Independent personal services: income generally taxable in resident state, but may be taxed where fixed base or prolonged stay. Independent personal services income of a resident is generally taxable only in the State of residence, except that the other State may tax income attributable to a fixed base regularly available there and income from activities performed in that State where the individual's period of presence meets the treaty's presence threshold; such taxation is limited to the portion attributable to the fixed base or to the activities performed 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.
Independent personal services: income generally taxable in resident state, but may be taxed where fixed base or prolonged stay.
Independent personal services income of a resident is generally taxable only in the State of residence, except that the other State may tax income attributable to a fixed base regularly available there and income from activities performed in that State where the individual's period of presence meets the treaty's presence threshold; such taxation is limited to the portion attributable to the fixed base or to the activities performed in that other State.
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