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were a resident of Belgium prior to coming to the US.
Since you meet those requirements, the first $2000 of
your earned income for 2002 and 2003 is exempt from US
income tax, as shown above.
Petitioner timely filed a petition with this Court.
Discussion
Petitioner argues that all of his 2002 and 2003 wage income
from his residencies at Fairview Hospital and Maimonides Medical
Center is exempt from taxation pursuant to article 20 of the
treaty. Articles 20 and 21 of the treaty provide:
Article 20
TEACHERS
(1) An individual who is a resident of one of the
Contracting States at the time he becomes temporarily
present in the other Contracting State and who, at the
invitation of the Government of that other Contracting
State or of a university or other recognized
educational institution in that other Contracting State
is temporarily present in that other Contracting State
for the primary purpose of teaching or engaging in
research, or both, at a university or other recognized
educational institution shall be exempt from tax by
that other Contracting State on his income from
personal services for teaching or research at such
university or educational institution, for a period not
exceeding 2 years from the date of his arrival in that
other Contracting State.
(2) This article shall not apply to income from
research if such research is undertaken not in the
public interest but primarily for the private benefit
of a specific person or persons.
Article 21
STUDENTS AND TEACHERS
(1)(a) An individual who is a resident of one of
the Contracting States at the time he becomes
temporarily present in the other Contracting State and
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