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Amended Return

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Amended Return

Amended return 3. Amended return   Rent Expense Table of Contents Introduction Topics - This chapter discusses: RentConditional sales contract. Amended return Leveraged leases. Amended return Leveraged leases of limited-use property. Amended return Taxes on Leased Property Cost of Getting a Lease Improvements by Lessee Capitalizing Rent Expenses Introduction This chapter discusses the tax treatment of rent or lease payments you make for property you use in your business but do not own. Amended return It also discusses how to treat other kinds of payments you make that are related to your use of this property. Amended return These include payments you make for taxes on the property. Amended return Topics - This chapter discusses: The definition of rent Taxes on leased property The cost of getting a lease Improvements by the lessee Capitalizing rent expenses Rent Rent is any amount you pay for the use of property you do not own. Amended return In general, you can deduct rent as an expense only if the rent is for property you use in your trade or business. Amended return If you have or will receive equity in or title to the property, the rent is not deductible. Amended return Unreasonable rent. Amended return   You cannot take a rental deduction for unreasonable rent. Amended return Ordinarily, the issue of reasonableness arises only if you and the lessor are related. Amended return Rent paid to a related person is reasonable if it is the same amount you would pay to a stranger for use of the same property. Amended return Rent is not unreasonable just because it is figured as a percentage of gross sales. Amended return For examples of related persons, see Related persons in chapter 2, Publication 544. Amended return Rent on your home. Amended return   If you rent your home and use part of it as your place of business, you may be able to deduct the rent you pay for that part. Amended return You must meet the requirements for business use of your home. Amended return For more information, see Business use of your home in chapter 1. Amended return Rent paid in advance. Amended return   Generally, rent paid in your trade or business is deductible in the year paid or accrued. Amended return If you pay rent in advance, you can deduct only the amount that applies to your use of the rented property during the tax year. Amended return You can deduct the rest of your payment only over the period to which it applies. Amended return Example 1. Amended return You are a calendar year taxpayer and you leased a building for 5 years beginning July 1. Amended return Your rent is $12,000 per year. Amended return You paid the first year's rent ($12,000) on June 30. Amended return You can deduct only $6,000 (6/12 × $12,000) for the rent that applies to the first year. Amended return Example 2. Amended return You are a calendar year taxpayer. Amended return Last January you leased property for 3 years for $6,000 a year. Amended return You paid the full $18,000 (3 × $6,000) during the first year of the lease. Amended return Each year you can deduct only $6,000, the part of the lease that applies to that year. Amended return Canceling a lease. Amended return   You generally can deduct as rent an amount you pay to cancel a business lease. Amended return Lease or purchase. Amended return   There may be instances in which you must determine whether your payments are for rent or for the purchase of the property. Amended return You must first determine whether your agreement is a lease or a conditional sales contract. Amended return Payments made under a conditional sales contract are not deductible as rent expense. Amended return Conditional sales contract. Amended return   Whether an agreement is a conditional sales contract depends on the intent of the parties. Amended return Determine intent based on the provisions of the agreement and the facts and circumstances that exist when you make the agreement. Amended return No single test, or special combination of tests, always applies. Amended return However, in general, an agreement may be considered a conditional sales contract rather than a lease if any of the following is true. Amended return The agreement applies part of each payment toward an equity interest you will receive. Amended return You get title to the property after you make a stated amount of required payments. Amended return The amount you must pay to use the property for a short time is a large part of the amount you would pay to get title to the property. Amended return You pay much more than the current fair rental value of the property. Amended return You have an option to buy the property at a nominal price compared to the value of the property when you may exercise the option. Amended return Determine this value when you make the agreement. Amended return You have an option to buy the property at a nominal price compared to the total amount you have to pay under the agreement. Amended return The agreement designates part of the payments as interest, or that part is easy to recognize as interest. Amended return Leveraged leases. Amended return   Leveraged lease transactions may not be considered leases. Amended return Leveraged leases generally involve three parties: a lessor, a lessee, and a lender to the