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