Taxation of non-government pensions: residence state has exclusive taxing right over treaty-covered pensions and annuities. Taxation of non-government pensions and annuities allocates taxing jurisdiction to the recipient's state of residence: a resident's pension or annuity derived from sources in the other Contracting State may be taxed only in the resident's state. 'Pension' means periodic payments for past services or compensation for injuries sustained during service. 'Annuity' means a stated periodic payment during life or a specified period payable under an obligation in return for adequate and full consideration in money or money's worth.
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 non-government pensions: residence state has exclusive taxing right over treaty-covered pensions and annuities.
Taxation of non-government pensions and annuities allocates taxing jurisdiction to the recipient's state of residence: a resident's pension or annuity derived from sources in the other Contracting State may be taxed only in the resident's state. "Pension" means periodic payments for past services or compensation for injuries sustained during service. "Annuity" means a stated periodic payment during life or a specified period payable under an obligation in return for adequate and full consideration in money or money's worth.
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