Taxation of other income: residents taxed only in their State, subject to permanent establishment and gambling exceptions. Other income of a resident not dealt with elsewhere is generally taxable only in the resident State. Exceptions permit taxation in the source State where such income is effectively connected with a permanent establishment or fixed base there, in which case Article 7 or Article 14 applies, and where income arises from lotteries, betting, gambling or similar games, which may be taxed in the source State.
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: residents taxed only in their State, subject to permanent establishment and gambling exceptions.
Other income of a resident not dealt with elsewhere is generally taxable only in the resident State. Exceptions permit taxation in the source State where such income is effectively connected with a permanent establishment or fixed base there, in which case Article 7 or Article 14 applies, and where income arises from lotteries, betting, gambling or similar games, which may be taxed in the source State.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.