Taxation of independent personal services: residence state primary, but fixed base or extended local presence permits source-state taxation. Income from independent personal services of a resident is taxable only in the resident State except where the individual has a fixed base in the other State-then only income attributable to that fixed base may be taxed there-or where the individual's stay in the other State meets the prolonged-presence threshold-then only income derived from activities performed in that other State may be taxed there. The term 'professional services' includes independent scientific, literary, artistic, educational or teaching activities and the independent activities of physicians, lawyers, engineers, architects, surgeons, dentists and accountants.
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Provisions expressly mentioned in the judgment/order text.
Taxation of independent personal services: residence state primary, but fixed base or extended local presence permits source-state taxation.
Income from independent personal services of a resident is taxable only in the resident State except where the individual has a fixed base in the other State-then only income attributable to that fixed base may be taxed there-or where the individual's stay in the other State meets the prolonged-presence threshold-then only income derived from activities performed in that other State may be taxed there. The term 'professional services' includes independent scientific, literary, artistic, educational or teaching activities and the independent activities of physicians, lawyers, engineers, architects, surgeons, dentists and accountants.
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