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.
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.
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.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.