Publication 901
U.S. Tax Treaties
(Revised: 4/2001)

Estonia

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

1. Payments from abroad, other than compensation for personal services, for maintenance, education, study, research, or training.
2. The grant, allowance, or award.
3. Income from personal services performed in the United States of up to $5,000 for each tax year.

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

An individual who is a resident of Estonia on the date of arrival in the United States and who is in the United States as an employee of, or under contract with, a resident of Estonia is exempt from U.S. income tax for a period of 12 consecutive months on up to $8,000 received for personal services if the individual is in the United States primarily to:

1. Acquire technical, professional, or business experience from a person other than that resident of Estonia, or
2. Study at an educational institution.

An individual who is a resident of Estonia on the date of arrival in the United States and who is temporarily present in the United States for not longer than 1 year as a participant in a program sponsored by the U.S. Government primarily to train, research, or study is exempt from U.S. income tax on income received for personal services for the training, research, or study in the amount of $10,000.

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

Finland

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

France

An individual who is a resident of France on the date of arrival in the United States and who is temporarily in the United States primarily to study at a university or other recognized educational institution in the United States, obtain professional training, or study, or do research as a recipient of a grant, allowance, or award from a not-for-profit governmental, religious, charitable, scientific, artistic, cultural, or educational organization is exempt from U.S. income tax on the following amounts.

1. Gifts from abroad for maintenance, education, study, research, or training.
2. The grant, allowance, or award.
3. Income from personal services performed in the United States of up to $5,000 each tax year.

An individual is entitled to this benefit and the benefit described earlier under Professors, Teachers, and Researchers for a maximum of 5 tax years.

This exemption does not apply to income from research carried on mainly for the private benefit of any person rather than in the public interest.

An individual who is a resident of France on the date of arrival in the United States and who is in the United States as an employee of, or under contract with, a resident of France is exempt from U.S. income tax for a period of 12 consecutive months on up to $8,000 received for personal services if the individual is in the United States primarily to:

1. Acquire technical, professional, or business experience from a person other than that resident of France, or
2. Study at an educational institution.

Germany

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

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

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

1. They are present in the United States for not more than 4 years, and
2. The services are performed for the purpose of supplementing funds available otherwise for maintenance, education, or training.

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

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

1. The individual is temporarily in the United States for not more than one year to acquire technical, professional, or business experience from any person other than his or her employer, and
2. The compensation is not more than $10,000.

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

Greece

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

Hungary

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

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

Iceland

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

1. Gifts from abroad for maintenance, education, study, research, or training.
2. The grant, allowance, or award.
3. Income from personal services performed in the United States of up to $2,000 each tax year.

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

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

1. Acquire technical, professional, or business experience from a person other than that resident of Iceland or other than a person related to that person, or
2. Study at an educational institution.

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

India

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

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

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

Indonesia

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

1. All payments from abroad for maintenance, education, study, research, or training.
2. The grant, allowance, or award.
3. Income from personal services performed in the United States of up to $2,000 each tax year.

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

Ireland

A student, apprentice, or business trainee who is a resident of Ireland immediately before visiting the United States and is in the United States for the purpose of full-time education at a recognized educational institution or full-time training is exempt from U.S. income tax on amounts received from sources outside the United States for the individual's maintenance, education, or training.

Apprentices and business trainees are entitled to the benefit of this exemption for a maximum period of 1 year.

Israel

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

1. Gifts from abroad for maintenance, education, study, research, or training.
2. The grant, allowance, or award.
3. Income from personal services performed in the United States of up to $3,000 each tax year.

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

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

1. Acquire technical, professional, or business experience from a person other than that resident of Israel or other than a person related to that resident, or
2. Study at a university or other educational institution.

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

Italy

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

Jamaica

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

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

1. Acquire technical, professional, or business experience from a person other than that resident of Jamaica or other than a person related to that resident, or
2. Study at a university or other recognized educational institution.

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

Japan

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

1. Gifts from abroad for maintenance, education, study, research, or training.
2. The grant, allowance, or award.
3. Income from personal services performed in the United States of up to $2,000 each tax year.

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

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

1. Acquire technical, professional, or business experience from a person other than that resident of Japan, or
2. Study at an educational institution.

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

Kazakstan

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

1. Study at a university or other accredited educational institution,
2. Obtain training required to qualify him or her to practice a profession or professional specialty, or,
3. Study or do research as a recipient of a grant, allowance, or other similar payments from a governmental, religious, charitable, scientific, literary, or educational organization.

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

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

Korea, Republic of

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

1. Amounts from abroad for maintenance, education, study, research, or training.
2. The grant, allowance, or award.
3. Income from personal services performed in the United States of up to $2,000 each tax year.

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

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

1. Acquire technical, professional, or business experience from a person other than that resident of Korea or other than a person related to that resident, or
2. Study at an educational institution.

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

Latvia

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

1. Payments from abroad, other than compensation for personal services, for maintenance, education, study, research, or training.
2. The grant, allowance, or award.
3. Income from personal services performed in the United States of up to $5,000 for each tax year.

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

An individual who is a resident of Latvia on the date of arrival in the United States and who is in the United States as an employee of, or under contract with, a resident of Latvia is exempt from U.S. income tax for a period of 12 consecutive months on up to $8,000 received for personal services if the individual is in the United States primarily to:

1. Acquire technical, professional, or business experience from a person other than that resident of Latvia, or
2. Study at an educational institution.

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

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

Lithuania

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

1. Payments from abroad, other than compensation for personal services, for maintenance, education, study, research, or training.
2. The grant, allowance, or award.
3. Income from personal services performed in the United States of up to $5,000 for each tax year.

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

An individual who is a resident of Lithuania on the date of arrival in the United States and who is in the United States as an employee of, or under contract with, a resident of Lithuania is exempt from U.S. income tax for a period of 12 consecutive months on up to $8,000 received for personal services if the individual is in the United States primarily to:

1. Acquire technical, professional, or business experience from a person other than that resident of Lithuania, or
2. Study at an educational institution.

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

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

Luxembourg

Note:    See the effective dates of the new treaty under Important Changes at the beginning of this publication.

New treaty.   A student, apprentice, or business trainee who is a resident of Luxembourg immediately before visiting the United States and is in the United States for the purpose of full-time education at a recognized educational institution or full-time training is exempt from U.S. income tax on amounts received for the individual's maintenance, education, or training.

Apprentices and business trainees are entitled to the benefit of this exemption for a maximum period of 2 years.

If the individual's visit to the United States is longer than 2 years, the exemption is lost for the entire visit unless the competent authorities of Luxembourg and the United States agree otherwise.

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

1. Students at a university, college, school, or other recognized educational institution, or
2. Business apprentices for not more than one year, or
3. Recipients of a grant, allowance, or award from a religious, charitable, scientific, literary, or educational organization primarily to study or research.

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

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

Mexico

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

Morocco

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

1. Gifts from abroad for maintenance, education, study, research, or training.
2. The grant, allowance, or award.
3. Income from personal services performed in the United States of up to $2,000 each tax year.

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

Netherlands

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

1. Payments from abroad for maintenance, education, or training.
2. Income from personal services performed in the United States of up to $2,000 each tax year.

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

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

1. The amount of the grant, allowance, or award.
2. Income of up to $2,000 for personal services performed in the United States for any tax year if the services are connected with, or incidental to, the study, research, or training.

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

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