ARTICLE 17 — U.S. Income Tax Treaty

Artistes and Athletes

Notwithstanding the provisions of Articles 14 (Independent Personal Services) and 15 (Dependent Personal Services), income derived by a resident of a Contracting State as a public entertainer, such as a theatre, motion picture, radio, or television artiste, or a musician, or as an athlete, from his personal activities as such exercised in the other Contracting State, may be taxed in that other Contracting State, except where the amount of the gross receipts derived by such entertainer or athlete, not including expenses reimbursed to him or borne on his behalf, from such activities does not exceed 250 United States dollars or its equivalent in Barbadian currency per day, or 4,000 United States dollars or its equivalent in Barbadian currency in the taxable year.
Where income in respect of personal activities of an entertainer or athlete accrues not to that entertainer or athlete himself but to another person, that income may, notwithstanding the provisions of Articles 7 (Business Profits), 14 (Independent Personal Services), and 15 (Dependent Personal Services) be taxed in the Contracting State in which the activities of the entertainer or athlete are exercised, unless it is established that neither the entertainer or athlete nor persons related thereto participate directly or indirectly in the profits of that other person in any manner, including the receipt of deferred remuneration, bonuses, fees, dividends, partnership distributions, or other distributions.
The provisions of paragraphs 1 and 2 shall not apply

a) to income derived from activities performed in a Contracting State by entertainers or athletes if the visit to that Contracting State is substantially supported by public funds of the other Contracting State, including any political subdivision, local authority or statutory body thereof;

b) to a nonprofit organization no part of the income of which was payable to, or otherwise inures to the benefit of, any private proprietor, member or shareholder thereof, or other individual; or

c) to an entertainer or athlete in respect of services provided to an organization referred to in subparagraph b).