Tax Treaty Case Law around the Globe 2018
1. Aufl. 2019
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S. 231Chapter 21 United States: Payments to Graduate Students
Yariv Brauner
21.1. Introduction
2017 provided an opportunity to review the tax treatment of payments to foreign graduate students in the United States. The first case in this chapter, Pei Fang Guo, reviews the taxation of unemployment compensation paid to a postgraduate fellow. The second case, Joanna Klubo-Gwiezdzinska, reviews the taxation of payments to a research fellow pursuant to a treaty with a “Students” provision. The third case, Zhongxia Ye, concerns the interpretation of a “Teachers, Professors, and Researchers” treaty article with respect to a tenure-track professor. Finally, Evgeny Kiselev reviews the taxation of research funds paid to a graduate student. This final case was actually decided in the early part of 2018, but I found it appropriate for inclusion.
21.2. Pei Fang Guo
21.2.1. Facts of the case
The taxpayer had been a Canadian citizen since 2003. In October 2010 she moved to Ohio to take up a position as a post-doctoral fellow at the University of Cincinnati (UC). She was employed there from October 2010 to November 2011 on a nonimmigrant professional visa. Her contract with UC expired on . Af...