Non-governmental pensions and annuities taxable only in recipient's residence state; definitions delimit scope for taxation. Non-governmental pensions and annuities under the DTAA are taxable only in the recipient's State of residence. 'Pension' covers periodic payments for past services or compensation for service-related injuries. 'Annuity' means a stated periodic sum payable during life or a specified period in return for adequate and full consideration in money or money's worth. Both categories are allocated to residence-state taxation, limiting source-state taxing rights.
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.
Non-governmental pensions and annuities taxable only in recipient's residence state; definitions delimit scope for taxation.
Non-governmental pensions and annuities under the DTAA are taxable only in the recipient's State of residence. "Pension" covers periodic payments for past services or compensation for service-related injuries. "Annuity" means a stated periodic sum payable during life or a specified period in return for adequate and full consideration in money or money's worth. Both categories are allocated to residence-state taxation, limiting source-state taxing rights.
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