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Tax preparation software Publication 519 - Introductory Material Table of Contents Future Developments IntroductionOrdering forms and publications. Tax preparation software Tax questions. Tax preparation software What's New Reminders Future Developments For the latest information about developments related to Publication 519, such as legislation enacted after it was published, go to www. Tax preparation software irs. Tax preparation software gov/pub519. Tax preparation software Introduction For tax purposes, an alien is an individual who is not a U. Tax preparation software S. Tax preparation software citizen. Tax preparation software Aliens are classified as nonresident aliens and resident aliens. Tax preparation software This publication will help you determine your status and give you information you will need to file your U. Tax preparation software S. Tax preparation software tax return. Tax preparation software Resident aliens generally are taxed on their worldwide income, the same as U. Tax preparation software S. Tax preparation software citizens. Tax preparation software Nonresident aliens are taxed only on their income from sources within the United States and on certain income connected with the conduct of a trade or business in the United States. Tax preparation software The information in this publication is not as comprehensive for resident aliens as it is for nonresident aliens. Tax preparation software Resident aliens are generally treated the same as U. Tax preparation software S. Tax preparation software citizens and can find more information in other IRS publications. Tax preparation software Table A, Where To Find What You Need To Know About U. Tax preparation software S. Tax preparation software Taxes, provides a list of questions and the chapter or chapters in this publication where you will find the related discussion. Tax preparation software Answers to frequently asked questions are presented in the back of the publication. Tax preparation software Table A. Tax preparation software Where To Find What You Need To Know About U. Tax preparation software S. Tax preparation software Taxes Commonly Asked Questions Where To Find The Answer Am I a nonresident alien or resident alien? See chapter 1. Tax preparation software Can I be a nonresident alien and a resident alien in the same year? See Dual-Status Aliens in chapter 1. Tax preparation software See chapter 6. Tax preparation software I am a resident alien and my spouse is a nonresident alien. Tax preparation software Are there special rules for us? See Nonresident Spouse Treated as a Resident  in chapter 1. Tax preparation software See Community Income in chapter 2. Tax preparation software Is all my income subject to U. Tax preparation software S. Tax preparation software tax? See chapter 2. Tax preparation software See chapter 3. Tax preparation software Is my scholarship subject to U. Tax preparation software S. Tax preparation software tax? See Scholarship Grants, Prizes, and Awards in chapter 2. Tax preparation software See Scholarship and Fellowship Grants in chapter 3. Tax preparation software See chapter 9. Tax preparation software What is the tax rate on my income subject to U. Tax preparation software S. Tax preparation software tax? See chapter 4. Tax preparation software I moved to the United States this year. Tax preparation software Can I deduct my moving expenses on my U. Tax preparation software S. Tax preparation software return? See Deductions in chapter 5. Tax preparation software Can I claim exemptions for my spouse and children? See Exemptions in chapter 5. Tax preparation software I pay income taxes to my home country. Tax preparation software Can I get credit for these taxes on my U. Tax preparation software S. Tax preparation software tax return? See Tax Credits and Payments in chapter 5. Tax preparation software What forms must I file and when and where do I file them? See chapter 7. Tax preparation software How should I pay my U. Tax preparation software S. Tax preparation software income taxes? See chapter 8. Tax preparation software Am I eligible for any benefits under a tax treaty? See Income Entitled to Tax Treaty Benefits in chapter 8. Tax preparation software See chapter 9. Tax preparation software Are employees of foreign governments and international organizations exempt from U. Tax preparation software S. Tax preparation software tax? See chapter 10. Tax preparation software Is there anything special I have to do before leaving the United States? See chapter 11. Tax preparation software See Expatriation Tax in chapter 4. Tax preparation software Comments and suggestions. Tax preparation software   We welcome your comments about this publication and your suggestions for future editions. Tax preparation software   You can write to us at the following address: Internal Revenue Service Tax Forms and Publications Division 1111 Constitution Ave. Tax preparation software NW, IR-6526 Washington, DC 20224   We respond to many letters by telephone. Tax preparation software Therefore, it would be helpful if you would include your daytime phone number, including the area code, in your correspondence. Tax preparation software   You can send us comments from www. Tax preparation software irs. Tax preparation software gov/formspubs/. Tax preparation software Click on “More Information” and then on “Comment on Tax Forms and Publications. Tax preparation software ”   Although we cannot respond individually to each comment received, we do appreciate your feedback and will consider your comments as we revise our tax products. Tax preparation software Ordering forms and publications. Tax preparation software   Visit www. Tax preparation software irs. Tax preparation software gov/formspubs/ to download forms and publications, call 1-800-829-3676, or write to the address below and receive a response within 10 days after your request is received. Tax preparation software Internal Revenue Service 1201 N. Tax preparation software Mitsubishi Motorway Bloomington, IL 61705-6613 Tax questions. Tax preparation software   If you have a tax question, check the information available on IRS. Tax preparation software gov or call 1-800-829-1040. Tax preparation software We cannot answer tax questions sent to either of the above addresses. Tax preparation software What's New Personal exemption increased. Tax preparation software  For tax years beginning in 2013, the personal exemption amount is increased to $3,900. Tax preparation software U. Tax preparation software S. Tax preparation software real property interest. Tax preparation software  Generally, the treatment of a regulated investment company (RIC) as a qualified investment entity (QIE) was scheduled to expire at the end of 2011. Tax preparation software The provision has been extended through 2013. Tax preparation software The special rules that apply to distributions from a QIE attributable to the gain from the sale or exchange of a U. Tax preparation software S. Tax preparation software real property interest will continue to apply to any distribution from a RIC in 2013. Tax preparation software Beginning in 2014 (unless extended by legislation), a RIC will only be treated as a QIE for certain distributions from the RIC that are directly or indirectly attributable to distributions received by the RIC from a REIT. Tax preparation software See Qualified investment entities under U. Tax preparation software S. Tax preparation software Real Property Interest. Tax preparation software Interest-related dividends and short-term capital gain dividends received from mutual funds. Tax preparation software  The exemption of tax on certain interest-related dividends and short-term capital gain dividends paid by a mutual fund or other regulated investment company was scheduled to expire at the end of 2011. Tax preparation software These provisions have been extended through 2013. Tax preparation software The exemption expires for amounts paid in tax years beginning after December 31, 2013 (unless extended by legislation). Tax preparation software