Can someone help me understand the verbiage in the US-UK tax treaty with regards to article 20 for students? (https://www.treasury.gov/resource-center/tax-policy/treaties/Documents/uktreaty.pdf)
"Payments received by a student or business apprentice who is, or was immediately before visiting a contracting State, a resident of the other Contracting State, and who is present in the first-mentioned State for the purpose of his full-time education at a university, college or other recognized educational institution of a similar nature, or for his full-time training, shall not be taxed in that State, provided that such payments arise outside that State, and are for the purpose of his maintenance, education or training. The exemption from tax provided by this article shall apply to a business apprentice only for a period of time not exceeding one year from the date he first arrives in the first-mentioned Contracting State for the purpose of his training."
I arrived in the US from the UK in August 2019 to enter grad school (full-time) on an F1 visa. As part of my course, I had to undertake an internship in the US (on CPT), which was paid, and then post graduation, since May 2020 I have been working full time in the US on OPT (also paid). Are either the internship or job exempt from US taxes since it is considered practical training linked to my education?
Or is the treaty suggesting that if I received money from outside the US (e.g. from the UK) during my full time studies, which was for the sole purposes of education/maintenance/training, only that would be exempt from US taxation?
