Summary

Stanley Matthews National Bank of Redemption v. Boston…

In view of the state of the question, as fixed by the previous decisions of this court, it is not perhaps very material now to inquire whether this alleged contrast between the taxation of national bank shares and of savings banks in Massachusetts is real or only apparent. There are several particulars which might be mentioned, and which, when properly allowed for, would certainly reduce the apparent inequality. There is only one, however, which we deem it important to notice. The tax on savings banks is based upon deposits merely.
Source: Wikisource

Stanley Matthews National Bank of Redemption v. Boston…

This is because deposits furnish the only capital which is invested and employed. The institutions themselves, although corporations, have no capital stock, and are managed by trustees, not selected by the depositors, but by public authority. The whole amount of the deposits, with the exceptions noted, are subjected to a tax of one-half of 1 per cent. On the other hand, the national banks pay a tax assessed upon the market value of the shares as personal property, upon a valuation, and at a rate exactly equal to that of all other personal property subject to taxation in the state.
Source: Wikisource

Stanley Matthews National Bank of Redemption v. Boston…

Corporations chartered by the commonwealth or organized under general laws, for purposes of business or profit, having a capital stock divided into shares, excepting banks, are subject to a tax upon their corporate franchises. For purposes of taxation, the law requires the corporate franchise in each case to be estimated at a valuation thereof equal to the aggregate value of the shares in its capital stock.
Source: Wikisource

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