Taxation of Independent Personal Services allocated to other state if fixed base exists or presence exceeds treaty threshold. Income from independent personal services is taxable only in the resident State except where the individual has a fixed base in the other State-allowing taxation of income attributable to that base-or where the individual's presence in the other State exceeds the treaty's days threshold, permitting taxation only of income derived from activities performed 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.
Taxation of Independent Personal Services allocated to other state if fixed base exists or presence exceeds treaty threshold.
Income from independent personal services is taxable only in the resident State except where the individual has a fixed base in the other State-allowing taxation of income attributable to that base-or where the individual's presence in the other State exceeds the treaty's days threshold, permitting taxation only of income derived from activities performed there.
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