Dependent personal services: source-state taxing rights limited where employment is exercised, subject to presence, employer residency and deductibility. Dependent personal services income is taxable primarily in the employee's State of residence unless the employment is exercised in the other Contracting State, in which case the other State may tax remuneration derived therefrom. However, such source-state taxation does not apply if the employee's presence in the other State does not exceed an aggregate 183 days in the fiscal year, the remuneration is paid by or on behalf of an employer not resident in that State, and the remuneration is not deductible for profit taxation there. Remuneration for employment aboard a ship or aircraft in international traffic may be taxed in the State of residence of the person deriving the operation's profits.