Taxation of other income: resident-state has primary right, source-state may tax gambling and PE connected income. Items of income not dealt with elsewhere are taxable only in the State of residence, except where the recipient carries on business through a permanent ... Summary
Taxation of other income: resident-state has primary right, source-state may tax gambling and PE connected income.
Items of income not dealt with elsewhere are taxable only in the State of residence, except where the recipient carries on business through a permanent establishment or performs independent personal services from a fixed base in the other State and the income is effectively connected with that establishment or base, in which case Article 7 or Article 14 applies; however, income from lotteries and other forms of gambling sourced in the other State may be taxed by that source State.
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