Resident

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..... able to tax in that State in respect only of income from sources in that State or capital situated therein. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his status shall be determined as follows (a) he shall be deemed to be a resident of the State in which he has a permanent home available to him, if he has a permanent home ava .....

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