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of <h1>Immovable property taxed where located; movable property taxed by business base; ships taxed by management location.</h1> Capital represented by immovable property owned by a resident of one State but situated in the other State may be taxed in the State where the property is located. Movable property forming part of a business's permanent establishment or a fixed base for independent personal services in the other State may also be taxed there. Ships and aircraft operated in international traffic and related movable property are taxable only in the State where the enterprise's effective management is located. All other capital elements of a resident are taxable only in the resident's State.
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