Other income: residence-state taxation is primary, but the source state may also tax if the income arises there under treaty. Article 22 treats items of a resident's income not covered by other treaty provisions as principally taxable in the resident State, while permitting the State where the income arises to also tax that income; it functions as a residual allocation rule preserving primary residence taxation and limited source taxation under the treaty framework.
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.
Other income: residence-state taxation is primary, but the source state may also tax if the income arises there under treaty.
Article 22 treats items of a resident's income not covered by other treaty provisions as principally taxable in the resident State, while permitting the State where the income arises to also tax that income; it functions as a residual allocation rule preserving primary residence taxation and limited source taxation under the treaty framework.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.