TaxTMI 
TaxTMI 
Resident
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....ture, and also includes that Contracting State and any political subdivision or local authority thereof. This term does not include any person whose tax is determined in that Contracting State on a fixed-fee, "forfait" or similar basis, or who is liable to tax in respect only of income from sources in that Contracting State or of profits attributable to a permanent establishment in that Contractin....
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.... States, he shall be deemed to be a resident only of the Contracting State with which his personal and economic relations are closer (center of vital interests); (b) if the Contracting State in which he has his center of vital interests cannot be determined, or if he does not have a permanent home available to him in either Contracting State, he shall be deemed to be a resident only of the Contr....