Taxation of other income: resident state generally has taxing right, but source state may tax effectively connected income. Items of a resident's other income are generally taxable only in the resident state, but where the resident carries on business through a permanent establishment or performs independent personal services from a fixed base and the income is effectively connected with that establishment or base, the provisions governing Business Profits or Independent Personal Services apply and the source state may tax the income; additionally, notwithstanding those rules, other income of a resident arising in the source state may be taxed in that source state.
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.
Taxation of other income: resident state generally has taxing right, but source state may tax effectively connected income.
Items of a resident's other income are generally taxable only in the resident state, but where the resident carries on business through a permanent establishment or performs independent personal services from a fixed base and the income is effectively connected with that establishment or base, the provisions governing Business Profits or Independent Personal Services apply and the source state may tax the income; additionally, notwithstanding those rules, other income of a resident arising in the source state may be taxed in that source state.
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