Royalties shall be deemed to arise in a Contracting State when the payer is that Contracting State, a political subdivision, a local authority thereof or a resident of that Contracting State.

如果支付特许权使用费的人是缔约国一方、其行政区或地方当局或该缔约国居民，应认为该特许权使用费发生在该缔约国。

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Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political or administrative subdivision, a local authority or a resident of that State.

如果支付特许权使用费的人是缔约国一方、其行政或管理机构、地方当局或该缔约国居民，应认为该特许权使用费发生在该国。

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In New York, as in most other states, a person can be deemed a resident either by being domiciled in the state or by maintaining a residence in the state for most or all of the year and spending the requisite number of days in the state.

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You may not exceed a total of 45 total days within the state, once you are deemed a non-resident of California.

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