Taxation of immovable property income: source state may tax property-based income including agricultural and forestry receipts.

Income from immovable property may be taxed by the State where the property is situated; this includes income from agriculture and forestry and applies to direct use, letting, or other forms of use. The term immovable property is determined by the law of the State in which the property is located and includes accessories, livestock and equipment used in agriculture and forestry, usufruct, and rights to payments for working mineral deposits and natural resources; ships, boats, aircraft and motor cars are excluded. The rule also covers enterprise income from immovable property and income from immovable property used for independent personal services.

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