ARTICLE 22
U.S. Income Tax Treaty — Japan Technical Explanation - 1971 · 2026-10-03 edition · updated 2026-10-04 · United States
Rules Applicable to Personal Income Articles
This article extends the benefits of the personal services income articles (Article 17 through 21) to reimbursed travel expenses. However, such reimbursed expenses will not be taken into account in computing the maximum amount of exemptions. Maximum amounts are specified in paragraph (2) of Article 17 (relating to income from independent personal services of a public entertainer) and in Article 20 (relating to students and trainees). If an individual qualifies for the benefits of more than one of the provisions of Article 17 through 21, he may choose the provision most favorable to him, but he may not claim the benefits of more than one article with respect to the same income in any one taxable year.
As noted above, if an individual qualifies for the benefits provided under Article 19 (relating to teachers and researchers) or paragraph (1) of Article 20 (relating to students and trainees), such benefits will extend only for that period of time which is reasonably and customarily required to effectuate the purpose of the visit. If an individual qualifies successively for the benefits provided under both of such provisions, such benefits will not extend, in any case, for more than a total of 5 taxable years from the date of his arrival.
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