Independent personal services: residency-based taxation, with exceptions for a fixed base or prolonged presence enabling source-state taxation.

Income from independent personal services is taxable only in the individual's State of residence except where the individual has a fixed base in the other State, in which case only income attributable to that fixed base may be taxed there, or where the individual's presence in the other State meets the treaty's threshold for prolonged presence, in which case only income from activities performed there may be taxed by that State. "Professional services" are defined to include specified independent professions and activities.

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