poration, although payable to banks in other States.[507] These
taxes, however, were deemed to have been laid, not on the property, but
upon an event, the transfer in one instance, and execution, in the
latter, which took place in the taxing State.

Taxes on Intangibles Invalidated.--The following personal
property taxes on intangibles have not been upheld:

(1) Debts evidenced by notes in safekeeping within the taxing State, but
made and payable and secured by property in a second State and owned by
a resident of a third State.[508]

(2) A property tax sought to be collected from a life beneficiary on the
corpus of a trust composed of property located in another State and as
to which said beneficiary had neither control nor possession, apart from
the receipt of income therefrom.[509] However, a personal property tax
may be collected on one-half of the value of the corpus of a trust from
a resident who is one of the two trustees thereof, notwithstanding that
the trust was created by the will of a resident of another State in
respect of intangible property located in the latter State, at least
where it does not appear that the trustee is exposed to the danger of
other _ad valorem_ taxes in another State.[510] The first case, Brooke
_v._ Norfolk,[511] is distinguishable by virtue of the fact that the
property tax therein voided was levied upon a resident beneficiary
rather than upon a resident trustee in control of nonresident
intangibles. Different too is Safe Deposit and Trust Co. _v._
Virginia,[512] where a property tax was unsuccessfully demanded of a
nonresident trustee with respect to nonresident intangibles under its
control.

(3) A tax, measured by income, levied on trust certificates held by a
resident, representing interests in various parcels of land (some inside
the State and some outside), the holder of the certificates, though
without a voice in the management of the property, being entitled to a
share in the net income and, upon sale of the property, to the proceeds
of the sale.[513]

Transfer Taxes (Inheritance, Estate, Gift Taxes).--Being
competent to regulate exercise of the power of testamentary disposition
and the privilege of inheritance, a State may base its succession taxes
upon either the transmission, or an exercise of the legal power of
transmission, of property by will or by descent, or the enjoyment of the
legal privilege of taking property by devise or descent.[514] But
whatever may be t