Taxation of other income: ordinarily taxable only in resident state; PE-linked income or gambling may be taxed in source state. Article 22 generally makes miscellaneous income of a resident taxable only in the State of residence. Exceptions: income (other than from immovable property) connected with a permanent establishment or a fixed base in the other State is treated as effectively connected and governed by the rules for business or independent personal service income; and income from lotteries, betting and other gambling 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: ordinarily taxable only in resident state; PE-linked income or gambling may be taxed in source state.
Article 22 generally makes miscellaneous income of a resident taxable only in the State of residence. Exceptions: income (other than from immovable property) connected with a permanent establishment or a fixed base in the other State is treated as effectively connected and governed by the rules for business or independent personal service income; and income from lotteries, betting and other gambling arising in the other State may be taxed in that State.
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