TAXATION - SITUS OF INTANGIBLES - BUSINESS SITUS

Authors

Michigan Law Review, University of Michigan Law School

Abstract

A manufacturing corporation incorporated in Delaware and maintained a nominal office there, but had branch offices and factories in several states. Its principal office was in West Virginia. All contracts made by the branch offices were subject to approval by the home office and withdrawals from the bank deposits in the several states were under the control of the home office. A West Virginia statute placed an ad valorem property tax on corporations whose bank deposits and accounts receivable were "liable to taxation." The state court applied the statute to the bank deposits in banks outside the state and to accounts receivable carried on the books of branch offices. Held, the due process clause did not prevent West Virginia from levying this tax. Wheeling Steel Corporation v. Fox, 298 U.S. 193, 56 S. Ct. 773 (1936).

Recommended Citation

Michigan Law Review, TAXATION - SITUS OF INTANGIBLES - BUSINESS SITUS, 35 Mich. L. Rev. 1032 (1937).
Available at: https://repository.law.umich.edu/mlr/vol35/iss6/26