Taxation of other income: residence generally taxes it, except source taxation for gambling income and PE connected items. Other income of a resident is generally taxable only in the State of residence. If the recipient carries on business through a permanent establishment or performs independent personal services from a fixed base in the other State and the income is effectively connected with that permanent establishment or fixed base, the rules for business profits or independent personal services apply. Income from lotteries, gambling, races and similar games 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: residence generally taxes it, except source taxation for gambling income and PE connected items.
Other income of a resident is generally taxable only in the State of residence. If the recipient carries on business through a permanent establishment or performs independent personal services from a fixed base in the other State and the income is effectively connected with that permanent establishment or fixed base, the rules for business profits or independent personal services apply. Income from lotteries, gambling, races and similar games sourced in the other State may be taxed by that source State.
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