Taxation of other income: generally taxable only in resident state, with limited source-state taxation permitted. Items of income of a resident not dealt with in other Articles are generally taxable only in the resident State. Exceptions apply where the resident carries on business through a permanent establishment or performs independent personal services from a fixed base in the other State and the income is effectively connected with that permanent establishment or fixed base, in which case the rules on business profits or independent personal services apply. Additionally, the State where the income arises may tax such items, and a special limiting rule governs income from an estate or a trust where beneficiary taxation in the residence State is required.
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 resident state, with limited source-state taxation permitted.
Items of income of a resident not dealt with in other Articles are generally taxable only in the resident State. Exceptions apply where the resident carries on business through a permanent establishment or performs independent personal services from a fixed base in the other State and the income is effectively connected with that permanent establishment or fixed base, in which case the rules on business profits or independent personal services apply. Additionally, the State where the income arises may tax such items, and a special limiting rule governs income from an estate or a trust where beneficiary taxation in the residence State is required.
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