Capital gains taxation: immovable property taxed in source state; other gains generally taxed in the resident state. Gains from alienation are taxed by reference to property type and location: immovable property is taxable in the State where situated; movable property of a permanent establishment or fixed base may be taxed in the State of that establishment or fixed base; ships and aircraft operated in international traffic are taxable only in the enterprise's State of residence; gains from shares may be taxed in the other State where, during the 365 days before alienation, more than 50 percent of their value derived from immovable property situated there; other gains are taxable only in the alienator's State of residence.
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.
Capital gains taxation: immovable property taxed in source state; other gains generally taxed in the resident state.
Gains from alienation are taxed by reference to property type and location: immovable property is taxable in the State where situated; movable property of a permanent establishment or fixed base may be taxed in the State of that establishment or fixed base; ships and aircraft operated in international traffic are taxable only in the enterprise's State of residence; gains from shares may be taxed in the other State where, during the 365 days before alienation, more than 50 percent of their value derived from immovable property situated there; other gains are taxable only in the alienator's State of residence.
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