Mehrdad Hamzeye Langroudi - Page 8

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               who is temporarily present in that other Contracting                   
               State for the primary purpose of:                                      
                         (i) Studying at a university or other                        
                    recognized educational institution in that other                  
                    Contracting State, or                                             
                         (ii) Securing training required to qualify                   
                    him to practice a profession or professional                      
                    specialty, or                                                     
                         (iii) Studying or doing research as a recipient of           
                    a grant, allowance, or award from a governmental,                 
                    religious, charitable, scientific, literary, or                   
                    educational organization,                                         
               shall be exempt from tax by that other Contracting                     
               State with respect to amounts described in subparagraph                
               (b) for a period not exceeding 5 taxable years from the                
               date of his arrival in that other Contracting State.                   
                    (b) The amounts referred to in subparagraph (a)                   
                         (i) Gifts from abroad for the purpose of his                 
                    maintenance, education, study, research, or                       
                         (ii) The grant, allowance, or award; and                     
                         (iii) Income from personal services performed                
                    in that other Contracting State in an amount not                  
                    in excess of 2,000 United States dollars or its                   
                    equivalent in Belgian francs for any taxable year.                
          Convention for the Avoidance of Double Taxation and the                     
          Prevention of Fiscal Evasion with Respect to Taxes on Income,               
          U.S.-Belg., arts. 20-21, July 9, 1970, 23 U.S.T. 2687.                      
               In order to meet the requirements of article 20 of the                 
          treaty, petitioner would have to be “temporarily present in * * *           
          [the U.S.] for the primary purpose of teaching or engaging in               
          research”.  Petitioner argues that he accepted his residencies              

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