Taxation of other income: residence-based taxation subject to PE connection and source taxation for gambling-related receipts. Other income of a resident is taxable only in the State of residence unless exceptions apply: where income is effectively connected with a permanent establishment or fixed base in the other State, Articles 7 or 14 govern taxation; or where income arises from lotteries, races, games, gambling or betting in the other State, that State may tax it. Additionally, items of a resident's income arising in the other State and not covered by prior articles may also be taxed in that 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.
Taxation of other income: residence-based taxation subject to PE connection and source taxation for gambling-related receipts.
Other income of a resident is taxable only in the State of residence unless exceptions apply: where income is effectively connected with a permanent establishment or fixed base in the other State, Articles 7 or 14 govern taxation; or where income arises from lotteries, races, games, gambling or betting in the other State, that State may tax it. Additionally, items of a resident's income arising in the other State and not covered by prior articles may also be taxed in that State.
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