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 Italy - Personal Services Income

Income that residents of Italy receive for 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 Italy 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 following requirements are met.

- The residents are in the United States for no more than 183 days during the tax year.
- The income is paid by, or on behalf of, an employer who is not a resident of the United States.
- The income is not borne by a permanent establishment or a fixed base that the employer has in the United States.

These exemptions do not apply to directors´┐Ż fees and similar payments received by a resident of Italy for services performed in the United States as a member of the board of directors of a company that is a U.S. resident.

Pay received for employment regularly exercised aboard a ship or aircraft operated by a U.S. enterprise is subject to U.S. tax.

These exemptions do not apply to income residents of Italy receive as public entertainers (such as theater, motion picture, radio, or television artists, musicians, or athletes) if they are present in the United States for more than 90 days during the tax year or their gross receipts, including reimbursed expenses, are more than $20,000 during the tax year for their entertainment activities in the United States.

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