Taxation of other income: resident state generally has exclusive taxing right, but PE or fixed base links permit source state taxation. Items of income of a resident not dealt with elsewhere are taxable only in the resident State, but if the resident 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 establishment or base, the rules on business profits or independent personal services apply; additionally, income of a resident arising in the other State may also be taxed in that other State.
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 generally has exclusive taxing right, but PE or fixed base links permit source state taxation.
Items of income of a resident not dealt with elsewhere are taxable only in the resident State, but if the resident 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 establishment or base, the rules on business profits or independent personal services apply; additionally, income of a resident arising in the other State may also be taxed in that other State.
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