Taxation of other income: residence state generally taxes such receipts, with PE/fixed base and lottery exceptions. Article 22 provides that income of a resident not covered elsewhere in the Treaty is taxable only in the resident State, except where the beneficial owner carries on business via a permanent establishment or performs independent personal services from a fixed base in the other State and the income is effectively connected with that PE or fixed base-then Articles on business profits or independent personal services apply-and except that winnings or prizes from lotteries, games or races may be taxed in the State where they arise.
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: residence state generally taxes such receipts, with PE/fixed base and lottery exceptions.
Article 22 provides that income of a resident not covered elsewhere in the Treaty is taxable only in the resident State, except where the beneficial owner carries on business via a permanent establishment or performs independent personal services from a fixed base in the other State and the income is effectively connected with that PE or fixed base-then Articles on business profits or independent personal services apply-and except that winnings or prizes from lotteries, games or races may be taxed in the State where they arise.
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 