Multi-level marketing. Tax preparation software  Clarification regarding the characterization and source of income received from multi-level marketing companies by distributors (upper-tier distributors) that are based on the sales or purchases of persons whom they have recruited and sponsored (lower-tier distributors) is provided. Tax preparation software See Multi-level marketing under Personal Services in chapter 2. Tax preparation software Additional Medicare Tax. Tax preparation software  For 2013, you may be required to pay Additional Medicare Tax. Tax preparation software Also, you may need to report Additional Medicare Tax withheld by your employer. Tax preparation software For more information, see Additional Medicare Tax under Social Security and Medicare Taxes and Self-Employment Tax in chapter 8. Tax preparation software For more information on Additional Medicare Tax, go to IRS. Tax preparation software gov and enter “Additional Medicare Tax” in the search box. Tax preparation software Reminders Refunds of certain withholding tax delayed. Tax preparation software  Refund requests for tax withheld and reported on Form 1042-S, Form 8288-A, or Form 8805 may require additional time for processing. Tax preparation software Allow up to 6 months for these refunds to be issued. Tax preparation software Third party designee. Tax preparation software  You can check the “Yes” box in the “Third Party Designee” area of your return to authorize the IRS to discuss your return with a friend, family member, or any other person you choose. Tax preparation software This allows the IRS to call the person you identified as your designee to answer any questions that may arise during the processing of your return. Tax preparation software It also allows your designee to perform certain actions such as asking the IRS for copies of notices or transcripts related to your return. Tax preparation software Also, the authorization can be revoked. Tax preparation software See your income tax return instructions for details. Tax preparation software Change of address. Tax preparation software . Tax preparation software  If you change your mailing address, be sure to notify the Internal Revenue Service using Form 8822, Change of Address. Tax preparation software Photographs of missing children. Tax preparation software  The Internal Revenue Service is a proud partner with the National Center for Missing and Exploited Children. Tax preparation software Photographs of missing children selected by the Center may appear in this publication on pages that would otherwise be blank. Tax preparation software You can help bring these children home by looking at the photographs and calling 1-800-THE-LOST (1-800-843-5678) if you recognize a child. Tax preparation software Prev  Up  Next   Home   More Online Publications
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Tax preparation software 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. Tax preparation software Under these treaties, residents (not necessarily citizens) of foreign countries are taxed at a reduced rate, or are exempt from U. Tax preparation software S. Tax preparation software income taxes on certain items of income they receive from sources within the United States. Tax preparation software These reduced rates and exemptions vary among countries and specific items of income. Tax preparation software 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. Tax preparation software Also see Publication 519. Tax preparation software Many of the individual states of the United States tax the income of their residents. Tax preparation software 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. Tax preparation software Tax treaties reduce the U. Tax preparation software S. Tax preparation software taxes of residents of foreign countries. Tax preparation software With certain exceptions, they do not reduce the U. Tax preparation software S. Tax preparation software taxes of U. Tax preparation software S. Tax preparation software citizens or residents. Tax preparation software U. Tax preparation software S. Tax preparation software citizens and residents are subject to U. Tax preparation software S. Tax preparation software income tax on their worldwide income. Tax preparation software Treaty provisions generally are reciprocal (apply to both treaty countries); therefore, a U. Tax preparation software S. Tax preparation software 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. Tax preparation software Foreign taxing authorities sometimes require certification from the U. Tax preparation software S. Tax preparation software Government that an applicant filed an income tax return as a U. Tax preparation software S. Tax preparation software citizen or resident, as part of the proof of entitlement to the treaty benefits. Tax preparation software See Form 8802, Application for United States Residency Certification, to request a certification. Tax preparation software Disclosure of a treaty-based position that reduces your tax. Tax preparation software   If you take the position that any U. Tax preparation software S. Tax preparation software tax is overruled or otherwise reduced by a U. Tax preparation software S. Tax preparation software treaty (a treaty-based position), you generally must disclose that position on Form 8833 and attach it to your return. Tax preparation software 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. Tax preparation software 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. Tax preparation software For more information, see Publication 519 and the Form 8833 instructions. Tax preparation software   If you fail to file Form 8833, you may have to pay a $1,000 penalty. Tax preparation software Corporations are subject to a $10,000 penalty for each failure. Tax preparation software 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. Tax preparation software Pay for certain personal services performed in the United States. Tax preparation software Pay of a professor, teacher, or researcher who teaches or performs research in the United States for a limited time. Tax preparation software Amounts received for maintenance and studies by a foreign student or apprentice who is here for study or experience. Tax preparation software Wages, salaries, and pensions paid by a foreign government. Tax preparation software Personal Services Income Pay for certain personal services performed in the United States is exempt from U. Tax preparation software S. Tax preparation software 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. Tax preparation software For this purpose, the word “day” means a day during any part of which you are physically present in the United States. Tax preparation software Terms defined. Tax preparation software   Several terms appear in many of the discussions that follow. Tax preparation software The exact meanings of the terms are determined by the particular tax treaty under discussion; thus, the meanings vary among treaties. Tax preparation software The definitions that follow are, therefore, general definitions that may not give the exact meaning intended by a particular treaty. Tax preparation software   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. Tax preparation software   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. Tax preparation software 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. Tax preparation software S. Tax preparation software 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. Tax preparation software If they have a fixed base available in the United States, they are taxed on the income attributable to the fixed base. Tax preparation software 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. Tax preparation software S. Tax preparation software 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. Tax preparation software 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. Tax preparation software 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. Tax preparation software S. Tax preparation software income tax if they do not have a fixed base regularly available