Article 19 is not subject — U.S. Income Tax Treaty

Scope), by reason of the exception in subparagraph 5 of Article 1, with respect to benefits conferred by Japan under Article 19 or benefits conferred by the United States under Article 19 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 19 is subject to the saving clause with respect to benefits conferred by the United States to citizens and permanent residents of the United States. Accordingly, a U.S. citizen who is a resident of Japan and who visits the United States for the purpose of his education will not be exempt from U.S. tax on remittances from abroad that otherwise constitute U.S. taxable income. Under paragraph

5 of Article 1, however, a Japanese resident who is not a U.S. citizen, and who visits the United States for the purpose of his education and remains long enough to become a resident under U.S. law, but does not become a permanent resident ( i.e., does not acquire a green card), will be entitled to the benefits of Article 19.