ARTICLE 17. INCOME FROM PERSONAL — U.S. Income Tax Treaty

This Article provides that an individual resident of one State Is exempt from tax by the other State with respect to income from personal services performed in such other State if such person is physically present there for not more than 183 days, in the aggregate, during the taxable year and either (1) such individual is an employee of a resident of a State other than the State of source (or an em ployee of a permanent establishment of a resident of the State of source located outside such State) and the amount of such income is not deducted in computing the profits of a permanent establishment of the State of source; or (2) such income does not exceed $3,000 or Its equivalent In Trinidad and Tobago dollars.

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Thus, if such individual's employment income does not exceed $3,000 or its equivalent in Trinidad and Tobago dollars, such individual need only satisfy the physical presence limitation in order to qualify for the exemption.

Compensation for services performed as a member of the regular complement aboard ships or aircraft operated in international traffic by a resident of one State (and in the case of the United States, registered in the United States) are exempt from tax in the other State. This exception does not limit a State's right to tax its own citizens or residents.

"Income from personal services" includes income from the performance of per sonal services in an independent capacity and "employment Income." Employment income includes income from services performed by officers and directors of cor porations. However, income from personal services performed by partners is treated as income from the performance of services in an independent capacity.

The exemption applicable to personal service income is limited in the case of (1) public entertainers, such as musicians, actors, or professional athletes, and (2) any person providing the services of a person described in (1) even though such income may otherwise be considered exempt under some other provision of this Convention. These persons are taxable if their income from such activities exceeds $100 (or its equivalent in Trinidad and Tobago dollars) for each day the individual is present for purposes of performing within the State.