e separate parcels, or of exposing them for sale, each parcel loses
its character as an import and becomes subject to taxation as a part of
the general mass of property in the State.[1741] Imports for manufacture
cease to be such when the intended processing takes place,[1742] or when
the original packages are broken.[1743] Where a manufacturer imports
merchandise and stores it in his warehouse in the original packages,
that merchandise does not lose its quality as an import, at least so
long as it is not required to meet such immediate needs.[1744] The
purchaser of imported goods is deemed to be the importer if he was the
efficient cause of the importation, whether the title to the goods
vested in him at the time of shipment, or after its arrival in this
country.[1745] A State franchise tax measured by properly apportioned
gross receipts may be imposed upon a railroad company in respect of the
company's receipts for services in handling imports and exports at its
marine terminal.[1746]

Privilege Taxes

A State law requiring importers to take out a license to sell imported
goods amounts to an indirect tax on imports and hence is
unconstitutional.[1747] Likewise, a franchise tax upon foreign
corporations engaged in importing nitrate and selling it in the original
packages,[1748] a tax on sales by brokers[1749] and auctioneers[1750]
of imported merchandise in original packages, and a tax on the sale of
goods in foreign commerce consisting of an annual license fee plus a
percentage of gross sales,[1751] have been held invalid. On the other
hand, pilotage fees,[1752] a tax upon the gross sales of a purchaser
from the importer,[1753] a license tax upon dealing in fish which,
through processing, handling, and sale, have lost their distinctive
character as imports,[1754] an annual license fee imposed on persons
engaged in buying and selling foreign bills of exchange,[1755] and a tax
upon the right of an alien to receive property as heir, legatee, or
donee of a deceased person[1756] have been held not to be duties on
imports or exports.

Property Taxes

Property brought into the United States from without is immune from _ad
valorem_ taxation so long as it retains its character as an
import,[1757] but the proceeds of the sale of imports, whether in the
form of money or notes, may be taxed by a State.[1758] A property tax
levied on warehouse receipts for whiskey exported to Germany was held
unconstitutional as a tax on