ARTICLE 3

General Rules of Taxation

1. A resident of one of the Contracting States shall be taxable by the other Contracting State only on income derived from sources within that other Contracting State. For this purpose the rules set forth in Article 5 (Source of Income) shall be applied to determine the source of income.

2. A resident of one of the Contracting States may be taxed by the other Contracting State on income taxable under paragraph 1 in accordance with the limitations set forth in this Convention. Any income to which the provisions of this Convention are not expressly applicable shall be taxable by each of the Contracting States in accordance with its own law. The provisions of this Convention shall not be construed to restrict in any manner any exclusion, exemption, deduction, credit, or other allowance now or hereafter accorded (a) by the laws of one of the Contracting States in the determination of the tax imposed by that State or (b) by any other agreement between the Contracting States.

3. Except as provided in paragraph 4, a Contracting State may tax a resident of that Contracting State (whether or not such person is also a resident of the other Contracting State), and the United States may tax its citizens, as if this Convention had not come into effect.

4. The provisions of paragraph 3 shall not affect (a) The benefits conferred by a Contracting State under Articles 4 (Relief from Double Taxation), 6 (Nondiscrimination), and 7 (Tax Deferral for Technical Assistance)

(b) The benefits conferred by a Contracting State under Articles 18 (Teaching and Research), 19 (Students and Trainees), 20 (Governmental Salaries), and 21 (Rules Applicable to Personal Income Articles) upon individuals, other than

(i) citizens of that Contracting State, or, (ii) in the case of the United States, individuals having immigrant status in the United States.