to meet the jurisdictional requirements of due
process.

Intangible Personalty

General.--To determine whether a State, or States, may tax
intangible personal property, the Court has applied the fiction,
_mobilia sequuntur personam_ and has also recognized that such property
may acquire, for tax purposes, a business or commercial situs where
permanently located; but it has never clearly disposed of the issue as
to whether multiple personal property taxation of intangibles is
consistent with due process. In the case of corporate stock, however,
the Court has obliquely acknowledged that the owner thereof may be taxed
at his own domicile, at the commercial situs of the issuing corporation,
and at the latter's domicile; but, as of the present date,
constitutional lawyers are speculating whether the Court would sustain a
tax by all three jurisdictions, or by only two of them, and, if the
latter, which two, the State of the commercial situs and of the issuing
corporation's domicile, or the State of the owner's domicile and that of
the commercial situs.[494]

Taxes on Intangibles Sustained.--Thus far, the Court has
sustained the following personal property taxes on intangibles:

(1) A debt held by a resident against a nonresidence, evidenced by a
bond of the debtor and secured by a mortgage on real estate in the State
of the debtor's residence.[495]

(2) A mortgage owned and kept outside the State by a nonresident but on
land within the State.[496]

(3) Investments, in the form of loans to residents, made by a resident
agent of a nonresident creditor, are taxable to the nonresident
creditor.[497]

(4) Deposits of a resident in a bank in another State, where he carries
on a business and from which these deposits are derived, but belonging
absolutely to him and not used in the business, are subject to a
personal property tax in the city of his residence, whether or not they
are subject to tax in the State where the business is carried on. The
tax is imposed for the general advantage of living within the
jurisdiction [benefit-protection theory], and may be measured by
reference to the riches of the person taxed.[498]

(5) Membership owned by a nonresident in a domestic exchange, known as a
chamber of commerce.[499]

(6) Membership by a resident in a stock exchange located in another
State. "Double taxation" the Court observed "by one and the same State
is not" prohibited "by the Fourteenth Amendment; much less is t