Independent personal services: resident-state taxation prevails, but fixed base or prolonged presence permits source taxation. Income from independent personal services is taxable only in the resident State except where the individual has a fixed base in the other State-in which case only income attributable to that fixed base may be taxed there-or where the individual's presence in the other State meets the treaty's time based presence threshold, in which case only income from activities performed in that other 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: resident-state taxation prevails, but fixed base or prolonged presence permits source taxation.
Income from independent personal services is taxable only in the resident State except where the individual has a fixed base in the other State-in which case only income attributable to that fixed base may be taxed there-or where the individual's presence in the other State meets the treaty's time based presence threshold, in which case only income from activities performed in that other State may be taxed there.
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