Taxation of entertainers' and athletes' income: source state may tax performance earnings, subject to public funds exceptions. Income earned by entertainers and athletes from personal activities exercised in the other Contracting State may be taxed in the State where the activities are exercised, whether the income accrues to the performer or to another person. Exceptions: if the activities are funded wholly or substantially by the performer's resident State public funds, the income is taxable only in the resident State; similarly, if the recipient of the income is supported wholly or substantially by the other State's public funds, that other State has exclusive taxation.
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 entertainers' and athletes' income: source state may tax performance earnings, subject to public funds exceptions.
Income earned by entertainers and athletes from personal activities exercised in the other Contracting State may be taxed in the State where the activities are exercised, whether the income accrues to the performer or to another person. Exceptions: if the activities are funded wholly or substantially by the performer's resident State public funds, the income is taxable only in the resident State; similarly, if the recipient of the income is supported wholly or substantially by the other State's public funds, that other State has exclusive taxation.
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