Dependent personal services taxation: residence-based rule allowing source-state tax when employment is exercised abroad subject to presence and employer/PE tests.

Taxation of dependent personal services is residence-based: remuneration of a resident is taxable only in the resident State unless the employment is exercised in the other State, in which case that State may tax the remuneration. An exception prevents source-state taxation where the employee's presence in the other State is below an aggregate threshold, the remuneration is paid by an employer not resident in the other State, and the remuneration is not borne by a permanent establishment or fixed base of the employer in the other State; remuneration for work on ships or aircraft in international traffic may be taxed where the enterprise's place of effective management is located.

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