Taxation of other income: resident state has primary taxing right, with PE or fixed base connection allowing source state taxation. Income of a resident not dealt with in preceding articles is generally taxable only in the State of residence, but where 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 nexus, the provisions governing business profits or independent personal services apply and the other State may tax such income; additionally, unspecified items 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 state has primary taxing right, with PE or fixed base connection allowing source state taxation.
Income of a resident not dealt with in preceding articles is generally taxable only in the State of residence, but where 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 nexus, the provisions governing business profits or independent personal services apply and the other State may tax such income; additionally, unspecified items arising in the other State may also be taxed there.
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