axation
by two States upon identical or closely related property interests
falling within the jurisdiction of both, forbidden."[500]

(7) A resident owner may be taxed on stock held in a foreign corporation
that does no business and has no property within the taxing State. The
Court also added that "undoubtedly the State in which a corporation is
organized may * * *, [tax] of all its shares whether owned by residents
or nonresidents."[501]

(8) Stock in a foreign corporation owned by another foreign corporation
transacting its business within the taxing State. The Court attached no
importance to the fact that the shares were already taxed by the State
in which the issuing corporation was domiciled and might also be taxed
by the State in which the issuing corporation was domiciled and might
also be taxed by the State in which the stock owner was domiciled; or at
any rate did not find it necessary to pass upon the validity of the
latter two taxes. The present levy was deemed to be tenable on the basis
of the benefit-protection theory; namely, "the economic advantages
realized through the protection, at the place * * *, [of business situs]
of the ownership of rights in intangibles * * *"[502]

(9) Shares owned by nonresident shareholders in a domestic corporation,
the tax being assessed on the basis of corporate assets and payable by
the corporation either out of its general fund or by collection from the
shareholder. The shares represent an aliquot portion of the whole
corporate assets, and the property right so represented arises where the
corporation has its home, and is therefore within the taxing
jurisdiction of the State, notwithstanding that ownership of the stock
may also be a taxable subject in another State.[503]

(10) A tax on the dividends of a corporation may be distributed ratably
among stockholders regardless of their residence outside the State, the
stockholders being the ultimate beneficiaries of the corporation's
activities within the taxing State and protected by the latter and
subject to its jurisdiction.[504] This tax, though collected by the
corporation, is on the transfer to a stockholder of his share of
corporate dividends within the taxing State, and is deducted from said
dividend payments.[505]

(11) Stamp taxes on the transfer within the taxing State by one
nonresident to another of stock certificates issued by a foreign
corporation;[506] and upon promissory notes executed by a domestic
cor