Commonwealth v. Shenango Furnace Co.

Citations

• 268 Pa. 283
• 110 A. 721
• 1920 Pa. LEXIS 677

Syllabus

<p>Taxation — Corporations—Capital stock — Shares of stock — Corporation owning stock of another corporation — Double taxation— Liability for tax — Acts of Jan. 8, 1868,JP. L. 1818; June 1, 1889, P. L. 420; June 8, 1891, P. L. 229, and June 17, 1918, P. L. 507.</p> <p>1. Under the Acts of Jan. 3, 1868, P. L. 1318; June 1, 1889, P. L. 420; June 8, 1891, P. L. 229, and June 17, 1913, P. L. 507, a Pennsylvania corporation which owns all of the $750,000 of the stock of another Pennsylvania corporation, is taxable to the extent of $725,000 of such stock, -when it appears that that amount of the stock of the subordinate company was not taxed because represented by property permanently located outside of the State, where $25,000 of such stock was taxable.</p> <p>2. Capital stock of a Pennsylvania corporation, which is represented by shares .of stock in other Pennsylvania corporations not doing business in Pennsylvania, and whose capital stock is not liable to taxation here because it was represented by property permanently located outside of the State, is taxable here, and such tax is not double taxation.</p>