to them in the United States for performing the services. Tax preparation software If they have a fixed base available in the United States, they are taxed on the income attributable to the fixed base. Tax preparation software Income that residents of Austria receive for services performed in the United States as employees (dependent personal services) is exempt from U. Tax preparation software S. Tax preparation software income tax if the residents meet the following requirements. Tax preparation software They are in the United States for no more than 183 days in any 12-month period beginning or ending in the tax year. Tax preparation software Their income is paid by, or on behalf of, an employer who is not a U. Tax preparation software S. Tax preparation software resident. Tax preparation software Their income is not borne by a permanent establishment or a fixed base that the employer has in the United States. Tax preparation software 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. Tax preparation software 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. Tax preparation software S. Tax preparation software income tax. Tax preparation software 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. Tax preparation software S. Tax preparation software 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. Tax preparation software If they have a fixed base available in the United States, they are taxed on the income attributable to the fixed base. Tax preparation software Income that residents of Bangladesh receive for services performed in the United States as employees (dependent personal services) is exempt from U. Tax preparation software S. Tax preparation software income tax if the residents meet the following requirements. Tax preparation software They are in the United States for no more than 183 days in any 12-month period beginning or ending in the tax year. Tax preparation software Their income is paid by, or on behalf of, an employer who is not a U. Tax preparation software S. Tax preparation software resident. Tax preparation software Their income is not borne by a permanent establishment or a fixed base that the employer has in the United States. Tax preparation software 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. Tax preparation software Regardless of these limits, income of Bangladesh entertainers is exempt from U. Tax preparation software S. Tax preparation software 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. Tax preparation software 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. Tax preparation software S. Tax preparation software tax. Tax preparation software If the ship or aircraft is operated by a U. Tax preparation software S. Tax preparation software enterprise, the income is subject to U. Tax preparation software S. Tax preparation software tax. Tax preparation software If the resident of Bangladesh is a shareholder in a U. Tax preparation software S. Tax preparation software corporation, these exemptions do not apply to directors' fees received as a member of the board of directors of the U. Tax preparation software S. Tax preparation software corporation. Tax preparation software 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. Tax preparation software S. Tax preparation software tax at the rate of 15%. Tax preparation software 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. Tax preparation software S. Tax preparation software 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. Tax preparation software S. Tax preparation software residents that is not more than $5,000 (there is no dollar limit if the contractors are not U. Tax preparation software S. Tax preparation software residents), and Do not have a regular base available in the United States for performing the services. Tax preparation software 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. Tax preparation software Income that residents of Barbados receive for personal services performed in the United States as employees (dependent personal services) is exempt from U. Tax preparation software S. Tax preparation software tax if the residents meet four requirements. Tax preparation software They are in the United States for no more than 183 days during the calendar year. Tax preparation software The income earned in the calendar year in the United States is not more than $5,000. Tax preparation software Their income is paid by or for an employer who is not a U. Tax preparation software S. Tax preparation software resident. Tax preparation software The income is not borne by a permanent establishment or regular base of the employer in the United States. Tax preparation software 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. Tax preparation software S. Tax preparation software tax. Tax preparation software 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. Tax preparation software 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. Tax preparation software 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. Tax preparation software Under that provision, business profits are exempt from U. Tax preparation software S. Tax preparation software income tax unless the individual has a permanent establishment in the United States. Tax preparation software If they have a permanent establishment in the United States, they are taxed on the profit attributable to the permanent establishment. Tax preparation software Income that residents of Belgium receive for services performed in the United States as employees (dependent personal services) is exempt from U. Tax preparation software S. Tax preparation software income tax if the residents meet the following requirements. Tax preparation software They are in the United States for no more than 183 days in any 12-month period beginning or ending in the tax year. Tax preparation software Their income is paid by, or on behalf of, an employer who is not a U. Tax preparation software S. Tax preparation software resident. Tax preparation software Their income is not borne by a permanent establishment that the employer has in the United States. Tax preparation software 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. Tax preparation software 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. Tax preparation software S. Tax preparation software tax. Tax preparation software 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. Tax preparation software S. Tax preparation software income tax. Tax preparation software 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. Tax preparation software Under that provision, business profits are exempt from U. Tax preparation software S. Tax preparation software income tax unless the individual has a permanent establishment in the United States. Tax preparation software If they have a permanent establishment in the United States, they are taxed on the profit attributable to the permanent establishment. Tax preparation software 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. Tax preparation software Income that residents of Bulgaria receive for services performed in the United States as employees (dependent personal services) is exempt from U. Tax preparation software S. Tax preparation software income tax if the residents meet the following requirements. Tax preparation software They are in the United States for no more than 183 days in any 12-month period beginning or ending in the tax year. Tax preparation software Their income is paid by, or on behalf of, an employer who is not a U. Tax preparation software S. Tax preparation software resident. Tax preparation software Their income is not borne by a permanent establishment that the employer has in the United States. Tax preparation software 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. Tax preparation software S. Tax preparation software company. Tax preparation software 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. Tax preparation software S. Tax preparation software tax. Tax preparation software 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. Tax preparation software S. Tax preparation software