Independent personal services: generally taxed by residence, but source taxation allowed for fixed base, prolonged presence, or local payment. Independent personal services by a resident are taxable only in the state of residence except where income is attributable to a fixed base in the other State, where the individual's presence in the other State meets the treaty's prolonged-presence threshold and income is derived from activities there, or where remuneration for activities in the other State is paid by a resident or borne by a permanent establishment there and exceeds the treaty's fiscal-year threshold.
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: generally taxed by residence, but source taxation allowed for fixed base, prolonged presence, or local payment.
Independent personal services by a resident are taxable only in the state of residence except where income is attributable to a fixed base in the other State, where the individual's presence in the other State meets the treaty's prolonged-presence threshold and income is derived from activities there, or where remuneration for activities in the other State is paid by a resident or borne by a permanent establishment there and exceeds the treaty's fiscal-year threshold.
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