Taxation of other income: generally taxable only in the resident state, with permanent establishment and source exceptions. Other items of income of a resident are generally taxable only in the resident State. If such income (other than immovable property income) arises in the other State in connection with business through a permanent establishment or from independent personal services performed from a fixed base, and the right or property is effectively connected with that permanent establishment or fixed base, the rules on business profits or independent personal services apply. Despite those provisions, income of a resident not otherwise covered that arises in the other 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 other income: generally taxable only in the resident state, with permanent establishment and source exceptions.
Other items of income of a resident are generally taxable only in the resident State. If such income (other than immovable property income) arises in the other State in connection with business through a permanent establishment or from independent personal services performed from a fixed base, and the right or property is effectively connected with that permanent establishment or fixed base, the rules on business profits or independent personal services apply. Despite those provisions, income of a resident not otherwise covered that arises in the other State may be taxed there.
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