Dependent personal services: employment income taxed in resident state unless exercised abroad, subject to 183 day and PE conditions. Salaries, wages and similar remuneration of a resident are taxable only in the resident State unless the employment is exercised in the other State, in which case that State may tax the remuneration. However, remuneration exercised in the other State is taxable only in the resident State if the employee's presence there does not exceed an aggregate 183 days in any 12 month period, the payor is not resident in the other State, and the pay is not borne by a permanent establishment or fixed base. Separate provisions allow source taxation for international-traffic ship or aircraft employment and exempt pay to nationals of a designated national air carrier.
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.
Dependent personal services: employment income taxed in resident state unless exercised abroad, subject to 183 day and PE conditions.
Salaries, wages and similar remuneration of a resident are taxable only in the resident State unless the employment is exercised in the other State, in which case that State may tax the remuneration. However, remuneration exercised in the other State is taxable only in the resident State if the employee's presence there does not exceed an aggregate 183 days in any 12 month period, the payor is not resident in the other State, and the pay is not borne by a permanent establishment or fixed base. Separate provisions allow source taxation for international-traffic ship or aircraft employment and exempt pay to nationals of a designated national air carrier.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 
Join Channel
TaxTMI 