income tax. Tax preparation software 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. Tax preparation software Under that provision, business profits are exempt from U. Tax preparation software S. Tax preparation software income tax unless the individual has a permanent establishment in the United States. Tax preparation software If they have a permanent establishment in the United States, they are taxed on the profit attributable to the permanent establishment. Tax preparation software 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. Tax preparation software Income that residents of Canada receive for personal services performed as employees (dependent personal services) in the United States is exempt from U. Tax preparation software S. Tax preparation software tax if it is not more than $10,000 for the year. Tax preparation software 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. Tax preparation software S. Tax preparation software resident, and is not borne by a permanent establishment in the United States. Tax preparation software 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. Tax preparation software S. Tax preparation software tax. Tax preparation software 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. Tax preparation software 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. Tax preparation software S. Tax preparation software tax. Tax preparation software 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. Tax preparation software S. Tax preparation software 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. Tax preparation software If they have a fixed base available in the United States, they are taxable on the income attributable to the fixed base. Tax preparation software 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. Tax preparation software S. Tax preparation software 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. Tax preparation software S. Tax preparation software resident, and The pay is not borne by a permanent establishment or fixed base that the employer has in the United States. Tax preparation software These exemptions do not apply to directors' fees for service on the board of directors of a U. Tax preparation software S. Tax preparation software corporation. Tax preparation software 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). Tax preparation software However, income of athletes or public entertainers from China participating in a cultural exchange program agreed upon by the U. Tax preparation software S. Tax preparation software and Chinese governments is exempt from U. Tax preparation software S. Tax preparation software tax. Tax preparation software Commonwealth of Independent States Income that residents of a C. Tax preparation software I. Tax preparation software S. Tax preparation software member receive for performing personal services in the United States is exempt from U. Tax preparation software S. Tax preparation software income tax if those residents are in the United States for no more than 183 days during the tax year. Tax preparation software 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. Tax preparation software I. Tax preparation software S. Tax preparation software member or a resident of a C. Tax preparation software I. Tax preparation software S. Tax preparation software member is exempt from U. Tax preparation software S. Tax preparation software tax. Tax preparation software 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. Tax preparation software S. Tax preparation software 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. Tax preparation software If they have a fixed base available in the United States, they are taxable on the income attributable to the fixed base. Tax preparation software 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. Tax preparation software S. Tax preparation software 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. Tax preparation software S. Tax preparation software 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. Tax preparation software 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. Tax preparation software S. Tax preparation software tax. Tax preparation software 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. Tax preparation software Directors' fees received by residents of Cyprus for service on the board of directors of a U. Tax preparation software S. Tax preparation software corporation are exempt from U. Tax preparation software S. Tax preparation software 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. Tax preparation software 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. Tax preparation software S. Tax preparation software 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. Tax preparation software If they have a fixed base available, they are taxed only on income attributable to the fixed base. Tax preparation software Income that residents of the Czech Republic receive for employment in the United States (dependent personal services) is exempt from U. Tax preparation software S. Tax preparation software income tax if the following three requirements are met. Tax preparation software The resident is present in the United States for no more than 183 days in any 12-month period. Tax preparation software The income is paid by, or on behalf of, an employer who is not a U. Tax preparation software S. Tax preparation software resident. Tax preparation software The income is not borne by a permanent establishment or a fixed base that the employer has in the United States. Tax preparation software 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. Tax preparation software Regardless of these limits, income of Czech entertainers and sportsmen is exempt from U. Tax preparation software S. Tax preparation software 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. Tax preparation software 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. Tax preparation software 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. Tax preparation software S. Tax preparation software income tax. Tax preparation software If the ship or aircraft is operated by a U. Tax preparation software S. Tax preparation software enterprise, the income is subject to U. Tax preparation software S. Tax preparation software tax. Tax preparation software 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. Tax preparation software S. Tax preparation software income tax if they do not have a fixed base regularly available to them in the United States for performing the services. Tax preparation software If they have a fixed base available in the United States, they are taxed on the income attributable to the fixed base. Tax preparation software Income that residents of Denmark receive for services performed in the United States as employees (dependent personal services) is exempt from U. Tax preparation software S. Tax preparation software income tax if the residents meet the following requirements. Tax preparation software They are in the United States for no more than 183 days in any 12-month period beginning or ending in the tax year. Tax preparation software Their income is paid by, or on behalf of, an employer who is not a U. Tax preparation software S. Tax preparation software resident. Tax preparation software Their income is not borne by a permanent establishment or a fixed base that the employer has in the United States. Tax preparation software 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. Tax preparation software 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. Tax preparation software 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. Tax preparation software S. Tax preparation software income tax. Tax preparation software 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. Tax preparation software S. Tax preparation software income tax if they are in the United States for no more than 89 days during the tax year. Tax preparation software 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. Tax preparation software S. Tax preparation software income tax if the residents meet four requirements. Tax