Independent personal services: resident state taxes; other state may tax if services performed there or a fixed base exists. The DTAA permits the State of residence to tax income from independent personal services but allows the State where services are performed to tax income attributable to those services only if the individual meets a qualifying presence threshold in that State or if the individual or partnership maintains a fixed base there; partnership presence is attributed to individual members, and 'professional services' includes specified independent professions and activities.
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: resident state taxes; other state may tax if services performed there or a fixed base exists.
The DTAA permits the State of residence to tax income from independent personal services but allows the State where services are performed to tax income attributable to those services only if the individual meets a qualifying presence threshold in that State or if the individual or partnership maintains a fixed base there; partnership presence is attributed to individual members, and "professional services" includes specified independent professions and activities.
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