Independent personal services: taxable in residence unless income is attributable to a fixed base or presence over the threshold. Income from independent personal services earned by a resident is generally taxable only in the State of residence, except where such services are performed in the other State and the income is attributable to a fixed base regularly available there, or where the recipient's presence in that other State exceeds the treaty's temporal threshold permitting source-state taxation.
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: taxable in residence unless income is attributable to a fixed base or presence over the threshold.
Income from independent personal services earned by a resident is generally taxable only in the State of residence, except where such services are performed in the other State and the income is attributable to a fixed base regularly available there, or where the recipient's presence in that other State exceeds the treaty's temporal threshold permitting source-state taxation.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 
Join Channel
TaxTMI 
