Taxation of other income: residence generally has exclusive taxing right, with PE and gambling exceptions. Other income not addressed by earlier provisions is taxable only in the recipient's State of residence, except where the recipient's income is effectively connected with a permanent establishment or fixed base in the other State-bringing it within the business profits or independent services rules-or where the income arises from lotteries, gambling, betting or similar games in the source State, in which case the source State may tax that income.
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: residence generally has exclusive taxing right, with PE and gambling exceptions.
Other income not addressed by earlier provisions is taxable only in the recipient's State of residence, except where the recipient's income is effectively connected with a permanent establishment or fixed base in the other State-bringing it within the business profits or independent services rules-or where the income arises from lotteries, gambling, betting or similar games in the source State, in which case the source State may tax that income.
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