Independent Personal Services: income taxed in home state, except when foreign fixed base or extended presence permits taxation. Income from independent personal services of a resident is taxable only in the resident State except where the resident has a fixed base in the other State-then only income attributable to that fixed base may be taxed there-or where the resident's presence in the other State meets the duration threshold-then only income from activities performed there may be taxed. 'Professional services' includes independent scientific, literary, artistic, educational and teaching activities and specified independent professionals such as physicians, lawyers, engineers, architects, surgeons, dentists and accountants.
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: income taxed in home state, except when foreign fixed base or extended presence permits taxation.
Income from independent personal services of a resident is taxable only in the resident State except where the resident has a fixed base in the other State-then only income attributable to that fixed base may be taxed there-or where the resident's presence in the other State meets the duration threshold-then only income from activities performed there may be taxed. "Professional services" includes independent scientific, literary, artistic, educational and teaching activities and specified independent professionals such as physicians, lawyers, engineers, architects, surgeons, dentists and accountants.
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