For information call now:
Internal Revenue Service
Austin Service Center
P.O. Box 149342
Austin, TX 78714-9342
Thailand - Personal Services Income
Income that residents of Thailand receive for performing personal services as
independent contractors or as self-employed individuals (independent personal
services) in the United States during the tax year is exempt from U.S. income
tax if the residents:
- Are in the United States for no more than 89 days during the tax year, and
- Do not have a fixed base regularly available to them in the United States for
performing their services.
If they have a fixed base available in the United States, they are taxed only on
the income attributable to the fixed base.
This exemption does not apply if a resident of Thailand earns more than $10,000
for independent personal services and that income is paid by a U.S. resident or
borne by a permanent establishment or fixed base in the United States. Income
that residents of Thailand receive for 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 resident is in the United States for no more than 183 days in any 12-month
period beginning or ending in the tax year.
- 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 a fixed base
that the employer has in the United States.
These exemptions do not apply to directors� fees and similar payments received
by a resident of Thailand for services performed outside of Thailand as a member
of the board of directors of a company that is a resident of the United States.
These exemptions do not apply to income residents of Thailand receive for
performing services in the United States as entertainers (such as theater,
motion picture, radio, or television artists, or musicians) and athletes, if the
income is more than $100 a day or $3,000 for the tax year. Regardless of these
limits, income of Thai entertainers is exempt from U.S. tax if their visit to
the United States is substantially supported by public funds of Thailand or its
political subdivisions or local authorities.
The exemption does not apply to pay received by employees who are members of the
regular complement of a ship or aircraft operated in international traffic by a