Taxation of other income: resident's miscellaneous income generally taxable only in residence state, subject to permanent establishment connection. Items of income of a resident not covered elsewhere are generally taxable only in the resident State, but if the recipient carries on business through a permanent establishment or performs independent personal services from a fixed base in the other State and the income is effectively connected with that permanent establishment or fixed base, the rules on business profits or independent personal services apply; additionally, such income arising in the other State may also be taxed there.
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: resident's miscellaneous income generally taxable only in residence state, subject to permanent establishment connection.
Items of income of a resident not covered elsewhere are generally taxable only in the resident State, but if the recipient carries on business through a permanent establishment or performs independent personal services from a fixed base in the other State and the income is effectively connected with that permanent establishment or fixed base, the rules on business profits or independent personal services apply; additionally, such income arising in the other State may also be taxed there.
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