Taxation of other income: resident State generally has exclusive taxing right, subject to permanent establishment and source exceptions. Residual categories of income not addressed by specific treaty articles are taxable only in the taxpayer's State of residence, except where the resident carries on business through a permanent establishment or performs independent personal services from a fixed base in the source State and the income is effectively connected with that presence, in which case the rules for business profits or independent services apply; lottery and similar gaming winnings sourced in the other State may be taxed by 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 exclusive taxing right, subject to permanent establishment and source exceptions.
Residual categories of income not addressed by specific treaty articles are taxable only in the taxpayer's State of residence, except where the resident carries on business through a permanent establishment or performs independent personal services from a fixed base in the source State and the income is effectively connected with that presence, in which case the rules for business profits or independent services apply; lottery and similar gaming winnings sourced in the other State may be taxed by that source State.
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