Other income taxed in resident state, with narrow guarantee fee exceptions and permanent establishment carve out. Items of other income beneficially owned by a resident and not covered by earlier articles are taxable only in that resident State, subject to exceptions: (a) guarantee fees arising in one State may be taxed there if beneficially owned by a connected resident who benefits from a special tax regime in its residence State; and (b) for the United States, guarantee fees paid by an expatriated entity and beneficially owned by a connected resident company may be taxed in the United States for a ten year period under specified limitations. If the beneficial owner carries on business in the other State through a permanent establishment and the income is effectively connected, Article 7 applies.
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.
Other income taxed in resident state, with narrow guarantee fee exceptions and permanent establishment carve out.
Items of other income beneficially owned by a resident and not covered by earlier articles are taxable only in that resident State, subject to exceptions: (a) guarantee fees arising in one State may be taxed there if beneficially owned by a connected resident who benefits from a special tax regime in its residence State; and (b) for the United States, guarantee fees paid by an expatriated entity and beneficially owned by a connected resident company may be taxed in the United States for a ten year period under specified limitations. If the beneficial owner carries on business in the other State through a permanent establishment and the income is effectively connected, Article 7 applies.
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