Independent personal services: residence taxation generally exclusive, with exceptions for fixed base and substantial presence. Income from independent personal services earned by a resident is generally taxable only in the State of residence, except where the person has a fixed base regularly available in the other State-where only income attributable to that fixed base may be taxed there-or where the person's presence in the other State meets the Agreement's substantial presence threshold, in which case only income from activities performed in that other State may be taxed 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: residence taxation generally exclusive, with exceptions for fixed base and substantial presence.
Income from independent personal services earned by a resident is generally taxable only in the State of residence, except where the person has a fixed base regularly available in the other State-where only income attributable to that fixed base may be taxed there-or where the person's presence in the other State meets the Agreement's substantial presence threshold, in which case only income from activities performed in that other State may be taxed there.
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