within the state does not affect the liability of the estate of a nonresident decedent for transfer tax on property owned within the state. In re Hallenbeck's Estate, 186 N. Y. S. 293. Oklahoma

Money of a corporation, a part of its moneyed capital, surplus, and profits actually invested in the business of the corporation, is not exempt from assessment because it is in a bank in another state, in view of Rev. Laws 1910, No. 7306. In re Assessment of Chickasha Cotton Oil Co., 194 P. 215. Vermont

Where foreign corporation with manufacturing plant and branch office in the state attended to all business matters, originating at such branch office, at its home office outside the state where it also kept the accounts, originating from business in the state and fixed prices, made sales, and paid accounts at such home office, the accounts payable to the corporation originating from business in the state were not taxable. National Metal Edge Box Co. v. Town of Readsboro, 111 A. 386. Virginia

Intangible personal property, such as stocks, bonds, and other evidence of indebtedness, are subject to an inheritance tax in the state in which the owner was domiciled at the time of his death, without reference to actual location of the evidences of such indebtedness, because the domicile of the owner fixes for taxation the situs of personalty of this character

Stock in a Missouri national bank owned by a Virginia decedent is subject to Virginia inheritance taxes as are funds derived from sale thereof, notwithstanding the state of Missouri imposed and collected inheritance taxes; the double taxation not being invalid. Cornett's Ex'rs. v. Commonwealth, 105 S. E. 230.

New York

TREATIES

Convention between United States and Austria, concluded May 8, 1848, proclaimed October 25, 1850 (9 Stat. 944, art. 2), extending stipulations of treaty of commerce and navigation, concluded August 27, 1829, proclaimed February 10, 1831 (8 Stat. 398,) in substance giving Austrian subjects the privilege to inherit real property, conditionally on sale within two years, held not abrogated by war between the United States and AustriaHungary.

A treaty with a foreign country, when in force, is the supreme law of the land, by Const. U. S. art. 6, and supersedes all inconsistent laws. Techt v. Hughes, 128 N. E. 185.

Texas

The prohibition of the Hague treaty against the confiscation of private property or land does not apply to civil warfare, to render nugatory a confiscatory decree of a Mexican revolutionary general. Terrazas v. Holmes, 225 S. W. 848. Washington

A treaty between United States and foreign country is the supreme law of the land, and provisions in the Constitution of a state which are in conflict therewith must give way to the treaty.

The treaty of November 25, 1850, between the United States and Switzerland (11 Stat. 590) article 5 of which, after providing for ownership of personal property by aliens, makes the same provisions applicable to real estate within the states or cantons in which foreigners are entitled to hold real estate, was manifestly intended not to apply where the holding of land by aliens was prohibited, and therefore that treaty does not conflict with Const. art. 2, No. 33, prohibiting land ownership by aliens who have not declared their intention subject to certain exceptions. State v. Staeheli, 192 P. 991.

Customs Duty Changes.

Under recent by-laws issued by the Department of Trade and Customs, the following are added to the list of articles and material which may be imported at reduced rates of duty if used in the manufacture of specified goods within the Commonwealth :

Minor Articles: Glass Polishing-Oxide of Iron. (Provided security be given by the owner that the material will be used for that purpose only, and that evidence of such use be given to the satisfaction of the Collector within six months after delivery by the Customs, or such further time as the Collector may allow. Cigar and Cigarette Cases-Frames. Sieves used on Asbestos Cement Machines-Woven wire not less than 54 inches.

Machine Tools and Parts: Copper, Electrolytic-Copper plates, known as Stripping or Starting plates of No. 16 or thicker gauge, and of which length and width both exceed 30 inches. Stone and Marble Cutting-Sonte channelers (but not the motive power, engine combination, or power connections, if any, when not integral parts of the exempt machine). Fruit Canning-Syrupers, exhausters, cookers, coolers, slicers, peelers, fillers, scalders and washers, blanching, pineapple corers and sizers, pineapple graters, pineapple eradicators, canning tables.

Miscellaneous-Brass wire scratch brushes (but not the motive power, engine combination or power connections, if any, when not integral parts of the exempt machine).

The above specified "minor articles" and "machine tool and parts" are now admitted (for the purposes specified) free of duty if from the United Kingdom, and at the rate of lo per cent ad valorem if from any other country.

