Taxation of other income: resident-state taxation, but source-state taxation applies for PE- or fixed-base-connected items and gambling proceeds. Items of income of a resident not dealt with elsewhere are generally taxable only in the resident State. Where such income (other than immovable property income) is earned in the other State and is effectively connected with a permanent establishment or fixed base through which the resident carries on business or performs independent personal services, it is taxable under the rules for business profits or independent personal services. Income from lotteries, games or gambling may be taxed by the 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.
Taxation of other income: resident-state taxation, but source-state taxation applies for PE- or fixed-base-connected items and gambling proceeds.
Items of income of a resident not dealt with elsewhere are generally taxable only in the resident State. Where such income (other than immovable property income) is earned in the other State and is effectively connected with a permanent establishment or fixed base through which the resident carries on business or performs independent personal services, it is taxable under the rules for business profits or independent personal services. Income from lotteries, games or gambling may be taxed by the source State.
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