Taxation of Independent Personal Services: residence taxation with exceptions for fixed base or prolonged presence permitting source-state taxation. Income of a resident individual from professional or similar independent activities is taxable only in the State of residence except where the individual has a fixed base in the other State-then only income attributable to that fixed base may be taxed there-or where the individual's stay in the other State aggregates to or exceeds 183 days in the relevant previous year or taxable period-then only income from activities performed in that other State may be taxed there. 'Professional services' covers independent scientific, literary, artistic, educational or teaching activities and listed independent professions.
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: residence taxation with exceptions for fixed base or prolonged presence permitting source-state taxation.
Income of a resident individual from professional or similar independent activities is taxable only in the State of residence except where the individual has a fixed base in the other State-then only income attributable to that fixed base may be taxed there-or where the individual's stay in the other State aggregates to or exceeds 183 days in the relevant previous year or taxable period-then only income from activities performed in that other State may be taxed there. "Professional services" covers independent scientific, literary, artistic, educational or teaching activities and listed independent professions.
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