Independent personal services: taxable in residence state unless fixed base abroad or prolonged stay permits source-state taxation.

Income from independent personal services by a resident is taxable only in the residence State except where the individual has a fixed base in the other State-then only income attributable to that fixed base may be taxed there-or where the individual's prolonged presence in the other State triggers taxation there, in which case only income from activities performed in that State may be taxed. "Professional services" includes independent scientific, literary, artistic, educational activities and listed professions.

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