Independent personal services: taxable in resident state, except fixed base or prolonged presence permits source taxation. Income from independent personal services by a resident is taxable only in that State, except where the person has a fixed base in the other State-then only income attributable to that fixed base may be taxed there-or where the person's stay in the other State meets the Convention's prolonged presence threshold, in which case only income from activities performed in that 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: taxable in resident state, except fixed base or prolonged presence permits source taxation.
Income from independent personal services by a resident is taxable only in that State, except where the person has a fixed base in the other State-then only income attributable to that fixed base may be taxed there-or where the person's stay in the other State meets the Convention's prolonged presence threshold, in which case only income from activities performed in that State may be taxed there.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 
Join Channel
TaxTMI 
