e benefited directly or indirectly, a tax on such island was
held to be a deprivation of property without due process of law.[487]
Finally, a State may levy an assessment for special benefits resulting
from an improvement already made[488] and may validate an assessment
previously held void for want of authority.[489]

JURISDICTION TO TAX

Land

Prior even to the ratification of the Fourteenth Amendment, it was
settled principle that a State could not tax land situated beyond its
limits; and subsequently elaborating upon that principle the Court has
said that "* * *, we know of no case where a legislature has assumed to
impose a tax upon land within the jurisdiction of another State, much
less where such action has been defended by a court."[490] Insofar as a
tax payment may be viewed as an exaction for the maintenance of
government in consideration of protection afforded, the logic sustaining
this rule is self-evident.

Tangible Personalty

As long as tangible personal property has a situs within its borders, a
State validly may tax the same, whether directly through an _ad valorem_
tax or indirectly through death taxes, irrespective of the residence of
the owner.[491] By the same token, if tangible personal property makes
only occasional incursions into other States, its permanent situs
remains in the State of origin, and is taxable only by the latter.[492]
The ancient maxim, _mobilia sequuntur personam_, which had its origin
when personal property consisted in the main of articles appertaining to
the person of the owner, yielded in modern times to the "law of the
place where the property is kept and used." In recent years, the
tendency has been to treat tangible personal property as "having a situs
of its own for the purpose of taxation, and correlatively to * * *
exempt [it] at the domicile of its owner."[493]The benefit-protection
theory of taxation, upon which the Court has in fact relied to sustain
taxation exclusively by the situs State, logically would seem to permit
taxation by the domiciliary State as well as by the nondomiciliary State
in which the tangibles are situate, especially when the former levies
the tax on the owner in terms of the value of the tangibles. Thus far,
however, the Court has taken the position that when the tangibles have a
situs elsewhere, the domiciliary State can neither control such
property nor extend to it or to its owner such measure of protection as
would be adequate