Taxation of other income: residence taxation generally applies, but source state may tax PE connected income and lottery winnings. Items of income of a resident not dealt with elsewhere are taxable only in the resident State, except where income (other than immovable property) is effectively connected with a permanent establishment or arises from independent personal services from a fixed base in the other State, in which case the rules on business profits or independent personal services apply; winnings from lotteries, puzzles, races, card games and other games may be taxed in the State where they arise.
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 taxation generally applies, but source state may tax PE connected income and lottery winnings.
Items of income of a resident not dealt with elsewhere are taxable only in the resident State, except where income (other than immovable property) is effectively connected with a permanent establishment or arises from independent personal services from a fixed base in the other State, in which case the rules on business profits or independent personal services apply; winnings from lotteries, puzzles, races, card games and other games may be taxed in the State where they arise.
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