nse tax imposed by that State in
retaliation for a like tax levied by Pennsylvania against New York
corporations. This tax was held valid on the ground that the State,
having power to exclude entirely, could change the conditions of
admission for the future, and could demand the payment of a new or
further tax, as a license fee.[1065] Later cases whittled down this rule
considerably. The Court decided that "after its admission, the foreign
corporation stands equal and is to be classified with domestic
corporations of the same kind,"[1066] and that where it has acquired
property of a fixed and permanent nature in a State, it cannot be
subjected to a more onerous tax for the privilege of doing business than
domestic corporations.[1067] A State statute taxing foreign corporations
writing fire, marine, inland navigation and casualty insurance on net
receipts, including receipts from casualty business was held invalid
under the equal protection clause where foreign companies writing only
casualty insurance were not subject to a similar tax.[1068] Recently,
the doctrine of Fire Asso. of Philadelphia _v._ New York was revived to
sustain an increased tax on gross premiums which was exacted as an
annual license fee from foreign but not from domestic
corporations.[1069] Even though the right of a foreign corporation to do
business in a State rests on a license, yet the equal protection clause
is held to insure it equality of treatment, at least so far as _ad
valorem_ taxation is concerned.[1070]

Income Taxes

A State law which taxes the entire income, including that derived
without the State, of domestic corporations which do business in the
State, while exempting entirely the income received outside the State by
domestic corporations which do no local business, is arbitrary and
invalid.[1071] In taxing the income of a nonresident, there is no denial
of equal protection in limiting the deduction of losses to those
sustained within the State, although residents are permitted to deduct
all losses, wherever incurred.[1072] A retroactive statute imposing a
graduated tax at rates different from those in the general income tax
law, on dividends received in a prior year which were deductible from
gross income under the law in effect when they were received, is not
obnoxious to the equal protection clause.[1073]

Inheritance Taxes

In inheritance taxation, there is no denial of equal protection in
prescribing different treatmen