Rev. Rul. 83-11

1983-1 C.B. 367, 1983-2 I.R.B. 13.

                       Internal Revenue Service
                                 Revenue Ruling

                          NIH VISITING FELLOWS PROGRAM

                          Published: January 10, 1983

United States-Arab Republic of Egypt Income Tax Treaty 1982-1 C.B. 219, United States-Republic of Korea Income Tax Treaty 1979-2 C.B. 435, United States- Kingdom of Morocco Income Tax Treaty 1982-2 C.B. 405

(Also Part I, Section 894; 26 CFR 1.894-1.)

  NIH Visiting Fellows Program.  Amounts received by residents of Egypt, Korea, and Morocco from the National Institutes of Health under the Visiting Fellows Program are exempt from Federal income tax pursuant to the respective countries' tax conventions with the United States.  Rev. Rul. 80-98 supplemented.

  Rev. Rul. 80-98, 1980-1 C.B. 368, amplifying Rev. Rul. 80-36, 1980-1 C.B. 366, provides that amounts received from the National Institutes of Health (NIH) under the Visiting Fellows Program by residents of Belgium, Finland, France, Iceland, Japan, the Netherlands, Norway, Poland, Romania, and Trinidad and Tobago, are exempt from federal income tax under the respective countries' tax conventions with the United States.

  Rev. Rul. 80-98 examined Article 20 of the United States-Japan Income Tax Convention (Japanese Treaty) and concluded that provision of the Japanese Treaty exempts payments from NIH under the Visiting Fellows Program from federal income tax.  The respective income tax conventions of the other countries considered in Rev. Rul. 80-98, contain provisions that are identical or substantially similar to Article 20 of the Japanese Treaty.

  Article 23 of the United States-Arab Republic of Egypt Income Tax Treaty, Article 21 of the United States-Republic of Korea Income Tax Treaty, and Article 18 of the United States-Kingdom of Morocco Income Tax Treaty are substantially similar to Article 20 of the Japanese Treaty.  Therefore, amounts received by residents of Egypt, Korea, and Morocco from NIH under the Visiting Fellows Program are exempt from federal income tax pursuant to the tax treaties of those countries.

EFFECT ON OTHER REVENUE RULINGS

  Rev. Rul. 80-98, 1980-1 C.B. 368, is supplemented.

Rev. Rul. 83-11, 1983-1 C.B. 367, 1983-2 I.R.B. 13.