Article 21 deals with visiting students, apprentices, and

business trainees.

An individual who is a resident of one of the Contracting States and who visits the other Contracting State for the purpose of full-time education or training, will not be taxed by that other State on amounts received from abroad to cover his expenses. The reference to "full-time" is not intended to exclude full-time students who, in accordance with their visas, may hold part-time jobs. The exemption, however, does not extend to any amounts received as compensation for services rendered, which are covered under Article 14 (Independent personal services) or Article 15 (Dependent personal services). The exemption also does not apply

                                                                  - **`45`**                                                                   

to any grant provided from within the host State, which is taxable in accordance with the domestic laws of that State.

Under paragraph 5(b) of Article 1 (Personal scope), Article 21 is an exception to the saving clause of paragraph 4 of Article 1 for individuals who are not citizens of the United States or green card holders but are residents of the United States under the physical presence tests of Code section 7701(b).