preparation software They are in the United States for no more than 89 days during the tax year. Tax preparation software They are employees of a resident of, or a permanent establishment in, Egypt. Tax preparation software Their income is not borne by a permanent establishment that the employer has in the United States. Tax preparation software Their income is subject to Egyptian tax. Tax preparation software 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. Tax preparation software 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. Tax preparation software 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. Tax preparation software S. Tax preparation software 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. Tax preparation software If they have a fixed base available, they are taxed on the income attributable to the fixed base. Tax preparation software Income that residents of Estonia receive for services performed in the United States as employees (dependent personal services) is exempt from U. Tax preparation software S. Tax preparation software income tax if the following requirements are met. Tax preparation software 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. Tax preparation software The income is paid by, or on behalf of, an employer who is not a U. Tax preparation software S. Tax preparation software resident. Tax preparation software The income is not borne by a permanent establishment or a fixed base that the employer has in the United States. Tax preparation software 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. Tax preparation software S. Tax preparation software resident. Tax preparation software 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. Tax preparation software S. Tax preparation software tax. Tax preparation software 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. Tax preparation software Regardless of these limits, income of Estonian entertainers or athletes is exempt from U. Tax preparation software S. Tax preparation software 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. Tax preparation software 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. Tax preparation software S. Tax preparation software income tax if they do not have a fixed base regularly available to them in the United States for performing the services. Tax preparation software If they have a fixed base available in the United States, they are taxed on the income attributable to the fixed base. Tax preparation software 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. Tax preparation software S. Tax preparation software income tax if the residents meet three requirements. Tax preparation software They are in the United States for no more than 183 days during any 12-month period. Tax preparation software Their income is paid by, or on behalf of, an employer who is not a resident of the United States. Tax preparation software Their income is not borne by a permanent establishment, fixed base, or trade or business that the employer has in the United States. Tax preparation software 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. Tax preparation software 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. Tax preparation software 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. Tax preparation software S. Tax preparation software income tax if they do not have a fixed base regularly available to them in the United States for performing the services. Tax preparation software If they have a fixed base available in the United States, they are taxed on the income attributable to the fixed base. Tax preparation software 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. Tax preparation software S. Tax preparation software income tax if the residents meet three requirements. Tax preparation software They are in the United States for no more than 183 days in any 12-month period. Tax preparation software Their income is paid by, or on behalf of, an employer who is not a resident of the United States. Tax preparation software Their income is not borne by a permanent establishment or a fixed base that the employer has in the United States. Tax preparation software 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. Tax preparation software 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. Tax preparation software Regardless of these limits, income of French entertainers or sportsmen is exempt from U. Tax preparation software S. Tax preparation software tax if their visit is principally supported by public funds of France. Tax preparation software 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. Tax preparation software 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. Tax preparation software Under that provision, business profits are exempt from U. Tax preparation software S. Tax preparation software income tax unless the individual has a permanent establishment in the United States. Tax preparation software If they have a permanent establishment in the United States, they are taxed on the profit attributable to the permanent establishment. Tax preparation software 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. Tax preparation software S. Tax preparation software tax if the residents meet three requirements. Tax preparation software They are in the United States for no more than 183 days during the calendar year. Tax preparation software The income is paid by, or on behalf of, an employer who is not a resident of the United States. Tax preparation software The income is not borne by a permanent establishment that the employer has in the United States. Tax preparation software 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. Tax preparation software S. Tax preparation software tax. Tax preparation software 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. Tax preparation software 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. Tax preparation software S. Tax preparation software 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. Tax preparation software Income of German entertainers or athletes is exempt from U. Tax preparation software S. Tax preparation software tax if their visit to the United States is substantially supported by public funds of Germany, its political subdivisions, or local authorities. Tax preparation software Greece Income that residents of Greece receive for labor or personal services (including practicing liberal and artistic professions) is exempt from U. Tax preparation software S. Tax preparation software 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. Tax preparation software The pay, regardless of amount, is exempt from U. Tax preparation software S. Tax preparation software 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. Tax preparation software 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. Tax preparation software S. Tax preparation software 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. Tax preparation software If they have a fixed base available in the United States, they are taxed on the income attributable to the fixed base. Tax preparation software 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. Tax preparation software S. Tax preparation software income tax if the residents meet three requirements. Tax preparation software They are in the United States for no more than 183 days during the tax year. Tax preparation software Their income is paid by or on behalf of an employer who is not a resident of the United States. Tax preparation software Their income is not borne by a permanent establishment or a fixed base that the employer has in the United States. Tax preparation software 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. Tax preparation software S. Tax preparation software tax. Tax preparation software If the ship or aircraft is operated by a U. Tax preparation software S. Tax preparation software enterprise, the pay is subject to U. Tax preparation software S. Tax preparation software tax. Tax preparation software 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. Tax preparation software Under that