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of <h1>Entertainers' and athletes' foreign income taxable in activity state unless part of government-backed cultural exchange program.</h1> Income derived by entertainers and athletes from personal activities in a foreign Contracting State may be taxed in that state, overriding certain provisions related to personal services. If the income accrues to another person, it may still be taxed in the state where the activities occur. However, if the activities are part of a government-supported cultural exchange program, the income is taxable only in the entertainer or athlete's resident state. This applies whether the income accrues directly to the entertainer or athlete or to another person, provided the program is certified and supported by public funds or qualifying organizations.
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