[Code of Federal Regulations]
[Title 26, Volume 18, Parts 500 to 599]
[Revised as of April 1, 2000]
From the U.S. Government Printing Office via GPO Access
[CITE: 26CFR521.112]

[Page 151-152]
 
                       TITLE 26--INTERNAL REVENUE
 
     CHAPTER 1--INTERNAL REVENUE SERVICE DEPARTMENT OF THE TREASURY 
                               (Continued)
 
PART 521--DENMARK--Table of Contents
 
                       Subpart--General Income Tax
 
Sec. 521.112  Compensation for labor or personal services.

    Article XI of the convention adopts the principle that compensation 
for labor or personal services, including the practice of the liberal 
professions, is subject to tax only in the contracting State in which 
such services are rendered. Hence, in general, such compensation derived 
by a nonresident alien individual residing in Denmark for services 
rendered in the United States is subject to Federal income tax. Under 
Article XI of the convention this general rule is subject to the 
following exceptions:
    (a) Where such individual is temporarily present in the United 
States for a period or periods not exceeding a total of 90 days during 
the taxable year, compensation received for labor or personal services 
within the United States during such year is exempt from Federal income 
tax provided such compensation does not exceed $3,000 in the aggregate.
    (b) Where such individual is temporarily present in the United 
States for a period or periods not exceeding a total of 180 days during 
the taxable year, compensation for labor or personal services within the 
United States during such year is exempt from Federal income tax 
provided such compensation is received for services performed as a 
worker or employee of, or under contract with, a resident or corporation 
of Denmark (even though such resident or corporation is engaged in trade 
or business in the United

[[Page 152]]

States) which resident or corporation actually bears the expense of such 
compensation and is not reimbursed therefor by another person.
    As to the source of compensation for labor or personal services, see 
section 119(a)(3) of the Internal Revenue Code.