Residence-based taxation of other income, except when effectively connected to a permanent establishment or fixed base, allows source taxation. Income not covered by earlier provisions is generally taxable only in the recipient's State of residence, but income connected with a permanent establishment or fixed base in the other State is governed by the rules for business profits or independent personal services; lottery and gambling-type income sourced in the other State may be taxed in that 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.
Residence-based taxation of other income, except when effectively connected to a permanent establishment or fixed base, allows source taxation.
Income not covered by earlier provisions is generally taxable only in the recipient's State of residence, but income connected with a permanent establishment or fixed base in the other State is governed by the rules for business profits or independent personal services; lottery and gambling-type income sourced in the other State may be taxed in that source State.
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