ART. 81] VALUATION AND ASSESSMENT. 1797

completion of the assessment of all the taxable property in any county
of this State or any assessment district of Baltimore city, said book shall
be delivered to the state tax commissioner for his information and
guidance in the discharge of his official duties; and the valuation and
assessment of said shares of stock shall not be returned by the said asses-
sors to the boards of county commissioners acting as boards of control
and review for the several counties and the boards of control and review
of Baltimore city. All bonds and certificates of indebtedness bearing
interest, issued by any railroad or other corporation of this state secured
by mortgage of property wholly within this State, belonging to resi-
dents of this State, shall be subject to valuation, assessment and taxa-
tion to the owner or owners thereof, in the same manner as like bonds
or certificates of indebtedness bearing interest and secured by mort-
gage of property partly in this State and partly in some other State or
States are now subject to valuation and assessment under the laws of
this State. All other property of every kind, nature and description
within this State, except as provided by section 4, shall be valued and
assessed for the purpose of state, county and. municipal taxation to the
respective owners thereof in the manner prescribed by this article;
provided nothing contained in this section or article shall repeal, modify
or affect sections 91-93 relating to the taxation of savings banks, or
sections 218-228, both inclusive, relating to the taxation of distilled
spirits.

Corporate taxation.

The tangible personal property of a foreign corporation permanently
located in this state, is subject to taxation here, although such stock is
owned by residents of Maryland and assessed to the owners. Such taxation
is not double taxation. The fact that the personal property of a domestic
corporation whose stock Is taxable in Maryland, is exempt under section
4, does not affect the liability of a foreign corporation to such taxation on
its personal property. Capital stock may be taxed to the corporation, and
the shares to the holders. What is "double taxation"? Cases reviewed.
Wilkens Co. v. Baltimore, 103 Md. 309. And see Consolidated Gas Co. v.
Baltimore, 101 Md. 554.

Both the property and the capital stock of a corporation can not be taxed.
The state may tax a national bank in accordance with its own laws and in
conformity with the rules applicable to citizens and state corporations.
Frederick County v. Farmers' Bank, 48 Md. 121. And see Gordon v. Balti-
more. 5 Gill, 231; State v. Mayhew, 2 Gill. 487: Tax Cases. 12 G. & ,T 117.
Cf. Wilkens Co. v. Baltimore, 103 Md. 309.

Under this section and sections 94 and 214, mortgage bonds secured by
property in this state and owned by residents of Maryland, are taxable to the
owners thereof and not to the corporation itself, nor is there any other
provision of the law imposing such taxation upon the corporation. Consoli-
dated Gas Co. v. Baltimore, 101 Md. 555; Consolidated Gas Co. v. Baltimore
105 Md. 50.

Stock of a Maryland transportation company held by non-residents, is
taxable at the place where its principal office is located. Such tax is not in
conflict with either the state or federal constitution. Corrv v. Baltimore
9G Md. 319 (affirmed in 196 U. S. 466).

The fact that the capital stock of a corporation is principally invested
in patent rights granted by the United States, does not exempt such stock
from taxation; nor is the value of such patent rights to be deducted in
assessing the stock. Crown Cork and Seal Co. v. State, 87 Md. 696.

A bridge over the Potomac river and other property of the bridge com-
pany within the limits of Maryland, are taxable under the act of 1852, ch.