Article 18 is not subject to the saving clause of subparagraph 4(a) of Article 1 (General

Scope), by reason of the exception in subparagraph 5 of Article 1, with respect to benefits conferred by Japan under Article 18 or benefits conferred by the United States under Article 18 to a resident of the United States who is neither a citizen of United States, nor a person who has been admitted for permanent residence there ( i.e., a “green card” holder). Article 18 is subject to the saving clause with respect to benefits conferred by the United States to citizens and permanent residents of the United States. Thus, for example, a resident of Japan who, in the course of rendering services to the government of Japan, becomes a resident of the United States (but not a permanent resident) would be entitled to the exemption from taxation by the Contracting State of source provided by paragraph 1. In addition, an individual who receives a pension paid by the Government of Japan in respect of services rendered to that Government is taxable on that pension only in Japan unless the individual is a U.S. citizen or acquires a U.S. green card.

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