lessor. Amended return Usually the lease term covers a large part of the useful life of the leased property, and the lessee's payments to the lessor are enough to cover the lessor's payments to the lender. Amended return   If you plan to take part in what appears to be a leveraged lease, you may want to get an advance ruling. Amended return Revenue Procedure 2001-28 on page 1156 of Internal Revenue Bulletin 2001-19 contains the guidelines the IRS will use to determine if a leveraged lease is a lease for federal income tax purposes. Amended return Revenue Procedure 2001-29 on page 1160 of the same Internal Revenue Bulletin provides the information required to be furnished in a request for an advance ruling on a leveraged lease transaction. Amended return Internal Revenue Bulletin 2001-19 is available at www. Amended return irs. Amended return gov/pub/irs-irbs/irb01-19. Amended return pdf. Amended return   In general, Revenue Procedure 2001-28 provides that, for advance ruling purposes only, the IRS will consider the lessor in a leveraged lease transaction to be the owner of the property and the transaction to be a valid lease if all the factors in the revenue procedure are met, including the following. Amended return The lessor must maintain a minimum unconditional “at risk” equity investment in the property (at least 20% of the cost of the property) during the entire lease term. Amended return The lessee may not have a contractual right to buy the property from the lessor at less than fair market value when the right is exercised. Amended return The lessee may not invest in the property, except as provided by Revenue Procedure 2001-28. Amended return The lessee may not lend any money to the lessor to buy the property or guarantee the loan used by the lessor to buy the property. Amended return The lessor must show that it expects to receive a profit apart from the tax deductions, allowances, credits, and other tax attributes. Amended return   The IRS may charge you a user fee for issuing a tax ruling. Amended return For more information, see Revenue Procedure 2014-1 available at  www. Amended return irs. Amended return gov/irb/2014-1_IRB/ar05. Amended return html. Amended return Leveraged leases of limited-use property. Amended return   The IRS will not issue advance rulings on leveraged leases of so-called limited-use property. Amended return Limited-use property is property not expected to be either useful to or usable by a lessor at the end of the lease term except for continued leasing or transfer to a lessee. Amended return See Revenue Procedure 2001-28 for examples of limited-use property and property that is not limited-use property. Amended return Leases over $250,000. Amended return   Special rules are provided for certain leases of tangible property. Amended return The rules apply if the lease calls for total payments of more than $250,000 and any of the following apply. Amended return Rents increase during the lease. Amended return Rents decrease during the lease. Amended return Rents are deferred (rent is payable after the end of the calendar year following the calendar year in which the use occurs and the rent is allocated). Amended return Rents are prepaid (rent is payable before the end of the calendar year preceding the calendar year in which the use occurs and the rent is allocated). Amended return These rules do not apply if your lease specifies equal amounts of rent for each month in the lease term and all rent payments are due in the calendar year to which the rent relates (or in the preceding or following calendar year). Amended return   Generally, if the special rules apply, you must use an accrual method of accounting (and time value of money principles) for your rental expenses, regardless of your overall method of accounting. Amended return In addition, in certain cases in which the IRS has determined that a lease was designed to achieve tax avoidance, you must take rent and stated or imputed interest into account under a constant rental accrual method in which the rent is treated as accruing ratably over the entire lease term. Amended return For details, see section 467 of the Internal Revenue Code. Amended return Taxes on Leased Property If you lease business property, you can deduct as additional rent any taxes you have to pay to or for the lessor. Amended return When you can deduct these taxes as additional rent depends on your accounting method. Amended return Cash method. Amended return   If you use the cash method of accounting, you can deduct the taxes as additional rent only for the tax year in which you pay them. Amended return Accrual method. Amended return   If you use an accrual method of accounting, you can deduct taxes as additional rent for the tax year in which you can determine all the following. Amended return That you have a liability for taxes on the leased property. Amended return How much the liability is. Amended return That economic performance occurred. Amended return   The liability and amount of taxes are determined by state or local law and the lease agreement. Amended return Economic performance occurs as you use the property. Amended return Example 1. Amended return Oak Corporation is a calendar year taxpayer that uses an accrual method of accounting. Amended return Oak leases land for use in its business. Amended return Under state law, owners of real property become liable (incur a lien on the property) for real estate taxes for the year on January 1 of that year. Amended return However, they do not have to pay these taxes until July 1 of the next year (18 months later) when tax bills are issued. Amended return Under the terms of the lease, Oak becomes liable for the real estate taxes in the later year when the tax bills are issued. Amended return If the lease ends before the tax bill for a year is issued, Oak is not liable for the taxes for that year. Amended return Oak cannot deduct the real estate taxes as rent until the tax bill is issued. Amended return This is when Oak's liability under the lease becomes fixed. Amended return Example 2. Amended return The facts are the same as in Example 1 except that, according to the terms of the lease, Oak becomes liable for the real estate taxes when the owner of the property becomes liable for them. Amended return As a result, Oak will deduct the real estate taxes as rent on its tax return for the earlier year. Amended return This is the year in which Oak's liability under the lease becomes fixed. Amended return Cost of Getting a Lease You may either enter into a new lease with the lessor of the property or get an existing lease from another lessee. Amended return Very often when you get an existing lease from another lessee, you must pay the previous lessee money to get the lease, besides having to pay the rent on the lease. Amended return If you get an existing lease on property or equipment for your business, you generally must amortize any amount you pay to get that lease over the remaining term of the lease. Amended return For example, if you pay $10,000 to get a lease and there are 10 years remaining on the lease with no option to renew, you can deduct $1,000 each year. Amended return The cost of getting an existing lease of tangible property is not subject to the amortization rules for section 197 intangibles discussed in chapter 8. Amended return Option to renew. Amended return   The term of the lease for amortization includes all renewal options plus any other period for which you and the lessor reasonably expect the lease to be renewed. Amended return However, this applies only if less than 75% of the cost of getting the lease is for the term remaining on the purchase date (not including any period for which you may choose to renew, extend, or continue the lease). Amended return Allocate the lease cost to the original term and any option term based on the facts and circumstances. Amended return In some cases, it may be appropriate to make the allocation using a present value computation. Amended return For more information, see Regulations section 1. Amended return 178-1(b)(5). Amended return Example 1. Amended return You paid $10,000 to get a lease with 20 years remaining on it and two options to renew for 5 years each. Amended return Of this cost, you paid $7,000 for the original lease and $3,000 for the renewal options. Amended return Because $7,000 is less than 75% of the total $10,000 cost of the lease (or $7,500), you must amortize the $10,000 over 30 years. Amended return That is the remaining life of your present lease plus the periods for renewal. Amended return Example 2. Amended return The facts are the same as in Example 1, except that you paid $8,000 for the original lease and $2,000 for the renewal options. Amended return You can amortize the entire $10,000 over the 20-year remaining life of the original lease. Amended return The $8,000 cost of getting the original lease was not less than 75% of the total cost of the lease (or $7,500). Amended return Cost of a modification agreement. Amended return   You may have to pay an additional “rent” amount over part of the lease period to change certain provisions in your lease. Amended return You must capitalize these payments and amortize them over the remaining period of the lease. Amended return You cannot deduct the payments as additional rent, even if they are described as rent in the agreement. Amended return Example. Amended return You are a calendar year taxpayer and sign a 20-year lease to rent part of a building starting on January 1. Amended return However, before you occupy it, you decide that you really need less space. Amended return The lessor agrees to reduce your rent from $7,000 to $6,000 per year and to release the excess space from the original lease. Amended return In exchange, you agree to pay an additional rent amount of $3,000, payable in 60 monthly installments of $50 each. Amended return   You must capitalize the $3,000 and amortize it over the 20-year term of the lease. Amended return Your amortization deduction each year will be $150 ($3,000 ÷ 20). Amended return You cannot deduct the $600 (12 × $50) that you will pay during each of the first 5 years as rent. Amended return Commissions, bonuses, and fees. Amended return   Commissions, bonuses, fees, and other amounts you pay to get a lease on property you use in your business are capital costs. Amended return You must amortize these costs over the term of the lease. Amended return Loss on merchandise and fixtures. Amended return   If you sell at a loss merchandise and fixtures that you bought solely to get a lease, the loss is a cost of getting the lease. Amended return You must capitalize the loss and amortize it over the remaining term of the lease. Amended return Improvements by Lessee If you add buildings or