Independent personal services: income generally taxable in resident state, but may be taxed where fixed base or prolonged stay.

Independent personal services income of a resident is generally taxable only in the State of residence, except that the other State may tax income attributable to a fixed base regularly available there and income from activities performed in that State where the individual's period of presence meets the treaty's presence threshold; such taxation is limited to the portion attributable to the fixed base or to the activities performed in that other State.

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