Residency-based taxation of other income allows source-state tax when income is connected to a permanent establishment or fixed base. Items of income of a resident not dealt with in earlier Articles are generally taxable only in the State of residence, but where the resident 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, the provisions on business profits or independent personal services apply; additionally, the other State may tax residual items of income arising in its territory notwithstanding those rules.
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.
Residency-based taxation of other income allows source-state tax when income is connected to a permanent establishment or fixed base.
Items of income of a resident not dealt with in earlier Articles are generally taxable only in the State of residence, but where the resident 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, the provisions on business profits or independent personal services apply; additionally, the other State may tax residual items of income arising in its territory notwithstanding those rules.
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