Matson Navigation Co. v. State Board of Equalization, 297 U.S. 441 (1936)

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Matson Navigation Co. v. State Board

of Equalization of California
No. 346

Argued January 17, 1936
Decided March 2, 1936
297 U.S. 441

APPEAL FROM THE SUPREME COURT OF CALIFORNIA

Syllabus

1. The commerce clause does not prevent a State from imposing upon her corporations, for the privilege of exercising their corporate franchises within the State, a tax measured on the net income justly attributable to their business done within the State, though part of the income so attributable be from interstate and foreign commerce. P. 443.

2. A tax thus laid held consistent with due process. Hans Rees’ Sons v. North Carolina, 283 U.S. 123, distinguished. P. 444.

3. A state tax on the privilege of exercising corporate franchises within the State, measured at a uniform rate on net income attributable to business within the State, does not discriminate unconstitutionally against corporations deriving such income from interstate and foreign as well as from intrastate business because other corporations, having no interstate business, are taxed only on intrastate income, or because foreign corporations engaged in interstate and foreign business exclusively are exempt from the tax. P. 445.

4. A foreign corporation whose sole business in a State is interstate and foreign commerce cannot be subjected to a privilege tax. P. 446.

5. A discrimination in state taxation required by the commerce clause cannot be held to violate the equal protection clause of the Fourteenth Amendment. P. 446.

3 Cal.2d 1, 43 P. 2d 805, affirmed.

Appeal from a judgment sustaining, on review, a state tax.