Taxation of independent personal services: residence-state taxation, but other state may tax income tied to fixed base or prolonged presence. Income of a resident individual from professional or similar independent activities is taxable only in the State of residence, except that the other Contracting State may tax income attributable to a fixed base there or income from activities performed there if the individual's stay in that State meets the treaty's prolonged-presence threshold. 'Professional services' is defined to include independent scientific, literary, artistic, educational or teaching activities and specifically names physicians, lawyers, engineers, architects, surgeons, dentists and accountants.
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Provisions expressly mentioned in the judgment/order text.
Taxation of independent personal services: residence-state taxation, but other state may tax income tied to fixed base or prolonged presence.
Income of a resident individual from professional or similar independent activities is taxable only in the State of residence, except that the other Contracting State may tax income attributable to a fixed base there or income from activities performed there if the individual's stay in that State meets the treaty's prolonged-presence threshold. "Professional services" is defined to include independent scientific, literary, artistic, educational or teaching activities and specifically names physicians, lawyers, engineers, architects, surgeons, dentists and accountants.
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