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2. TAXABLE INCOME.

Under the Wisconsin Income-Tax Act, the term “income” is not restrictive, but includes all gains, profits or income of any kind derived from any source whatever, except certain specified exempted items. The exempted items include, inter alia, inheritances and gifts, insurance, except that paid to a partnership or corporation upon the policies on the lives of its officers, partners or employees, and income of insurance companies and steam railroad corporations.

NATIONAL AND FOREIGN INCOME.

In general, if the situs of the source of income is in Wisconsin, it is Wisconsin income; if the situs is outside, it is foreign income. As has been indicated above, certain classes of income have been allocated to source for taxation purpose, whereas certain others are allocated to the State of residence of the taxpayer. Consequently, if real estate, tangible personal property, a farm, mine or quarry is situated in Wisconsin, the income therefrom is regarded as Wisconsin income. It is important to note that any tangible personal property must have obtained in Wisconsin a definite situs before its sale can constitute a sale within Wisconsin for purposes of income-tax. Otherwise the sale within the State of an article of tangible personal property which has just entered the State or is passing through the State, or has not yet acquired a definite situs therein, is regarded as coming under the category of property in interstate commerce, which is not subject to tax in Wisconsin.

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