Independent personal services: residence-based taxation except where a fixed base or prolonged presence permits source-state taxation. Income from independent personal services by a resident is taxable only in the resident State, except where the resident has a fixed base regularly available in the other State or where the resident's stay in the other State meets the treaty's prolonged-presence threshold; in those cases only income attributable to that fixed base or derived from activities performed in the other State may 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.
Independent personal services: residence-based taxation except where a fixed base or prolonged presence permits source-state taxation.
Income from independent personal services by a resident is taxable only in the resident State, except where the resident has a fixed base regularly available in the other State or where the resident's stay in the other State meets the treaty's prolonged-presence threshold; in those cases only income attributable to that fixed base or derived from activities performed in the other State may be taxed there.
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