Independent personal services: source-state taxation limited to income tied to a fixed base or substantial presence. Income of a resident individual from professional or similar independent activities is taxable only in the State of residence except where the individual has a fixed base in the other State-allowing taxation of income attributable to that fixed base-or where the individual's presence in the other State meets a substantial-presence threshold-allowing taxation only of income from activities performed 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.
Independent personal services: source-state taxation limited to income tied to a fixed base or substantial presence.
Income of a resident individual from professional or similar independent activities is taxable only in the State of residence except where the individual has a fixed base in the other State-allowing taxation of income attributable to that fixed base-or where the individual's presence in the other State meets a substantial-presence threshold-allowing taxation only of income from activities performed there.
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