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          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.

          <h1>Taxation of unspecified income: resident State has primary right, source State may also tax; PE-linked income follows specific allocation rules.</h1> Income not expressly mentioned is taxable primarily in the taxpayer's State of residence, although the source State may also tax such income. Income effectively connected with a permanent establishment or fixed base in the source State is not covered by the primary-residence rule and is governed by the treaty provisions allocating business profits or income from a fixed base.

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