Dependent personal services: residence-based taxation with limited source-state taxation when presence, employer residence, and deductibility conditions align.

Remuneration from employment is taxable only in the individual's State of residence unless the employment is exercised in the other State, in which case that State may tax such remuneration; however, where the presence in the other State meets a short-term presence test, the employer is non-resident in that State, and the remuneration is not deductible against a permanent establishment or fixed base there, taxation is confined to the State of residence. Remuneration for employment aboard ships or aircraft in international traffic may be taxed in the operator's State of residence.

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