- 5 - petitioner’s earned income for 2002 and 2003 is exempt from U.S. income tax. The supplement also explains the reason for respondent’s determination regarding petitioner’s claim that all of his wages were exempt from income tax. In the supplement, respondent states: Article 20 of the treaty between the United States and Belgium allows residents of Belgium to exempt from United States taxation income received for the primary purpose of teaching or engaging in research, or both, from a university or other recognized educational institution for a period of 2 years from the date of arrival if invited by the United States Government or of a university or other recognized educational institution. You did not show that you were invited to work for the primary purpose of teaching or research. You stated on your 2002 income tax return that your occupation was ‘Anesthesia Trainee’, and that your purpose for coming to the United States was for ‘Training (Medical Specialty) [sic]. On May 30, 2003 we received your signed response to our request for additional information regarding your 2002 claim for treaty benefits. Your response included a work phone number at Maimonides Medical Center for Resident Training, which shows that you were still in residency training as of that date. That shows that you were not in the United States for the primary purpose of teaching or research in 2003. The certificates you provided from Fairview Hospital and Maimonides Medical Center show that you were in the United States as a resident in Internal Medicine and Anesthesiology, which means your primary purpose was residency, not teaching or research. Based on the above facts, the income you received is not exempt from U.S. income tax under Article 20 of the income tax treaty between Belgium and the United States. Article 21 of the treaty allows you to exempt up to $2000 of earned income per year for the first five tax years you are present in the US for training if youPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 NextLast modified: November 10, 2007