Article 15. TEACHERS

The existing Convention provides that teachers who are residents of one

of the Contracting States and who are temporarily present in the other Con­ tracting State for a period not exceed­ ing 2 years for the purpose of teaching at an educational institution are ex­ empt from taxation in such other Contracting State on remuneration re­ ceived for such teaching.

The proposed Convention continues with minor modification the 2-year exemption period for visiting teachers. This exemption applies to an individ­ ual who is a resident of and residing in one of the Contracting States at the time he is invited by the other Con­ tracting State or by a recognized edu­ cational institution of the other Con­ tracting State to teach or do research in the other Contracting State and temporarily comes to such other Con­ tracting State primarily in order to engage in such teaching or research. Since the period of temporary visit may be of such duration that an indi­ vidual may lose his status as a resident of the State of which he was a resi­ dent, the article makes clear that the individual need only be a resident of such State at the beginning of his visit. The exemption is for the indi­ vidual’s income from personal service for teaching or research at such recog­ nized educational institution. For pur­ poses of the United States, the term “recognized” will be construed to mean accredited. However, the ex­ emption does not apply to income from research undertaken not in the public interest but primarily for the benefit of a specific person or persons. If the individual’s visit exceeds a pe­ riod of 2 years from the date of his arrival, the exemption applies to the income received by the individual be­ fore the expiration of such 2-year pe­ riod.