R.C.S.A. § 12-711(b)-1
Connecticut adjusted gross income derived from or connected with sources within this state
Cite as Conn. Agencies Regs. § 12-711(b)-1
state
(a) Connecticut adjusted gross income of a nonresident individual derived from or connected
with sources within this state is that portion of Connecticut adjusted gross income
that is derived from or connected with Connecticut sources. In addition to the items
of income, gain, loss and deduction realized directly by a nonresident individual,
it includes such individual’s distributive share of partnership income, gain, loss
and deduction (see Part VII), his or her pro rata share of S corporation income, gain,
loss and deduction (see Part VII) and his or her share of trust or estate income,
gain, loss and deduction (see Part IV), to the extent derived from or connected with
Connecticut sources.
Example: During 1992, taxpayer N, a nonresident individual, was paid a salary of $10,000 by
his employer, which is headquartered in Massachusetts. N’s salary paychecks are drawn
on a Massachusetts bank. Eighty percent of N’s working days were properly considered
days worked within Connecticut. N is also a partner in a partnership carrying on business
as a manufacturer’s representative both within and without Connecticut. N’s distributive
share as a partner of the partnership income was $35,000. Seventy percent of the income
of the partnership was properly allocated to Connecticut. N received $3,000 in net
rental income from a Springfield, Massachusetts apartment house that N owns. N also
received a share as a beneficiary of a trust under the will of his father. Income
of the trust consisted of $4,000 in net rentals from a Hartford medical office building
and $6,000 in dividends from a Connecticut corporation. N’s share as a 50% beneficiary
of this trust was $5,000.
The portion of N’s salary that was derived from or connected with Connecticut sources
is $8,000, determined on the basis of an allocation of days worked in and out of Connecticut
and not by where payment was made (see § 12-711(c)-5 of this Part). N’s share of the
partnership income which is sourced to Connecticut is $24,500, determined on the basis
of the partnership’s 70% allocation (see Part VII). The income from the Massachusetts
apartment house is not included in Connecticut adjusted gross income derived from
or connected with sources within Connecticut (see § 12-711(b)-3 of this Part). N’s
share of the income from the trust that is derived from or connected with sources
within Connecticut is limited to $2,000, his 50% share of Connecticut rental income,
because dividends are income from intangibles that are generally not considered to
be derived from or connected with Connecticut sources for a nonresident (see § 12-713(a)-4
of Part IV and § 12-711(b)-5 of this Part).
Connecticut
adjusted gross
income
Connecticut
adjusted gross
income derived from
or connected with
Connecticut sources
Salary
$10,000
$ 8,000
Partnership share
35,000
24,500
Mass. rental income
3,000
0
Trust share:
Conn. rental income
$2,000
Dividends
$3,000
$ 5,000
2,000
Total
$53,000
$34,500
(b) While this section pertains to Section 12-711(b) of the general statutes, for purposes
of supplementary interpretation, as the phrase is used in Section 12-2 of the general
statutes, the adoption of this section is authorized by Section 12-701(c) of the general
statutes.