in and fairly intelligible way
that it adds to the value of the road and the rights exercised in the
State.[559] Also, a State property tax on railroads, which is measured
by gross earnings apportioned to mileage, is not unconstitutional in the
absence of proof that it exceeds what would be legitimate as an ordinary
tax on the property valued as part of a going concern or that it is
relatively higher than taxes on other kinds of property.[560] The tax
reaches only revenues derived from local operations, and the fact that
the apportionment formula does not result in mathematical exactitude is
not a constitutional defect.[561]

Income and Other Taxes

Individual Incomes.--Consistently with due process of law, a
State annually may tax the entire net income of resident individuals
from whatever source received,[562] and that portion of a nonresident's
net income derived from property owned, and from any business, trade, or
profession carried on, by him within its borders.[563] Jurisdiction, in
the case of residents, is founded upon the rights and privileges
incident to domicile; that is, the protection afforded the recipient of
income in his person, in his right to receive the income, and in his
enjoyment of it when received, and, in the case of nonresidents, upon
dominion over either the receiver of the income or the property or
activity from which it is derived, and upon the obligation to contribute
to the support of a government which renders secure the collection of
such income. Accordingly, a State may tax residents on income from rents
of land located outside the State and from interest on bonds physically
without the State and secured by mortgage upon lands similarly
situated;[564] and the income received by a resident beneficiary from
securities held by a trustee in a trust created and administered in
another State, and not directly taxable to the trustee.[565] Nor does
the fact that another State has lawfully taxed identical income in the
hands of trustees operating therein necessarily destroy a domiciliary
State's right to tax the receipt of said income by a resident
beneficiary. "The taxing power of a State is restricted to her confines
and may not be exercised in respect of subjects beyond them."[566]
Likewise, even though a nonresident does no business within a State, the
latter may tax the profits realized by the nonresident upon his sale of
a right appurtenant to membership in a stock exchange within its