ubsequently increase
its stock to any amount.[3] Michigan, however, had a limitation of
five million dollars as to manufacturing or mercantile corporations,
and two million five hundred thousand dollars as to mines; while
Alabama and Missouri had a general limit of ten million dollars. The
general tendency is clearly to have no limitation whatever. Commonly
only a nominal proportion of the capital stock is to be paid in before
the company begins business, but the stockholders are always liable
to creditors for the amount unpaid. As already remarked, stock may
usually be paid up in property, labor, or services, or, indeed,
any legal consideration; and though most States provide that such
property, etc., shall be taken at its actual cash value, such laws,
except in Massachusetts, are not believed to be effectual.

[Footnote 1: A valuable report on this subject, brought down to 1903,
prepared by F.J. MacLeod, of Massachusetts, will be found in the
"Report of the Committee on Corporation Laws," above referred to, at
pp. 207-295.]

[Footnote 2: MacLeod, pp. 165-166.]

[Footnote 3: MacLeod, p. 169.]

That stockholders are individually liable to the extent of the unpaid
balance on their stock is merely a statutory statement of the ordinary
rule in equity. It is, therefore, law without statute. Apparently only
Indiana and Kansas now impose a double liability, the law in Ohio
having been recently altered by constitutional amendment. In several
States, however, they are liable for debts due for labor; in
California they are absolutely liable for such proportion of all
liabilities of the corporation as their stock bears to the total
capital stock, while in Nevada they are expressly exempted from any
liability whatever.

We can trace two other decided tendencies in recent legislation about
corporations. First, the increasing effort to bring about publicity of
all such matters as well as of the annual books and accounts, well
exemplified in the Massachusetts statute; second, the usual strong
prohibitions against consolidations to permit trusts or contracts to
further monopoly. There has also been a still more recent line of
legislation to prevent corporations from holding stock in other
corporations, or, at least, in competing companies; and to prevent alien
corporations from holding land.[1] Under the strict common law no
corporation could own or hold stock in another corporation or in itself.
This has been completely depart