Edward Terry Sanford

“ There is no sufficient reason why a foreign corporation desiring the continue the carrying on of business in the State for another year-from which it expects to derive a benefit-should be relieved of a privilege tax because it did not happen to have made any profit during the preceding year. ”

“ If the entire business of the corporation is not transacted within the State, the tax is to be based upon the portion of such ascertained net income determined by the proportion which the aggregate value of specified classes of the assets of the corporation within the State bears to the aggregate value of all such classes of assets wherever located. ”

“ There the Connecticut statute imposed upon foreign corporations doing business partly within and partly without the State an annual tax of two per cent upon the net income earned during the preceding year on business carried on within the State, ascertained by taking such proportion of the whole net income on which the corporation was required to pay a tax to the United States as the value of its real and tangible personal property within the State bore to the value of all of its real and tangible personal property. ”