provision, business profits are exempt from U. Tax preparation software S. Tax preparation software income tax unless the individual has a permanent establishment in the United States. Tax preparation software If they have a permanent establishment in the United States, they are taxed on the profit attributable to the permanent establishment. Tax preparation software Income that residents of Iceland receive for services performed in the United States as employees (dependent personal services) is exempt from U. Tax preparation software S. Tax preparation software income tax if the residents meet the following requirements. Tax preparation software They are in the United States for no more than 183 days in any 12-month period beginning or ending in the tax year. Tax preparation software Their income is paid by, or on behalf of, an employer who is not a U. Tax preparation software S. Tax preparation software resident. Tax preparation software Their income is not borne by a permanent establishment that the employer has in the United States. Tax preparation software 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. Tax preparation software S. Tax preparation software company. Tax preparation software 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. Tax preparation software S. Tax preparation software tax. Tax preparation software 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. Tax preparation software S. Tax preparation software income tax. Tax preparation software 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. Tax preparation software S. Tax preparation software 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. Tax preparation software If they have a fixed base available, they are taxed only on income attributable to the fixed base. Tax preparation software Income that residents of India receive for personal services performed in the United States as employees (dependent personal services) is exempt from U. Tax preparation software S. Tax preparation software income tax if the residents meet three requirements. Tax preparation software They are present in the United States for no more than 183 days during the tax year. Tax preparation software The income is paid by, or on behalf of, an employer who is not a resident of the United States. Tax preparation software The income is not borne by a permanent establishment, fixed base, or trade or business the employer has in the United States. Tax preparation software 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. Tax preparation software S. Tax preparation software enterprise. Tax preparation software 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. Tax preparation software S. Tax preparation software resident. Tax preparation software 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. Tax preparation software Regardless of this limit, the income of Indian entertainers and athletes is exempt from U. Tax preparation software S. Tax preparation software 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. Tax preparation software 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. Tax preparation software S. Tax preparation software 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. Tax preparation software If they have a fixed base available, they are taxed only on the income attributable to the fixed base. Tax preparation software Income that residents of Indonesia receive for personal services performed in the United States as employees (dependent personal services) is exempt from U. Tax preparation software S. Tax preparation software income tax if the residents meet three requirements. Tax preparation software They are present in the United States no more than 119 days during any consecutive 12-month period. Tax preparation software The income is paid by, or on behalf of, an employer who is not a resident of the United States. Tax preparation software The income is not borne or reimbursed by a permanent establishment the employer has in the United States. Tax preparation software 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. Tax preparation software S. Tax preparation software tax if the individual is a member of the regular complement of the ship or aircraft. Tax preparation software 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. Tax preparation software Regardless of these limits, income of Indonesian entertainers and athletes is exempt from U. Tax preparation software S. Tax preparation software 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. Tax preparation software 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. Tax preparation software S. Tax preparation software income tax if they do not have a fixed base regularly available to them in the United States for performing the services. Tax preparation software If they have a fixed base available in the United States, they are taxed on the income attributable to the fixed base. Tax preparation software Income that residents of Ireland receive for services performed in the United States as employees (dependent personal services) is exempt from U. Tax preparation software S. Tax preparation software income tax if the residents meet the following requirements. Tax preparation software They are in the United States for no more than 183 days in any 12-month period beginning or ending in the tax year. Tax preparation software Their income is paid by, or on behalf of, an employer who is not a U. Tax preparation software S. Tax preparation software resident. Tax preparation software Their income is not borne by a permanent establishment or a fixed base that the employer has in the United States. Tax preparation software 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. Tax preparation software However, amounts received for attending meetings in Ireland are not subject to U. Tax preparation software S. Tax preparation software income tax. Tax preparation software 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. Tax preparation software S. Tax preparation software income tax. Tax preparation software 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. Tax preparation software 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. Tax preparation software S. Tax preparation software income tax if they are in the United States for no more than 182 days during the tax year. Tax preparation software 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. Tax preparation software S. Tax preparation software income tax if the residents meet four requirements. Tax preparation software They are in the United States for no more than 182 days during the tax year. Tax preparation software They are employees of a resident of, or a permanent establishment in, Israel. Tax preparation software Their income is not borne by a permanent establishment that the employer has in the United States. Tax preparation software Their income is subject to Israeli tax. Tax preparation software 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. Tax preparation software S. Tax preparation software resident. Tax preparation software 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. Tax preparation software 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. Tax preparation software S. Tax preparation software income tax if they do not have a fixed base regularly available to them in the United States for performing the services. Tax preparation software If they have a fixed base available in the United States, they are taxed on the income attributable to the fixed base. Tax preparation software 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. Tax preparation software S. Tax preparation software income tax if the following requirements are met. Tax preparation software The residents are in the United States for no more than 183 days during the tax year. Tax preparation software The income is paid by, or on behalf of, an employer who is not a resident of the United States. Tax preparation software The income is not borne by a permanent establishment or a fixed base that the employer has in the United States. Tax preparation software 