Article 7 (Business Profits). The individual musicians would

   be taxable there, but only if their annual remuneration
   received for the performance in the host state exceeded the

threshold of 20,000 U.S. dollars. In the case of a monthly paid salary only that portion of the monthly pay may become taxable which is allocable to the days physically spent in the host country. If, however, a performance-related global

   payment is made, then the whole amount shall be taken into
   consideration without any deduction for periods of
   preparation spent outside the host State.

   The reference in the Memorandum of Understanding to a
performance-related global payment refers to a payment consisting

of compensation for performance and preparation where each such

activity is not separately compensated under the artiste's or

athlete's contract. Therefore, where a payment is for a

performance in a host State, including preparation done outside

the host State, the whole amount may be taken into account by the

host State with no deduction for periods of preparation spent
outside the host State.

   The 1956 Convention contains no special rules for the

taxation of the income of entertainers and athletes. Such income was subject to the general rules for the taxation of personal

service income, which imposed, among others, a $3,000 threshold
for taxation of personal services income.

   This Article is subject to the provisions of the saving

clause of paragraph 4 of Article 1 (Personal Scope). Thus, if an

entertainer or athlete who is resident in Austria is also a
citizen of the United States, the United States may tax all of

his or her income from performances in the United States without

regard to the provisions of this Article, subject, however, to
the special foreign tax credit provisions for U.S. citizens who
are residents of Austria found in paragraph 2 of Article 22
(Relief from Double Taxation). In addition, benefits of this

Article are subject to the provisions of Article 16 (Limitation

on Benefits).