRECIATION DEDUCTION DOES NOT APPLY Tax Year Amount 1st Tax Year $3,160 2nd Tax Year $5,100 3rd Tax Year $3,050 Each Succeeding Year $1,875 REV. Vita irs org PROC. Vita irs org 2012-23 TABLE 4 DEPRECIATION LIMITATIONS FOR TRUCKS AND VANS PLACED IN SERVICE IN CALENDAR YEAR 2012 FOR WHICH THE § 168(k) ADDITIONAL FIRST YEAR DEPRECIATION DEDUCTION DOES NOT APPLY Tax Year Amount 1st Tax Year $3,360 2nd Tax Year $5,300 3rd Tax Year $3,150 Each Succeeding Year $1,875 . Vita irs org 02 Inclusions in Income of Lessees of Passenger Automobiles. Vita irs org A taxpayer must follow the procedures in § 1. Vita irs org 280F-7(a) for determining the inclusion amounts for passenger automobiles first leased in calendar year 2012. Vita irs org In applying these procedures, lessees of passenger automobiles other than trucks and vans should use Table 5 of this revenue procedure, while lessees of trucks and vans should use Table 6 of this revenue procedure. Vita irs org REV. Vita irs org PROC. Vita irs org 2012-23 TABLE 5 DOLLAR AMOUNTS FOR PASSENGER AUTOMOBILES (THAT ARE NOT TRUCKS OR VANS) WITH A LEASE TERM BEGINNING IN CALENDAR YEAR 2012 Fair Market Value of Passenger Automobile Tax Year During Lease Over Not Over 1st 2nd 3rd 4th 5th & Later $18,500 $19,000 2 4 5 6 8 19,000 19,500 2 4 7 7 9 19,500 20,000 2 5 8 8 10 20,000 20,500 3 5 9 10 11 20,500 21,000 3 6 9 12 12 21,000 21,500 3 7 10 12 14 21,500 22,000 3 8 11 13 16 22,000 23,000 4 8 13 15 17 23,000 24,000 4 10 15 17 20 24,000 25,000 5 11 17 19 23 25,000 26,000 6 12 19 21 26 26,000 27,000 6 14 20 24 28 27,000 28,000 7 15 22 26 31 28,000 29,000 7 16 25 28 33 29,000 30,000 8 18 25 32 35 30,000 31,000 9 19 27 34 38 31,000 32,000 9 20 30 36 41 32,000 33,000 10 21 32 38 43 33,000 34,000 10 23 33 41 46 34,000 35,000 11 24 35 43 49 35,000 36,000 12 25 37 45 52 36,000 37,000 12 27 39 47 54 37,000 38,000 13 28 41 49 57 38,000 39,000 13 29 43 52 59 39,000 40,000 14 30 45 54 62 40,000 41,000 14 32 47 56 65 41,000 42,000 15 33 49 58 68 42,000 43,000 16 34 51 61 70 43,000 44,000 16 36 52 63 73 44,000 45,000 17 37 54 66 75 45,000 46,000 17 38 57 67 78 46,000 47,000 18 39 59 70 80 47,000 48,000 19 40 61 72 83 48,000 49,000 19 42 62 75 86 49,000 50,000 20 43 64 77 89 50,000 51,000 20 45 66 79 91 51,000 52,000 21 46 68 81 94 52,000 53,000 21 47 70 84 96 53,000 54,000 22 48 72 86 99 54,000 55,000 23 49 74 88 102 55,000 56,000 23 51 76 90 104 56,000 57,000 24 52 78 92 107 57,000 58,000 24 54 79 95 110 58,000 59,000 25 55 81 97 113 59,000 60,000 26 56 83 100 115 60,000 62,000 26 58 86 103 119 62,000 64,000 28 60 90 108 124 64,000 66,000 29 63 94 112 129 66,000 68,000 30 66 97 117 135 68,000 70,000 31 68 102 121 140 70,000 72,000 32 71 105 126 145 72,000 74,000 33 74 109 130 151 74,000 76,000 35 76 113 135 156 76,000 78,000 36 78 117 140 161 78,000 80,000 37 81 120 145 166 80,000 85,000 39 86 127 152 176 85,000 90,000 42 92 137 163 189 90,000 95,000 45 98 147 175 202 95,000 100,000 48 105 155 187 215 100,000 110,000 52 115 170 203 235 110,000 120,000 58 127 189 227 262 120,000 130,000 64 140 208 250 288 130,000 140,000 70 153 227 272 315 140,000 150,000 75 166 246 296 340 150,000 160,000 81 179 265 318 368 160,000 170,000 87 192 284 341 394 170,000 180,000 93 204 304 364 420 180,000 190,000 99 217 323 387 