Other income taxation: residency is primary, but source-state tax applies if income is effectively connected to a permanent establishment. Items of Other Income of a resident not dealt with elsewhere are generally taxable only in the resident State; however, if the resident 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, and the other State may also tax such 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.
Other income taxation: residency is primary, but source-state tax applies if income is effectively connected to a permanent establishment.
Items of Other Income of a resident not dealt with elsewhere are generally taxable only in the resident State; however, if the resident 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, and the other State may also tax such income.
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