3026 ARTICLE 81

(2) All tangible personal properties located in this State, by whomso-
ever owned, in the county and/or city in which the same are respectively
permanently located, (a) provided that rolling stock of railroads worked
by steam shall be taxed only as provided in Section 8 (a) ; and (b) pro-
vided further that tangible personal property located in this State, and
not permanently located in any county or city shall be subject to taxation
in the county and/or city where the owner resides or has his or its principal
office or place of business in this State.

(3) All shares of stock in any national bank situated in this State, in
the county and/or city where the holders thereof respectively reside, or if
they be non-residents of this State, in the county and/or city in which the
principal office of such bank is situated.

(4) All shares of stock in any domestic corporation, other than an ordi-
nary business corporation, in the county and/or city in which the owners
respectively reside, or, in the case of shares owned by non-residents of this
State, in the county and/or city in which the principal office of the corpora-
tion in this State is situated.

(5) All interest, shares or proportion owned by residents of this State
in all ships or other vessels, whether such ships or other vessels be in or out
of port, in the county and/or city in which the owners respectively reside.

(6) The stock in business of every person, firm or corporation engaged
in any manufacturing or commercial business in this State, which shall be
deemed permanently located in the county and/or city where such business
is carried on.

(7) So much of the capital stock of foreign finance corporations doing
business in Maryland as represents the business done in this State, in
the county and/or city in which the principal office of the corporation in
this state is situated.

Cited in Tax Comm. v. Allied Mortgage Cos., 175 Md. 360; Tax Comm. v. Balto.
Nat. Bnk., 174 Md. 405.

This section referred to in holding invalid ch. 497 of 1931, exempting W., B. & A.
Elec. R. Co. from taxation. Baltimore v. Williams, 61 Fed. (2nd), 374 (reversed and
act held valid by U. S. Supreme Court—289 U. S. 36).

Certificates or evidences of indebtedness of individual held not taxable under sub-
section 3 of this section. Baltimore v. Home Credit Co., 165 Md. 64.

Cited in construing sec. 7, sub-sec. 28. Steam Packet Co. v, Baltimore, 161 Md. 9.

Interest of resident of Maryland in trust estate administered for his benefit in another
state, is subject to taxation under this section. Double taxation. McCeney v. Prince
George's County, 153 Md. 26.

Corporate taxation.

2. 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 owners. Such taxation is not double taxation. The fact
that personal property of a domestic corporation whose stock is taxable in Maryland,
is exempt, does not affect liability of a foreign corporation to such taxation on its
personal property. Capital stock may be taxed to corporation, and the shares to
holders. What is "double taxation"? Cases reviewed. Wilkins Co. v. Baltimore,
103 Md. 309. And see Consolidated Gas Co. v. Baltimore, 101 Md. 554.

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

Under this section, mortgage bonds secured by property in this state and owned by
residents of Maryland, are taxable to owners thereof and not to corporation itself, nor
is there any other provision of law imposing such taxation upon the corporation.
Consolidated 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
state or Federal Constitution. Corry v. Baltimore, 96 Md. 319 (affirmed in 196
U. S. 466).