Independent personal services: residence-state taxation, but other state may tax if a fixed base exists or prolonged presence creates source. Income from independent personal services of a resident is taxable only in the residence State except where the individual has a fixed base in the other State-then only income attributable to that fixed base may be taxed there-or where the individual's aggregated presence in the other State meets a duration threshold permitting taxation only of income derived from activities performed in that other 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.
Independent personal services: residence-state taxation, but other state may tax if a fixed base exists or prolonged presence creates source.
Income from independent personal services of a resident is taxable only in the residence State except where the individual has a fixed base in the other State-then only income attributable to that fixed base may be taxed there-or where the individual's aggregated presence in the other State meets a duration threshold permitting taxation only of income derived from activities performed in that other State.
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