Capital gains taxation jurisdiction: source state taxes immovable property and permanent establishment disposals, residence covers other gains.

Gains from alienation of immovable property are taxable in the State where situated; gains from movable property of a permanent establishment or a fixed base are taxable in the State where that establishment or base is located; gains from ships or aircraft in international traffic are taxable only in the alienator's State of residence; disposals of shares tied principally to immovable property may be taxed in the State where the immovable property is situated, while other share disposals may be taxed in the company's State of residence; all other gains are taxable only in the alienator's State of residence.

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