$20,000
The US Model treaty's entertainer threshold. Real treaties vary (higher, lower, or none), so the payee's treaty decides. Where it applies it is a cliff, not an allowance: exceed it and the full amount is taxable, not just the excess.
The trap inside the trap: reimbursed expenses count toward the $20,000. The hotel bill can push the fee over the edge.
2006 US Model Technical Explanation, Article 16Full analysis →