Independent personal services: residency-based taxation, with exceptions for a fixed base or prolonged presence enabling source-state taxation. Income from independent personal services is taxable only in the individual's State of residence except where the individual has a fixed base in the other State, in which case only income attributable to that fixed base may be taxed there, or where the individual's presence in the other State meets the treaty's threshold for prolonged presence, in which case only income from activities performed there may be taxed by that State. 'Professional services' are defined to include specified independent professions and activities.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Independent personal services: residency-based taxation, with exceptions for a fixed base or prolonged presence enabling source-state taxation.
Income from independent personal services is taxable only in the individual's State of residence except where the individual has a fixed base in the other State, in which case only income attributable to that fixed base may be taxed there, or where the individual's presence in the other State meets the treaty's threshold for prolonged presence, in which case only income from activities performed there may be taxed by that State. "Professional services" are defined to include specified independent professions and activities.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 
Join Channel
TaxTMI 
