Taxation of artistes and athletes: income from personal performances abroad may be taxed in source state, subject to public fund exceptions. Income from personal performances by entertainers and athletes may be taxed in the State where the activities are exercised under a permissive source taxation rule. If income from those activities accrues to another person it may also be taxed in the State of performance. Both source state taxation rights are displaced when the performer or the person receiving the income is supported wholly or substantially from public funds of the residence State or of the State providing support.
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Provisions expressly mentioned in the judgment/order text.
Taxation of artistes and athletes: income from personal performances abroad may be taxed in source state, subject to public fund exceptions.
Income from personal performances by entertainers and athletes may be taxed in the State where the activities are exercised under a permissive source taxation rule. If income from those activities accrues to another person it may also be taxed in the State of performance. Both source state taxation rights are displaced when the performer or the person receiving the income is supported wholly or substantially from public funds of the residence State or of the State providing support.
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