Assume that the rule of residence for income tax purposes of State X is as follows: A person is resident in State X if: 1. has been present in State X in that income year, for a period of, or an aggregate period of, 183 days or more; or 2. has been present in State X in that income year and the 2 preceding income years, for an aggregate period of 270 days or more The rule of residence in State Y is the same. A Double Taxation Agreement is in force between States X and Y. The said agreement is based on the Model Tax Convention on Income and on Capital. Mr Voyageur had been present in the two States as follows: 2018-2019 2019-2020 2020-2021 State X 10 10 200 State Y 200 200 50 You are required to: (a) Explain in which State(s) Mr Voyageur is considered to be resident; [10 marks] (b) Explain the principles applicable in order to determine in which State Mr Voyageur is considered as resident for the application of the Double Taxation Agreement provisions. [20 marks]