The United States has income tax treaties with over 60 countries, all of which provide exemption from tax for residents of the treaty country who come to the United States for the primary purpose of their education or training. U.S. treaty policy as embodied in Article 20 of the U.S. Model Treaty is to provide tax exemption for payments for full-time education and training that arise outside the United States. Over one-half of the U.S. treaties provide for such a limited benefit for students and trainees including Article 21(1) of the treaty with India. However, the treaty with India provides an additional benefit for students and business apprentices.

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