Guide to Global Payroll Management - 2020 - E-45

Exemption does not apply if gross receipts, including reimbursements, exceed this amount during the year. Income is fully exempt if visit is wholly or mainly
supported by public funds of one or both of the treaty countries or their political subdivisions or local authorities.

Exemption applies to a business apprentice (trainee) only for a period not exceeding 1 year (2 years for Belgium and Bulgaria) from the date of arrival in the
United States.

Treated as business profits under Article 7 (VII) of the treaty.

Employment with a team which participates in a league with regularly scheduled games in both countries is covered under the provisions for dependent
personal services.

Exemption does not apply if during the immediately preceding period, the individual claimed the benefit of Article 20(2), (3), or (4).

Labor or personal services performed in connection with the exploration or exploitation of the seabed and sub-soil and their natural resources is fully exempt
for a period of 60 days in the tax year.

Remuneration for employment exercised aboard a ship or aircraft operated in international traffic by a resident of a contracting State may be taxed in that
State. Canada may tax the income from employment if the income is derived by a resident of Canada and the ship or aircraft is operated by a resident of
Canada. If operated by a Luxembourg resident and Luxembourg fails to tax the income, such income shall be taxed in the State of which the employee is a
resident. The income may be taxed in Tunisia only if the ship or aircraft is operated by an enterprise that is managed and controlled in Tunisia.

Remuneration derived by a resident of a contracting State in respect of an employment as a member of the regular compliment of a ship or aircraft operated
in international traffic may only be taxed in that State.

Income from personal services performed by a resident of one contracting State as an employee aboard ships or aircraft operated by a resident of the other
contracting State in international traffic may be taxed by that other contracting State if the employee is a member of the regular compliment of the ship or
aircraft.

The test does not apply if the entertainer is a resident of the one contracting State and is present in the other Contracting State pursuant to a specific
arrangement agreed to by the contracting States under a Cultural Relations Agreement dated December 15, 1972.

The U.S.-U.S.S.R. Income Tax Treaty, signed June 20, 1973, applies to the countries of Armenia, Azerbaijan, Belarus. Georgia, Kyrgystan, Moldova,
Tajikistan, Turkmenistan, and Uzbekistan.

Table 2. Compensation for Personal Services Performed in United States Exempt from U.S. Income Tax Under Income Tax Treaties

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This provision does not apply if these activities are substantially supported by a nonprofit organization or by public funds of the treaty country or its political
subdivisions or local authorities. For Indonesia and the Philippines, the competent authority of the sending state must certify that the visit qualifies.

A $10,000 limit applies if the expense is borne by a permanent establishment or a fixed base in the United States. Exemption does not apply if the recipient
maintains a permanent establishment in the U.S. with which the income is effectively connected.

Footnotes to Table 2. Compensation for Personal Services Performed in United States Exempt from U.S. Income Tax Under Income Tax Treaties

Table 2. (Continued)

Appendix E-Miscellaneous Lists and Tables

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