have a large bonded indebtedness. Originally when their possessions were situated in a single state, by appropriate laws, the non-resident as well as the resident bondholder, could have been made taxable by that state. But to-day their loans are secured on the whole corporate property, which extends through different states. Perhaps the state might declare that hereafter no such bonds should be valid, unless certain requirements were complied with. It might demand that the bondholders should be liable to taxation on their bonds; not on the total value-that would be usurpation—but on such part thereof as was in just proportion to the value of the security situated within its borders. It is evident that this, to be even tolerable, would have to be adopted by all the states interested. Or the state might say that no such contracts should be made; that no lien should extend beyond the boundaries of the state. This, however, would involve great embarrassment in procuring loans. Besides, these provisions could act only prospectively, and would leave unaffected the great mass of existing corporate indebtedness for many years to come. The obligation of contract clause in the United States constitution intervenes here to prevent any alteration of existing contracts. The states, we repeat, are practically powerless to deal with the question.

The United States is not. Under the European systems of taxation, and under the income taxes levied both in England and this country, non-residents deriving any income from any source within the state are subjected to taxation thereon. It is well known to what a great extent aliens are investors in American securities; these persons escape taxation within this country. They are not only not taxed at the place where the property is located, but they are not taxed anywhere in the United States. This is a legitimate field of taxation which has long escaped.' There would also be many ulterior benefits,

1 "Staatspapiere, Eisenbahnobligationen, Pfandbriefe sammeln sich in den

the need of which has long been recognized. All the questions of the taxation of corporations engaged in inter-state commerce, of railway employment, and many other matters that will readily suggest themselves, as well as the matter now proposed, would be more advantageously controlled. Let the states, then, exempt from taxation all such corporations as possess that inter-state character; let the United States levy a general tax on their capital stockand bonds, and require the treasurer of the corporation to pay the tax, and give to the corporation a right to deduct the tax paid on account of such bonds from the interest paid to the bondholders without regard to their residence. The proceeds of these taxes could then be distributed among the several states in which the corporation operated, according to the extent of their business therein.' The tax so levied could be called a franchise tax on the corporation, and thus escape the objections presented by the Foreign Held Bonds Case. Whether this would be declared illegal as a direct tax, not levied according to the rule of apportionment required by the United States constitution, is not certain, under the recent decision in the Income Tax cases.

The public bonds which have been declared exempt from

Händen der kapitalkräftigen Staaten, die Hypothekschulden der Landbewohner sind zu einem grossen Teil in den Händen der Städter oder Angehöriger wohlhabender Gemeinden. Für die verschuldeten Gemeinwesen ist es von Bedeutung, die Steuer von dem Zinsertrag, der in ihrem Territorium gewonnen wird, bezw. von den ihnen wirtschaftlich zugehörigen Personen zu erhalten.”—Schanz, FinanzArchiv, 1892, ii, s. 12.

1 A similar suggestion to this was made by Prof. Seligman, in respect to the taxation of the receipts of certain inter-state corporations, in order to escape the difficulties attendant on the taxation of receipts of inter-state commerce.-Seligman, Taxation of Corp. op. cit., p. 464. Dr. Schanz also has suggested a similar method for such difficulties: "Es ist desshalb am besten, im Gemeindessteuerrecht schlechtweg den Kapitalisten am Wohnort zu fassen und bei drückender Lage stark verschuldeter Gemeinden ein zweckmässig ausgebildetes Subventionswesen der übergeordneten Gemeinschaften eintreten zu lassen (etc.).”—Schanz, FinanzArchiv, 1892, ii, s. 16.

2 Cf. Railroad Co. vs. Collector, 100 U. S., 595.

taxation are now beyond the taxing power of either the states or the federal government; in the former case by the prohibition of the constitution of the United States, in the latter by every principle of justice. Henceforth, however, it would be sounder policy to leave such property to the operation of the tax laws of both state and federal governments.'

It

'The exemption of such stock is a continual source of fraud and evasion. should not be exempted. "It was bad financiering, even in the darkest hour of our national struggle, and is wholly inexcusable now" [in case of conversion]. "The rate of interest is far less essential than equality in taxation by which that interest is paid."-A. Walker, Science of Wealth, 1866, p. 344.

COLUMBIA COLLEGE

University Faculty of Political Science.

