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 France - Personal Services Income

Income that residents of  France receive for performing personal services as independent contractors or self-employed individuals (independent personal services) in the United States is exempt from U.S. income tax if they do not have a fixed base regularly available to them in the United States for performing the services. If they have a fixed base available in the United States, they are taxed on the income attributable to the fixed base.

Income that residents of Finland receive for labor or personal services performed in the United States as employees (dependent personal services) is exempt from U.S. income tax if the residents meet three requirements.

- The resident is present in the United States for no more than 183 days in any 12-month period.
- Their income is paid by, or on behalf of, an employer who is not a resident of the United States.
- Their income is not borne by a permanent establishment,  fixed base, or trade or or business that the employer has in the United States.

The exemption does not apply to pay received by a resident of  France who is an employee and member of the regular complement of a ship or peraircraft operated in international traffic by a resident of the United States.

These exemptions do not apply to income  residents of Finland receive as public entertainers (such as theater, motion picture radio, or television artists, or musicians), or sportsmen from France who earn more than $10,000 in gross receipts, including reimbursed expenses, from their entertainment activities in the United States during the tax year. Regardless of these limits, income of French entertainers or sportsmen is exempt from U.S. tax if their visit is principally supported by public funds of France.

These exemptions do not apply to directors´┐Ż fees and similar payments received by a resident of France as a member of the board of directors of a company that is a resident of the United States.

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