Other income residual rule: treaty unspecified income may be taxed by residence and by the source state. Items of income not expressly allocated by earlier treaty provisions fall under the residual rule for Other income, permitting taxation by the State of ... Summary
Other income residual rule: treaty unspecified income may be taxed by residence and by the source state.
Items of income not expressly allocated by earlier treaty provisions fall under the residual rule for Other income, permitting taxation by the State of residence, while also allowing taxation by the State where the income arises, thereby creating concurrent residence and source taxing entitlements for unspecified income.
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