Article 20 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 or benefits conferred by the United States 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 20 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 to teach at a university will not be exempt from U.S. tax on his salary. Under paragraph 5 of Article 1, however, a person who is not a U.S. citizen, and who visits the United States as a teacher 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 20.