Taxation of other income: residence-based rule yields where income is effectively connected with a permanent establishment or fixed base. Income of a resident not dealt with elsewhere is generally taxable only in the resident State; however, income (other than immovable property) that is effectively connected with a permanent establishment or a fixed base in the other State is taxed under the rules for business profits or independent personal services, and income from lotteries, races, games or betting arising in the other State may be taxed in that State.
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 other income: residence-based rule yields where income is effectively connected with a permanent establishment or fixed base.
Income of a resident not dealt with elsewhere is generally taxable only in the resident State; however, income (other than immovable property) that is effectively connected with a permanent establishment or a fixed base in the other State is taxed under the rules for business profits or independent personal services, and income from lotteries, races, games or betting arising in the other State may be taxed in that State.
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