Taxation of other income: residence-based taxation with exceptions for income tied to a permanent establishment or fixed base. Items of income of a resident not dealt with elsewhere are generally taxable only in the State of residence. If such income is effectively connected with a permanent establishment or a fixed base in the other State-including income from independent personal services-then the rules on business profits or independent personal services apply instead. Notwithstanding the residence rule, the source State may also tax residual items of income arising within its territory.
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-based taxation with exceptions for income tied to a permanent establishment or fixed base.
Items of income of a resident not dealt with elsewhere are generally taxable only in the State of residence. If such income is effectively connected with a permanent establishment or a fixed base in the other State-including income from independent personal services-then the rules on business profits or independent personal services apply instead. Notwithstanding the residence rule, the source State may also tax residual items of income arising within its territory.
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