Countess de Noailles' Estate

Citations

• 236 Pa. 213
• 84 A. 665
• 1912 Pa. LEXIS 736

Syllabus

<p>Taxation — Collateral inheritance tax — Trusts and trustees— Situs of securities — Foreign resident.</p> <p>Where a widow domiciled in France dies without lineal descendants, the State of Pennsylvania cannot collect a collateral inheritance tax on bonds, mortgages and other securities held by a trustee in Pennsylvania, under a deed of trust executed sixty years before the decedent’s death, where it appears that the deed created a mere, passive trust and that the bonds, mortgages and securities, seven-eighths of which represented accumulations, were always at the decedent’s absolute disposal, and constituted part of her personal estate which passed directly to the ancillary administrators of her estate in Pennsylvania, and not to any beneficiaries, under the deed of trust.</p>