Independent personal services: taxable in resident state unless fixed base or prolonged presence permits other state taxation.

Independent personal services of a resident are taxable only in the resident State except where the individual has a fixed base in the other State, in which case only income attributable to that fixed base may be taxed there, or where the individual's aggregated presence in the other State meets the treaty's duration threshold, in which case only income from activities performed in that State may be taxed there.

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