Taxation of Independent Personal Services: residence-based taxation except where a fixed base or substantial presence permits source taxation. Income from independent personal services of a resident is taxable only in the resident State except where the individual has a fixed base in the other State-then only income attributable to that fixed base may be taxed there-or where the individual's stay in the other State meets a presence threshold-then only income from activities performed in that State may be taxed there.
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 Independent Personal Services: residence-based taxation except where a fixed base or substantial presence permits source taxation.
Income from independent personal services of a resident is taxable only in the resident State except where the individual has a fixed base in the other State-then only income attributable to that fixed base may be taxed there-or where the individual's stay in the other State meets a presence threshold-then only income from activities performed in that State may be taxed there.
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