Charles Evans Hughes

“ And we cannot doubt that the question whether the state is taxing a foreign corporation for a privilege not granted-that is, whether the acts done by the corporation at the time to which the tax relates are of such a nature as to subject it to the local authority upon the ground that it is doing acts which can only be done with the permission of that authority-must be regarded as a Federal question. ”

“ It is as to the power of the state to treat the mere continuance of the obligation of the existing policies held by resident policy holders as the transaction of a local business justifying the imposition of an annual privilege tax in the absence of the actual conduct of business within the limits of the state. ”

“ The insurance company, a New York corporation, had been admitted to do business in North Carolina, and had actually transacted business in that state prior to the year 1899. The legislature of North Carolina enacted a statute providing that any corporation desiring to do business in the state after June 1, 1899, must become a domestic corporation. ”