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. Tax preparation software S. Tax preparation software resident. Tax preparation software Pay received for employment regularly exercised aboard a ship or aircraft operated by a U. Tax preparation software S. Tax preparation software enterprise is subject to U. Tax preparation software S. Tax preparation software tax. Tax preparation software 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. Tax preparation software 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. Tax preparation software S. Tax preparation software 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. Tax preparation software S. Tax preparation software contractor. Tax preparation software 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. Tax preparation software There is no dollar limit for condition (3) if the contractor is from a country other than the United States. Tax preparation software Income that residents of Jamaica receive for personal services performed in the United States as employees (dependent personal services) is exempt from U. Tax preparation software S. Tax preparation software income tax if the residents meet four requirements. Tax preparation software They are in the United States for no more than 183 days during the tax year. Tax preparation software Their income is paid by or for an employer who is not a resident of the United States. Tax preparation software Their income is not borne by a permanent establishment or a fixed base that the employer has in the United States. Tax preparation software Their net income received for the services is not more than $5,000 during the tax year. Tax preparation software 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. Tax preparation software S. Tax preparation software tax. Tax preparation software If the ship or aircraft is operated by a U. Tax preparation software S. Tax preparation software enterprise, the pay is subject to U. Tax preparation software S. Tax preparation software tax. Tax preparation software 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. Tax preparation software Directors' fees received by residents of Jamaica for services performed in the United States as members of boards of directors of U. Tax preparation software S. Tax preparation software corporations are exempt from U. Tax preparation software S. Tax preparation software 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. Tax preparation software 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. Tax preparation software Under that provision, business profits are exempt from U. Tax preparation software S. Tax preparation software income tax unless the individual has a permanent establishment in the United States. Tax preparation software If they have a permanent establishment in the United States, they are taxed on the profits attributable to the permanent establishment. Tax preparation software Income that residents of Japan receive for services performed in the United States as employees (dependent personal services) is exempt from U. Tax preparation software S. Tax preparation software income tax if the residents meet the following requirements. Tax preparation software They are in the United States for no more than 183 days in any 12-month period beginning or ending in the tax year. Tax preparation software Their income is paid by, or on behalf of, an employer who is not a U. Tax preparation software S. Tax preparation software resident. Tax preparation software Their income is not borne by a permanent establishment that the employer has in the United States. Tax preparation software 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. Tax preparation software 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. Tax preparation software S. Tax preparation software resident. Tax preparation software 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. Tax preparation software S. Tax preparation software tax. Tax preparation software 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. Tax preparation software S. Tax preparation software 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. Tax preparation software If the residents have a fixed base available, they are taxed only on the income attributable to the fixed base. Tax preparation software Income that residents of Kazakhstan receive for employment in the United States (dependent personal services) is exempt from U. Tax preparation software S. Tax preparation software income tax if the following three requirements are met. Tax preparation software The resident is in the United States for no more than 183 days in any 12-month period. Tax preparation software The income is paid by, or on behalf of, an employer who is not a resident of the United States. Tax preparation software The income is not borne by a permanent establishment or a fixed base that the employer has in the United States. Tax preparation software 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. Tax preparation software S. Tax preparation software tax. Tax preparation software 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. Tax preparation software S. Tax preparation software resident. Tax preparation software 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. Tax preparation software S. Tax preparation software 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. Tax preparation software 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. Tax preparation software 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. Tax preparation software S. Tax preparation software tax if the residents meet four requirements. Tax preparation software They are in the United States for no more than 182 days during the tax year. Tax preparation software They are employees of a resident of Korea or of a permanent establishment maintained in Korea. Tax preparation software Their compensation is not borne by a permanent establishment that the employer has in the United States. Tax preparation software Their income for those services is not more than $3,000. Tax preparation software 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. Tax preparation software 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. Tax preparation software S. Tax preparation software 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. Tax preparation software If they have a fixed base available, they are taxed only on the income attributable to the fixed base. Tax preparation software Income that residents of Latvia receive for services performed in the United States as employees (dependent personal services) is exempt from U. Tax preparation software S. Tax preparation software income tax if the following requirements are met. Tax preparation software 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. Tax preparation software The income is paid by, or on behalf of, an employer who is not a U. Tax preparation software S. Tax preparation software resident. Tax preparation software The income is not borne by a permanent establishment or a fixed base that the employer has in the United States. Tax preparation software 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. Tax preparation software S. Tax preparation software enterprise. Tax preparation software 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. Tax preparation software S. Tax preparation software resident. Tax preparation software 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. Tax preparation software Regardless of these limits, income of Latvian entertainers or athletes is exempt from U. Tax preparation software S. Tax preparation software 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. Tax preparation software 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. Tax preparation software S. Tax preparation software 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. Tax preparation software If they have a fixed base available, they are taxed only on the income attributable to the fixed base. Tax preparation software Income that residents of Lithuania receive for services performed in the United States as employees (dependent personal