icting demands of several States
and that the latter were confronted with a prospective inability to
collect.

Corporation Taxes

(1) Intangible Personal Property.--A State in which a foreign
corporation has acquired a commercial domicile and in which it maintains
its general business offices may tax the latter's bank deposits and
accounts receivable even though the deposits are outside the State and
the accounts receivable arise from manufacturing activities in another
State.[536] Similarly, a nondomiciliary State in which a foreign
corporation did business can tax the "corporate excess" arising from
property employed and business done in the taxing State.[537] On the
other hand, when the foreign corporation transacts only interstate
commerce within a State, any excise tax on such excess is void,
irrespective of the amount of the tax.[538] A domiciliary State,
however, may tax the excess of market value of outstanding capital stock
over the value of real and personal property and certain indebtedness of
a domestic corporation even though this "corporate excess" arose from
property located and business done in another State and was there
taxable. Moreover, this result follows whether the tax is considered as
one on property or on the franchise.[539] Also a domiciliary State,
which imposes no franchise tax on a stock fire insurance corporation,
validly may assess a tax on the full amount of its paid-in capital stock
and surplus, less deductions for liabilities, notwithstanding that such
domestic corporation concentrates its executive, accounting, and other
business offices in New York, and maintains in the domiciliary State
only a required registered office at which local claims are handled.
Despite "the vicissitudes which the so-called 'jurisdiction-to-tax'
doctrine has encountered * * *," the presumption persists that
intangible property is taxable by the State of origin.[540] But a
property tax on the capital stock of a domestic company which includes
in the appraisement thereof the value of coal mined in the taxing State
but located in another State awaiting sale deprives the corporation of
its property without due process of law.[541] Also void for the same
reason is a State tax on the franchise of a domestic ferry company which
includes in the valuation thereof the worth of a franchise granted to
the said company by another State.[542]

(2) Privilege Taxes Measured by Corporate Stock.--Since the tax
is levied