William O. Douglas

“ When a foreign insurance company desires, for the first time, to do business in Oklahoma, it must apply for license to expire on the last day of February next after the issue of the license and on or before such date it must pay the gross premium tax on all premiums, less proper deductions, received by it in Oklahoma from the date of its license to and including December 31st of that year. ”

“ And the equal protection clause does not require the tax or rate of tax exacted from a foreign corporation as a condition of entry to be the same as that imposed on domestic corporations. Hanover Fire Ins. Co. v Harding, supra, 272 U.S. at pages 510, 511, 47 S.Ct. at page 183, 71 L.Ed. 372, 49 A.L.R. 713.
The fact that Oklahoma collects the tax at the end of the license year is not material. That was done in Philadelphia Fire Ass'n v. New York, supra. The controlling fact is that the tax though collected later was levied upon the privilege of entering the State and engaging in business there. ”

“ Henderson, The Position of Foreign Corporations in American Constitutional Law (1918) , ch. VIII.↑ It is not contended that appellant is engaged in interstate commerce. Hence we do not have presented any question concerning the effect of the United States v. ”