not on property but on the privilege of doing business in
corporate form, a domestic corporation may be subjected to a privilege
tax graduated according to paid up capital stock, even though the
latter represents capital not subject to the taxing power of the
State.[543] By the same token, the validity of a franchise tax, imposed
on a domestic corporation engaged in foreign maritime commerce and
assessed upon a proportion of the total franchise value equal to the
ratio of local business done to total business, is not impaired by the
fact that the total value of the franchise was enhanced by property and
operations carried on beyond the limits of the State.[544] However, a
State, under the guise of taxing the privilege of doing an intrastate
business, cannot levy on property beyond its borders; and, therefore, as
applied to foreign corporations, a license tax based on authorized
capital stock is void,[545] even though there be a maximum to the
fee,[546] unless apportioned according to some method, as, for example,
a franchise tax based on such proportion of outstanding capital stock as
is represented by property owned and used in business transacted in the
taxing State.[547] An entrance fee, on the other hand, collected only
once as the price of admission to do an intrastate business, is
distinguishable from a tax and accordingly may be levied on a foreign
corporation on the basis of a sum fixed in relation to the amount of
authorized capital stock (in this instance, a $5,000 fee on an
authorized capital of $100,000,000).[548]

(3) Privilege Taxes Measured by Gross Receipts.--A municipal
license tax imposed as a percentage of the receipts of a foreign
corporation derived from the sales within and without the State of goods
manufactured in the city is not a tax on business transactions or
property outside the city and therefore does not violate the due process
clause.[549] But a State is wanting in jurisdiction to extend its
privilege tax to the gross receipts of a foreign contracting corporation
for work done outside the taxing State in fabricating equipment later
installed in the taxing State. Unless the activities which are the
subject of the tax are carried on within its territorial limits, a State
is not competent to impose such a privilege tax.[550]

(4) Taxes on Tangible Personal Property.--When rolling stock
is permanently located and employed in the prosecution of a business
outside the boundaries of a domicili