make other permanent improvements to leased property, depreciate the cost of the improvements using the modified accelerated cost recovery system (MACRS). Amended return Depreciate the property over its appropriate recovery period. Amended return You cannot amortize the cost over the remaining term of the lease. Amended return If you do not keep the improvements when you end the lease, figure your gain or loss based on your adjusted basis in the improvements at that time. Amended return For more information, see the discussion of MACRS in Publication 946, How To Depreciate Property. Amended return Assignment of a lease. Amended return   If a long-term lessee who makes permanent improvements to land later assigns all lease rights to you for money and you pay the rent required by the lease, the amount you pay for the assignment is a capital investment. Amended return If the rental value of the leased land increased since the lease began, part of your capital investment is for that increase in the rental value. Amended return The rest is for your investment in the permanent improvements. Amended return   The part that is for the increased rental value of the land is a cost of getting a lease, and you amortize it over the remaining term of the lease. Amended return You can depreciate the part that is for your investment in the improvements over the recovery period of the property as discussed earlier, without regard to the lease term. Amended return Capitalizing Rent Expenses Under the uniform capitalization rules, you must capitalize the direct costs and part of the indirect costs for certain production or resale activities. Amended return Include these costs in the basis of property you produce or acquire for resale, rather than claiming them as a current deduction. Amended return You recover the costs through depreciation, amortization, or cost of goods sold when you use, sell, or otherwise dispose of the property. Amended return Indirect costs include amounts incurred for renting or leasing equipment, facilities, or land. Amended return Uniform capitalization rules. Amended return   You may be subject to the uniform capitalization rules if you do any of the following, unless the property is produced for your use other than in a business or an activity carried on for profit. Amended return Produce real property or tangible personal property. Amended return For this purpose, tangible personal property includes a film, sound recording, video tape, book, or similar property. Amended return Acquire property for resale. Amended return However, these rules do not apply to the following property. Amended return Personal property you acquire for resale if your average annual gross receipts are $10 million or less for the 3 prior tax years. Amended return Property you produce if you meet either of the following conditions. Amended return Your indirect costs of producing the property are $200,000 or less. Amended return You use the cash method of accounting and do not account for inventories. Amended return Example 1. Amended return You rent construction equipment to build a storage facility. Amended return If you are subject to the uniform capitalization rules, you must capitalize as part of the cost of the building the rent you paid for the equipment. Amended return You recover your cost by claiming a deduction for depreciation on the building. Amended return Example 2. Amended return You rent space in a facility to conduct your business of manufacturing tools. Amended return If you are subject to the uniform capitalization rules, you must include the rent you paid to occupy the facility in the cost of the tools you produce. Amended return More information. Amended return   For more information on these rules, see Uniform Capitalization Rules in Publication 538 and the regulations under Internal Revenue Code section 263A. Amended return Prev  Up  Next   Home   More Online Publications
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Answers to Common Questions

Is an overpayment credit different from a refund?
You get an overpayment credit when your tax payments exceed what you owe. You will receive the overpayment credit as a refund automatically. You also, however, can ask us to apply the credit as an advance payment towards your next year's taxes instead of sending it to you as a refund.

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Please contact us at the number listed on your notice for specific information concerning your tax return.

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Contact us with your information at the toll-free number listed on your notice. Please have your documentation (such as cancelled checks, amended return, etc.) ready when you call. Our representative will discuss the issue with you and give you further instructions.

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

How do I adjust my estimated tax payments?
You can adjust your estimated tax payments by completing a Form 1040-ES, Estimated Tax for Individuals. See Publication 505, Tax Withholding and Estimated Tax for more information.

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


Tips for next year

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

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Page Last Reviewed or Updated: 03-Mar-2014

The Amended Return

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