Independent personal services: taxable in resident state; other state may tax if fixed base exists or presence is prolonged. Income from independent personal services of a resident is taxable only in the resident State, except that income attributable to a fixed base regularly available in the other Contracting State may be taxed in that other State, and extended presence in the other State meeting the treaty threshold likewise permits taxation there.
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Provisions expressly mentioned in the judgment/order text.
Independent personal services: taxable in resident state; other state may tax if fixed base exists or presence is prolonged.
Income from independent personal services of a resident is taxable only in the resident State, except that income attributable to a fixed base regularly available in the other Contracting State may be taxed in that other State, and extended presence in the other State meeting the treaty threshold likewise permits taxation there.
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