MICHIGAN ACADEMY OF SCIENCE. 
273 
viewed. This was not because they we're assessed beyond their cash 
value, but because their long escape from equal taxation had led them 
to believe, or at least assume, that they had prescriptive rights to ex- 
emptions.'"* 
The first fruits from the agitation thus engendered for increased rev- 
enues from corporations was the enactment of a law by which a practi- 
cal method was provided for securing reports from these creatures of the 
State. Utilizing the increased fund of information concerning corpo- 
rate business which came to it as a result of these reports the State tax 
commission has distributed material regularly to the local assessing of- 
ficers by which they might more properly place corporate property upon 
the assessment rolls than had formerly been the case. There can be little 
doubt now but that the circulars which the commission has distributed 
have been very helpful in enabling the local officer to perform his work 
more efficiently. 
An associate benefit which has come front this agitation for the better 
taxation of corporations has been the development of the legal right to 
assess the intangible property of these companies. The successful resist- 
ance on the part of the Detroit Common Council to the suit of the Cit- 
izens Street Railway company which sought to prevent the assessment 
of four millions of dollars of additional value against it on account of its 
franchise and other intangible property established the lawfulness of at- 
tacking this common and highly valuable species of wealth by assessing 
officers. The rule of taxation for foreign business corporations doing 
business within the State both with regard to the State franchise tax 
and also with regard to assessment by local officials is in no essential 
respect different from the rule applicable to the domestic kinds except 
in such minor respects as develop in the application of the tax. Vessel 
owning companies and private banking companies are required to make 
different reports from those exacted from other companies but in no 
other respect does this taxation differ from that of ordinary corpora- 
tions. 
The jurisdiction to which property shall be subject for taxation pur- 
poses or as quaintly expressed in the early taxing laws “Where property 
shall lie taxed,” has carefully been explained in each of the successive 
statutes. The situs question in the actual administration of a tax is 
of serious significance both to the property which is to be 
taxed and also to the authority which is to impose the levy. To the 
former the evils of double taxation are threatened if the competency of 
the jurisdiction to which it is liable is not clearly established while the 
latter is in danger of losing its revenue resources if the fiscal obligations 
of property are not clearly defined. This problem of localizing property 
for taxation purposes is one of constantly increasing significance too, 
owing to the growing complexity and extensiveness of the taxable in- 
volved and the theory of taxation is no longer complete without a dis- 
cussion of situs consideration under such strange terms as “division 
of yield,” “segregation of sources,” “centralized administration,” etc. 
Michigan has had an almost unique experience in dealing with the 
matter of situs privileges and responsibilities through the fact that it 
has been her policy to persistently ignore at all times situs considera- 
*Rep. of State Tax Com. 1901, p. 31. 
35 
