Other income taxation: residence-based rule with exceptions for permanent establishment, fixed base, and source taxation of gambling. Other income is generally taxable only in the resident State, except where income (other than immovable property income) is effectively connected with a ... Summary
Other income taxation: residence-based rule with exceptions for permanent establishment, fixed base, and source taxation of gambling.
Other income is generally taxable only in the resident State, except where income (other than immovable property income) is effectively connected with a permanent establishment or arises from independent personal services from a fixed base in the other State, in which case rules for business profits or independent personal services apply; additionally, income from lotteries, betting, gambling, races, games and similar activities sourced in the other State may be taxed in that source State.
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