Taxation of other income favors the resident State, but income linked to permanent establishments or gambling may be taxed at source. Items of income of a resident not addressed by other provisions are taxable only in the State of residence, except where the resident carries on business through a permanent establishment or performs independent personal services from a fixed base in the other State and the income is effectively connected with that permanent establishment or fixed base, in which case the rules on business profits or independent personal services apply; income from lotteries and gambling sourced in the other State may be taxed in that source State.