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 Ukraine - Personal Services Income

Income that residents of Ukraine 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 income is not attributable to a fixed base in the United States that is regularly available for performing the services. Income that residents of Ukraine 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 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� fees and similar payments received by a resident of Ukraine for services performed outside of Ukraine as a member of the board of directors of a company that is a resident of the United States.

These exemptions generally do not apply to income received as a public entertainer (such as a theater, motion picture, radio, or television artist, musician, or athlete). However, income of Ukrainian entertainers and sportsmen is exempt from U.S. income tax if their visit to the United States is substantially supported by public funds of Ukraine, its political subdivisions, or local authorities, or the visit is made pursuant to a specific arrangement between the United States and Ukraine.

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

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