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 Portugal - Personal Services Income

Income that residents of Portugal 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 the residents:
- Are in the United States for no more than 182 days in any 12-month period, and
- Do not have a fixed base regularly available to them in the United States for performing the activities.

If they have a fixed base available, they are taxed only on the income attributable to the fixed base.

Income that residents of Portugal receive for employment in the United States (dependent personal services) is exempt from U.S. income tax if the following three requirements are met.

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

Income received by a resident of Portugal for employment as a member of the regular complement of a ship or aircraft operated in international traffic is exempt from U.S. tax.

These exemptions do not apply to income residents of Portugal receive as public entertainers (such as theater, motion picture, radio, or television artists, or musicians) or athletes if that income, including reimbursed expenses, is more than $10,000. The income of Portuguese entertainers and athletes is exempt from U.S. tax if their visit to the United States is substantially supported by public funds of Portugal or its political or administrative subdivisions.

These exemptions do not apply to directors� fees and similar payments received by a resident of Portugal for services performed outside of Portugal as a member of the board of directors of a company that is a resident of the United States.

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