ARTICLE 17

Income from Personal Services

1. An individual who is a resident of one of the Contracting States shall be exempt from tax by the other Contracting State with respect to income from personal services performed within that other Contracting State if he is present within that other Contracting State for a period or periods not exceeding in the aggregate 183 days during the taxable year, and either(a) (i) Such individual is an employee of a resident of a State other than that other Contracting State (or of a permanent establishment of a resident of that other Contracting State located outside that Contracting State), and

(ii) Such income is not deducted as such in computing the profits of a permanent establishment in that other Contracting State which are subject to tax in that Contracting State; or (b) The gross amount of such income does not exceed $3,000 or its equivalent in Trinidad and Tobago dollars.

2. Compensation received by an individual for personal services performed aboard ships or aircraft operated in international traffic by a resident of a Contracting State (and, in the case of the United States, registered in the United States) shall, subject to paragraph 3 of Article 3 (General Rules of Taxation), be exempt from tax by the other Contracting State, if the services are performed by a member of the regular complement of the ship or aircraft.

3. For purposes of paragraph 1, the term “income from personal services” includes employment income and income earned by an individual from the performance of personal

services in an independent capacity. The term "employment income" includes income from services performed by officers and directors of corporations, but does not include income from personal services performed by partners, which shall be treated as income from the performance of services in an independent capacity.

4. The provisions of paragraph 1 shall not apply in the case of income from personal services derived by

(a) A public entertainer, theater, motion picture or television artist, musician, or athlete, if the gross amount of such income exceeds $100 or its equivalent in Trinidad and Tobago dollars for each day such person is present for the purpose of performing in the Contracting State in which such services are performed; or

(b) Any person providing the services of the persons described in subparagraph (a), even though such income may otherwise be considered to be exempt under some other provision of this Convention, if the gross amount of such income of such person for providing such services exceeds $100 or its equivalent in Trinidad and Tobago dollars for each day that the individuals whose services are being provided (or any one of such individuals) are present for the purpose of performing in the Contracting State in which such services are performed.