Income Taxes

Cover Income Taxes
Income Taxes
Thomas Emmette Lyons
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The recent Massachusetts income tax law makes residence the test of taxability and, with perhaps greater con- sistency, confines the tax to income received by resi- dents of that state, excluding income derived by non- residents from sources within the state. The Wis- consin law makes the source of income the test and limits the application of the tax to income derived from property located and business transacted within its borders, whether by residents or non-residents.
Even where the source
...of income is made the test of taxability, compensation for personal services, inter- est from securities and dividends from stocks are taxed at the residence of the recipient under the rule of mobilia sequuntur. The close commercial relations INCOME TAXES 19 and the principle of comity between the states stand in the way of one state taxing all income of its own residents and also that of non-residents derived from sources within its borders, as is done by the federal statute. To do so involves an inconsistency and if all states were to adopt a system of income taxation it would result in double taxation of all income de- rived from one state and paid to residents of another.

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