Taxation of other income: resident-state taxation unless a permanent establishment or fixed base produces effectively connected income. Article 22 treats other income of a resident not dealt with elsewhere as taxable only in that State, but if 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, Article 7 or Article 14 applies instead.
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: resident-state taxation unless a permanent establishment or fixed base produces effectively connected income.
Article 22 treats other income of a resident not dealt with elsewhere as taxable only in that State, but if 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, Article 7 or Article 14 applies instead.
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