services) is exempt from U. Tax preparation software S. Tax preparation software income tax if the following requirements are met. Tax preparation software 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. Tax preparation software The income is paid by, or on behalf of, an employer who is not a U. Tax preparation software S. Tax preparation software resident. Tax preparation software The income is not borne by a permanent establishment or a fixed base that the employer has in the United States. Tax preparation software 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. Tax preparation software S. Tax preparation software enterprise. Tax preparation software 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. Tax preparation software S. Tax preparation software resident. Tax preparation software 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. Tax preparation software Regardless of these limits, income of Lithuanian entertainers or athletes is exempt from U. Tax preparation software S. Tax preparation software 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. Tax preparation software 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. Tax preparation software S. Tax preparation software income tax if they do not have a fixed base regularly available to them in the United States for performing the services. Tax preparation software If they have a fixed base available in the United States, they are taxed on the income attributable to the fixed base. Tax preparation software Income that residents of Luxembourg receive for services performed in the United States as employees (dependent personal services) is exempt from U. Tax preparation software S. Tax preparation software income tax if the residents meet the following requirements. Tax preparation software They are in the United States for no more than 183 days in any 12-month period beginning or ending in the tax year. Tax preparation software Their income is paid by, or on behalf of, an employer who is not a U. Tax preparation software S. Tax preparation software resident. Tax preparation software Their income is not borne by a permanent establishment or a fixed base that the employer has in the United States. Tax preparation software 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. Tax preparation software S. Tax preparation software enterprise. Tax preparation software 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. Tax preparation software 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. Tax preparation software 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. Tax preparation software Under that provision, business profits are exempt from U. Tax preparation software S. Tax preparation software income tax unless the individual has a permanent establishment in the United States. Tax preparation software If they have a permanent establishment in the United States, they are taxed on the profits attributable to the permanent establishment. Tax preparation software Income that residents of Malta receive for services performed in the United States as employees (dependent personal services) is exempt from U. Tax preparation software S. Tax preparation software income tax if the residents meet the following requirements. Tax preparation software They are in the United States for no more than 183 days in any 12-month period beginning or ending in the tax year. Tax preparation software Their income is paid by, or on behalf of, an employer who is not a U. Tax preparation software S. Tax preparation software resident. Tax preparation software Their income is not borne by a permanent establishment that the employer has in the United States. Tax preparation software 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. Tax preparation software 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. Tax preparation software S. Tax preparation software tax. Tax preparation software Income received by a resident of Malta for employment aboard a ship or an aircraft operated in international traffic is exempt from U. Tax preparation software S. Tax preparation software income tax if the individual is a member of the regular complement of the ship or aircraft. Tax preparation software 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. Tax preparation software S. Tax preparation software 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. Tax preparation software If they have a fixed base available, they are taxed only on income attributable to the fixed base. Tax preparation software Income that residents of Mexico receive for employment in the United States (dependent personal services) is exempt from U. Tax preparation software S. Tax preparation software tax if the following three requirements are met. Tax preparation software The resident is present in the United States for no more than 183 days in a 12-month period. Tax preparation software The income is paid by, or on behalf of, an employer who is not a resident of the United States. Tax preparation software The income is not borne by a permanent establishment or fixed base that the employer has in the United States. Tax preparation software 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. Tax preparation software S. Tax preparation software resident. Tax preparation software 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. Tax preparation software This includes income from activities performed in the United States relating to the entertainer or athlete's reputation, such as endorsements of commercial products. Tax preparation software Regardless of this limit, the income of Mexican entertainers and athletes is exempt from U. Tax preparation software S. Tax preparation software tax if their visit to the United States is substantially supported by public funds of Mexico, its political subdivisions, or local authorities. Tax preparation software 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. Tax preparation software S. Tax preparation software 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. Tax preparation software 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. Tax preparation software 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. Tax preparation software S. Tax preparation software income tax if the residents meet three requirements. Tax preparation software They are in the United States for less than 183 days during the tax year. Tax preparation software 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. Tax preparation software Their income is not borne by a permanent establishment that the employer has in the United States. Tax preparation software Compensation received for services performed by a member of the board of directors of a corporation does not qualify for this exemption. Tax preparation software 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. Tax preparation software S. Tax preparation software income tax if the individual is a member of the regular complement of the ship or aircraft. Tax preparation software 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. Tax preparation software 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. Tax preparation software S. Tax preparation software income tax if the income is not attributable to a fixed base in the United States that is regularly available for performing the services. Tax preparation software Income that residents of the Netherlands receive for employment in the United States (dependent personal services) is exempt from U. Tax preparation software S. Tax preparation software income tax if the following three requirements are met. Tax preparation software The resident is in the United States for no more than 183 days during the tax year. Tax preparation software The income is paid by, or on behalf of, an employer who is not a U. Tax preparation software S. Tax preparation software resident. Tax preparation software The income is not borne by a permanent establishment or fixed base the employer has in the United States. Tax preparation software Income received by a Netherlands resident for employment as a member of the regular complement of a ship or