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 ... Summary
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.
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