Taxation of Independent Personal Services: residence-based taxation subject to fixed-base or presence threshold permitting source-state taxation. Income from independent personal services received by a resident is taxable only in the State of residence, except where the individual has a fixed base in the other State-in which case income attributable to that base may be taxed there-or where the individual's aggregate presence in the other State meets the treaty's presence threshold, in which case income from activities performed there may be taxed in that State. The term professional services includes independent scientific, literary, artistic, educational and specified professional occupations.
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 subject to fixed-base or presence threshold permitting source-state taxation.
Income from independent personal services received by a resident is taxable only in the State of residence, except where the individual has a fixed base in the other State-in which case income attributable to that base may be taxed there-or where the individual's aggregate presence in the other State meets the treaty's presence threshold, in which case income from activities performed there may be taxed in that State. The term professional services includes independent scientific, literary, artistic, educational and specified professional occupations.
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