446 190,000 200,000 105 230 342 409 473 200,000 210,000 111 243 361 432 499 210,000 220,000 116 256 380 455 526 220,000 230,000 122 269 399 478 552 230,000 240,000 128 282 418 501 578 240,000 and up 134 294 437 524 605 REV. Vita irs org PROC. Vita irs org 2012-23 TABLE 6 DOLLAR AMOUNTS FOR TRUCKS AND VANS WITH A LEASE TERM BEGINNING IN CALENDAR YEAR 2012 Fair Market Value of Truck or Van Tax Year During Lease Over Not Over 1st 2nd 3rd 4th 5th & Later $19,000 $19,500 1 4 5 6 7 19,500 20,000 2 4 6 7 9 20,000 20,500 2 5 7 8 10 20,500 21,000 2 5 8 10 11 21,000 21,500 3 6 9 10 13 21,500 22,000 3 6 10 12 14 22,000 23,000 3 8 11 14 15 23,000 24,000 4 9 13 16 18 24,000 25,000 4 10 15 19 21 25,000 26,000 5 11 17 21 24 26,000 27,000 6 12 19 23 26 27,000 28,000 6 14 21 25 29 28,000 29,000 7 15 23 27 32 29,000 30,000 7 17 24 30 34 30,000 31,000 8 18 26 32 37 31,000 32,000 9 19 28 34 40 32,000 33,000 9 20 31 36 42 33,000 34,000 10 21 33 39 44 34,000 35,000 10 23 34 41 48 35,000 36,000 11 24 36 44 50 36,000 37,000 12 25 38 46 53 37,000 38,000 12 27 40 48 55 38,000 39,000 13 28 42 50 58 39,000 40,000 13 29 44 53 60 40,000 41,000 14 31 45 55 63 41,000 42,000 14 32 48 57 66 42,000 43,000 15 33 50 59 69 43,000 44,000 16 34 52 61 72 44,000 45,000 16 36 53 64 74 45,000 46,000 17 37 55 66 77 46,000 47,000 17 38 58 68 79 47,000 48,000 18 40 59 70 82 48,000 49,000 19 41 61 73 84 49,000 50,000 19 42 63 75 87 50,000 51,000 20 43 65 78 89 51,000 52,000 20 45 66 80 93 52,000 53,000 21 46 68 83 95 53,000 54,000 21 48 70 84 98 54,000 55,000 22 49 72 87 100 55,000 56,000 23 50 74 89 103 56,000 57,000 23 51 76 92 105 57,000 58,000 24 52 78 94 108 58,000 59,000 24 54 80 96 111 59,000 60,000 25 55 82 98 114 60,000 62,000 26 57 85 101 118 62,000 64,000 27 60 88 106 123 64,000 66,000 28 62 93 110 128 66,000 68,000 29 65 96 115 134 68,000 70,000 30 67 100 120 139 70,000 72,000 32 70 103 125 144 72,000 74,000 33 72 108 129 149 74,000 76,000 34 75 111 134 155 76,000 78,000 35 78 115 138 160 78,000 80,000 36 80 119 143 165 80,000 85,000 38 85 125 151 175 85,000 90,000 41 91 135 163 187 90,000 95,000 44 98 144 174 201 95,000 100,000 47 104 154 185 214 100,000 110,000 52 113 169 202 234 110,000 120,000 57 127 187 225 261 120,000 130,000 63 139 207 248 287 130,000 140,000 69 152 226 271 313 140,000 150,000 75 165 245 294 339 150,000 160,000 81 178 264 316 366 160,000 170,000 87 190 283 340 392 170,000 180,000 92 204 302 362 419 180,000 190,000 98 216 322 385 445 190,000 200,000 104 229 340 409 471 200,000 210,000 110 242 359 431 498 210,000 220,000 116 255 378 454 524 220,000 230,000 122 267 398 477 551 230,000 240,000 127 281 416 500 577 240,000 and up 133 294 435 523 603 SECTION 5. Vita irs org EFFECTIVE DATE This revenue procedure applies to passenger automobiles that a taxpayer first places in service or first leases during calendar year 2012. Vita irs org SECTION 6. Vita irs org DRAFTING INFORMATION The principal author of this revenue procedure is Bernard P. Vita irs org Harvey of the Office of Associate Chief Counsel (Income Tax & Accounting). Vita irs org For further information regarding this revenue procedure, contact Mr. Vita irs org Harvey at (202) 622-4930 (not a toll-free call). Vita irs org Prev  Up  Next   Home   More Internal Revenue Bulletins