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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)
are:
(i) Gifts from abroad for the purpose of his
maintenance, education, study, research, or
training;
(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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