Dependent personal services tax allocation: remuneration taxed in resident state unless employment is exercised abroad, limited-presence exception applies.

Remuneration of a resident is taxable only in the resident State unless the employment is exercised in the other State, but where the individual's presence in the other State is limited, the employer is non-resident there, and the pay is not borne by a permanent establishment or fixed base in that State, taxation remains with the resident State; remuneration for employment aboard an internationally operated ship or aircraft is taxable only in the enterprise's State.

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