Capital gains allocation: source-state taxation for immovable property and PE-related assets, residence taxation for other property. Capital gains allocation permits taxation by the State where property is situated or used by a permanent establishment; immovable property situated in the source State may be taxed there; gains from movable property of a permanent establishment or fixed base, including their disposition, may be taxed in the State hosting that establishment or base; ships and aircraft used in international traffic are taxable only in the alienator's residence; share disposals may be taxed by the company's residence; other gains are taxable only in the alienator's residence.