Seth Low, LL. D., President. J. W. Burgess, LL. D., Professor of Constitutional History and Law. Richmond Mayo-Smith, Ph.D., Professor of Political Economy. Munroe Smith, J.U.D., Professor of Comparative Jurisprudence. F. J. Goodnow, LL.B., Professor of Administrative Law. E. R. A. Seligman, Ph.D., Professor of Political Economy and Finance. H. L. Osgood, Ph.D., (Adj.) Professor of History. Wm. A. Dunning, Ph.D., (Adj.) Professor of History. J. B. Moore, A.M., Professor of International Law. F. H. Giddings, A.M., Professor of Sociology. John B. Clark, Ph.D., Professor of Political Economy. J. H. Robinson, Ph.D., Professor of History. A. C. Bernheim, Ph.D., Lecturer on New York History. F. A. Bancroft, Ph.D., Lecturer on American History. W. Z. Ripley, Ph.D., Lecturer on Anthropology. G. L. Beer, A.M., Lecturer on European History. H. A. Cushing, A.M., Lecturer on European History. A. M. Day, A.M., Assistant in Economics.

COURSES OF LECTURES.

I. HISTORY.-[1] Roman History; [2] Outlines of Medieval History; [3] Outlines of Modern History; [4] European History since 1815; [5] English History; [6] American History; [7] The Middle Ages: [8] The XVI Century to the Peace of Augsburg: [9] Europe from Augsburg to Westphalia; [10] The Period of Louis XIV; [11] Europe and the French Revolution; [12] Europe and Napoleon [13] The Development of Prussia; [14] History of England; [15] Constitutional History of the United States; [16] History of the American Colonies; [17] History of the United States since 1861: [18] History of New York State; [19] State and National Politics, 1848-1861; [20] Development of the French Monarchy; [21] Historical and Political Geography; [22] Early and Mediaeval Church History: [23] Modern Church History; [24] Sources of Continental History; [25] Seminarium in European History; [26] Seminarium in American History.

II. ECONOMICS AND SOCIAL SCIENCE. [1]Elements of Political Economy; [2] Economic History: [3] Historical and Practical Political Economy; [4] Science of Finance; [5] Communism and Socialism: [6] Practical Statistics; [7] Science of Statistics; [8] History of Economic Theories; [9] Financial History of the United States; [10] Tariff History of the United States; [11] Railroad Problems; [12] Static Theory of Distribution; [13] Dynamic Theory of Distribution; [14] Sociulogy; [15] Crime and Penology: [16] The Family: [17] Pauperism; [18] Ethnology: [19] Anthropology: [20] Seminarium in Political Economy; [21] Seminarium in Science of Finance; [22] Seminarium in Social Science; [23] Seminarium in Statistics.

III. CONSTITUTIONAL AND ADMINISTRATIVE LAW.-[1] Comparative Constitutional Law of Europe and the United States; [2] Comparative Constitutional Law of the Commonwealths of the United States: [3] Administrative Law: [4] Law of Taxation; [5] Municipal Corporations; [6] Comparative Administration of New York, London, and Paris; [7] Seminarium in Constitu tional Law; [8] Seminarium in Administratium.

IV. DIPLOMACY AND INTERNATIONAL LAW.-[1] History of European Diplomacy; [2] History of American Diplomacy: [3] Principles of International Law; [4] Criminal Law and Extradition; [5] Seminarium in International Law.

V. ROMAN LAW AND COMPARATIVE JURISPRUDENCE.—[1] History and Institutes of Roman Law; [2] Roman Law, Cases from the Digest; [3] History of European Law; [4] Comparative Jurisprudence: General Principles; [s] Comparative Jurisprudence: Special Relations; [6] International Private Law; [7] Seminarium in Legal History: [8] Seminarium in Comparative Législation.

VI. POLITICAL PHILOSOPHY.-[1] History of Political Theories, ancient and mediæval; [a] History of Political Theories, modern; [3] History of American Politrcal Philosophy; [4] Seminarium in Political Theories of the XIXth Century.

The course of study covers three years, at the end of which the degree of Ph.D. may be taken. Any person not a candidate for a degree may attend any of the courses at any time by payment of a proportional fee. Twenty-four fellowships of $500 each, and thirty scholarships of $150 each are awarded to advanced students. Several prizes of from $50 to $150 are awarded annually. Three prize lectureships of $500 each for three years are open to competition of graduates. The library contains over 200,000 volumes. For further information address REGISTRAR.