Metropolitan Life Insurance v. City of New Orleans

Citations

• 205 U.S. 395
• 27 S. Ct. 499
• 51 L. Ed. 853
• 1907 U.S. LEXIS 1405

Syllabus

<p>Neither the fiction that personal property follows the domicil of the owner, nor.the doctrine that credits evidenced'by notes have the situs of the ’ latter, can be allowed to obscure the truth; and personal property may be taxed at its permanent abiding place although the domicil of the owner is elsewhere.</p> <p>Where a non-resident enters into the business of loaning money within a State and employs a local agent to conduct the business, the State may tax the capital employed precisely as it taxes the capital of its own citizens, in like situation, and may assess the credits arising out of the business, and the foreigner canno.t escape taxation upon his capital by temporarily removing from the State the evidences of credits which, under such circumstances, have a taxable situs in the State of then; origin. Loans made by a New York life insurance company on its own policies . in Louisiana are taxable in that State although • the notes may be ■ temporarily sent to the home office.</p> <p>115 Louisiana, 698, affirmed.</p>