Independent personal services: residence-state taxation unless fixed base or substantial presence permits source-state taxation of attributable income.

Income from independent personal services of a resident is taxable only in the State of residence unless the resident has a fixed base in the other State, in which case only income attributable to that fixed base may be taxed there, or unless the resident's presence in the other State exceeds the treaty's presence threshold, in which case only income attributable to activities performed there may be taxed by that State.

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