Residence-based taxation of independent personal services may yield to other-state taxation where fixed base, substantial presence, or resident-paid remuneration apply. Income from independent personal services by a resident is taxable only in the State of residence except where the person has a fixed base in the other State (so only income attributable to that base may be taxed there); where the person's presence in the other State amounts to a substantial presence (so only income from activities performed there may be taxed there); or where remuneration for activities in the other State is paid by a resident or borne by a permanent establishment or fixed base there and exceeds the fiscal-year threshold. 'Professional services' includes specified independent scientific, literary, artistic, educational and listed professional occupations.
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.
Residence-based taxation of independent personal services may yield to other-state taxation where fixed base, substantial presence, or resident-paid remuneration apply.
Income from independent personal services by a resident is taxable only in the State of residence except where the person has a fixed base in the other State (so only income attributable to that base may be taxed there); where the person's presence in the other State amounts to a substantial presence (so only income from activities performed there may be taxed there); or where remuneration for activities in the other State is paid by a resident or borne by a permanent establishment or fixed base there and exceeds the fiscal-year threshold. "Professional services" includes specified independent scientific, literary, artistic, educational and listed professional occupations.
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