Category: International Copyright 1998, The Tax Resource Group. All rights reserved. Telephone 800-578-3498. Internet: www.taxresourcegroup.com Taxpayer, a citizen of Austria, is a post-doctoral fellow doing medical research for a U.S. tax-exempt organization. Taxpayer has been advised that his wages for such research are exempt from U.S. tax under the U.S.-Austria tax treaty. This is incorrect advice. Various treaties to which the U.S. is a party provide such an exemption. For example, Article 20(1) of the U.S.-France treaty has such a provision. The U.S.- Autstria treaty, at Article XII, provides a similar exemption for teachers employed by U.S. educational organizations; however, there is no such provision for researchers. There are two treaties with Austria, the 1956 treaty and the 1996 treaty. The information set forth above regards the 1956 treaty which is currently in effect. The 1996 treaty, although ratified by the Senate, is not yet effective. That newer treaty does not even contain the exemption for teachers. |
