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1ARTICLE 1 · Personal Scope2ARTICLE 2 · Taxes Covered3ARTICLE 3 · General Definitions4ARTICLE 4 · Resident5ARTICLE 5 · Permanent Establishment6ARTICLE 6 · Income From Real Property7ARTICLE 7 · Business Profits8ARTICLE 8 · Shipping and Air Transport9ARTICLE 9 · Associated Enterprises10ARTICLE 10 · Dividends11ARTICLE 11 · Interest12ARTICLE 12 · Royalties13ARTICLE 13 · Capital Gains14ARTICLE 14 · Independent Personal Services15ARTICLE 15 · Dependent Personal Services16ARTICLE 16 · Directors’ Fees17ARTICLE 17 · Artistes and Sportsmen18ARTICLE 18 · Pensions19ARTICLE 19 · Public Remuneration20ARTICLE 20 · Teachers and Researchers21ARTICLE 21 · Students and Trainees22ARTICLE 22 · Other Income23ARTICLE 23 · Capital24ARTICLE 24 · Relief From Double Taxation25ARTICLE 25 · Non-Discrimination26ARTICLE 26 · Mutual Agreement Procedure27ARTICLE 27 · Exchange of Information28ARTICLE 28 · Assistance in Collection29ARTICLE 29 · Miscellaneous Provisions30ARTICLE 30 · Limitation on Benefits of the Convention31ARTICLE 31 · Diplomatic and Consular Officers32ARTICLE 32 · Provisions for Implementation33ARTICLE 33 · Entry Into Force34ARTICLE 34 · TerminationPublisher front matter and preamble · Publisher front matter and preambleSigned closing and authentic-language clause · Signed closing and authentic-language clauseNotes of exchange · Notes of exchange

34 articles · English

Source & edition
Country pairs / France / United States

France / United States · US FR 1994 CONVENTION

ARTICLE 17 · Artistes and Sportsmen

English · original source edition

Unreviewed · applicability unverified
Original & source
§ PDF page 19
ARTICLE 17 Artistes and Sportsmen
§ PDF page 19
1. Notwithstanding the provisions of Articles 14 (Independent Personal Services) and 15 (Dependent Personal Services), income derived by a resident of a Contracting State as an entertainer, such as a theater, motion picture, radio, or television artiste or a musician, or as a sportsman, from his personal activities as such exercised in the other Contracting State, may be taxed in that other State. However, the provisions of this paragraph shall not apply where the amount of the gross receipts derived by such entertainer or sportsman from such activities,
§ PDF page 20
including expenses reimbursed to him or borne on his behalf, does not exceed 10,000 United States dollars or its equivalent in French francs for the taxable period concerned.
§ PDF page 20
2. Where income in respect of personal activities exercised by an entertainer or sportsman in his capacity as such accrues not to the entertainer or sportsman but to another person, whether or not a resident of a Contracting State, that income may, notwithstanding the provisions of Articles 7 (Business Profits), 14 (Independent Personal Services), and 15 (Dependent Personal Services), be taxed in the Contracting State in which the activities of the entertainer or sportsman are exercised. However, the provisions of this paragraph shall not apply where it is established that neither the entertainer or sportsman nor persons related to him derive from that other person any income, directly or indirectly, in respect of such activities that in the aggregate exceeds the amount specified in paragraph 1 for the taxable period concerned.
§ PDF page 20
3. The provisions of paragraphs 1 and 2 shall not apply to income derived by a resident of a Contracting State as an entertainer or a sportsman from his personal activities as such exercised in the other Contracting State if the visit to that other State is principally supported, directly or indirectly, by public funds of the first-mentioned State or a political subdivision (in the case of the United States) or local authority thereof. In such case the income shall be taxable only in the first-mentioned State.
Citation to select or copy

France / United States; IRS/Treasury official source publication; edition us-fr-1994-convention; article 17; English; unreviewed source text, current applicability unverified; /editions/us-fr-1994-convention/en/articles/article-17/

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Source & edition

IRS/Treasury official source publication

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    SHA-256 909c4a1cf58a5138d7a443ac316c7815175960915f6d7ff501865ffc5cae957a

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Retained native extraction Article provenance

Edition
us-fr-1994-convention
Text available here
English
Review
Unreviewed; qualified human review pending
Current applicability
Not verified
Signature
1994-08-31
Currentness verified
False

Languages recorded in source metadata: English, Français. This is not a promise of available text or a translation.

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Private review only. Original source edition, not current-law certification.

Full text: native/us-fr-1994-convention/layout.txt; physical page ledger: native/us-fr-1994-convention/quality.json

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