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Taxation of other income: generally taxable in the resident state, with permanent establishment linked source exceptions. Items of other income of a resident not dealt with in earlier articles are generally taxable only in the State of residence, except where such income (other than immovable property income) is effectively connected with a permanent establishment or fixed base in the other State-then the rules on business profits or independent personal services apply-and the source State may also tax income not addressed in prior articles.
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: generally taxable in the resident state, with permanent establishment linked source exceptions.
Items of other income of a resident not dealt with in earlier articles are generally taxable only in the State of residence, except where such income (other than immovable property income) is effectively connected with a permanent establishment or fixed base in the other State-then the rules on business profits or independent personal services apply-and the source State may also tax income not addressed in prior articles.
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