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of <h1>Income from entertainers or athletes abroad taxable where earned, unless publicly funded; then taxed in resident state.</h1> Income derived by a resident entertainer or sportsperson from activities in another Contracting State may be taxed in that other State, overriding certain other provisions. If the income accrues to another person instead of the entertainer or sportsperson, it remains taxable in the State where the activities occur. However, if the activities are significantly supported by public funds from either State or their subdivisions, the income is taxable only in the entertainer's or sportsperson's resident State.
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