By a recent order of the Minister for Trade and Customs wheels made expressly for and usable only with motor cars shall be classified for tariff purposes under the item applicable to motor car chassis, the order to come into operation as from the 3rd of November, 1920.

The following stocks and dies, when not made wholly of wood, and not being machines, are now dutiable as "manufactures of metal, n. e. i." at the rate of 32 per cent on British and 45 per cent on all others: Dies-Button, lightning, elastic stock; English pattern; solid (round and square); die nuts. StocksElectric stock pattern; lightning pattern and similar types.

New Prohibitions.

A proclamation was issued on December 30, 1920, prohibiting the importation of all goods bearing the word "Bosch".

The Government has prohibited the importation of calcium carbide after December 2, 1920, except under written permit from the Minister of Trade and Customs.

Regulations for Dyes.

The Department of Trade and Customs of Australia has made a ruling by which any shipment to Australia of dyes of foreign origin must be accompanied by the British Customs Specification No. 30, and that prior to shipment a certificate must be obtained from the British Dye Commissioner giving permission for the export of consignment of dyes to Australia. Postponement of Certain Duties.

In the tariff, which came into operation March 25, 1920, provision was made for certain duties to come into operation at later dates.

Advice has now been received from the Department of Trade and Customs that the operation of the deferred duties has been postponed in the case of the following commodities:

Item 136, (D, 2 and F.), plain plate and sheet, and hoop iron and steel deferred to January 1, 1922; item 278 (A), carbonate and bicarbonate of soda, and item 388, metal cordage, postponed to January 1, 1922; and item 397 (D), sporting powder, wads for cartridges, percussion caps, cartridges for military purposes, detonators, empty cartridge cases caped or uncapped, fuse cotton and electrical mining fuse, postponed to January 1, 1922.

Item 278 (A) soda, ash, and item 278 (B), caustic soda, postponed to October 1, 1921. Through September 30, 1921, the duty on bulk soda ash and caustic soda from the United States will be 15 per cent ad valorem. On and after October 1, 1921, the duties will be: Soda ash, 80 shillings per ton, or 45 per cent ad valorem (whichever returns the higher duty) caustic soda, 100 shillings per ton, or 45 per cent ad valorem (whichever returns the higher duty). Item 152 A, pipes and tubes, postponed to January 1, 1922. AUSTRIA.

Surtax on Duties.

Customs duties paid in paper currency were increased to 80 times the pre-war or gold rate from April 15, 1921. BARBADOES.

Removal of Prohibition on Dyes.

The Official Gazetter of the Barbados Islands for October 7, 1920, contains an order in council of September 30, 1920,, which suspends the prohibition on the importation of foreign dyes and dyestuffs. This prohibition was imposed November 20, 1921. BRAZIL.

Government Aid to Importation of Live Stock.

The Department of Agriculture, Industry and Commerce has announced that the Government will aid importers of live stock in importing blooded animals by refunding the charges for freight from the country of origin to Brazil, by the free entry of the animals and by their free transportation into the interior.

BULGARIA.

Modified Regulations for Commerce.

On May 22, 1920, the Bulgarian Food Administration issued its order No. 460, which has as its aim the control of commerce in and with Bulgaria. Those regulations were modified by order No. 626, dated July 8, 1920. By order No. 626 it is declared that "the certification to the invoices, which are issued by representatives or consigness of foreign firms, will be computed at the rate of the National Bank of Bulgaria on the day when sale took place."

The representative of a foreign firm, acting in Bulgaria is, by this order, distinguished from a native importer and from a native merchant who holds goods on consignement for a foreign firm, and such representative is not considered a "first dealer", thus allowing him to sell to a native merchant, who shall then be considered the "first dealer" and enjoy the privileges of such. Paragraph III of this order (art. 25) reads:

"It may be that the exporter is not from the country in which the goods are produced but the country where the goods are customarily stored, etc. In either case, it will not be necessary to present a certified copy of the original factory invoice, but a duly certified invoice must be presented."

In article 26 of order No. 460 the words "If the customhouse is not in a town" should read "If the customhouse is in a town."

Relaxation of Prohibitions.

In a meeting held October 21, 1920, the Council of Ministers passed a decree abolishing all prohibitions on the importation of goods except those contained in the law of November 4, 1918. This law covered articles not of prime necessity. Automobiles, automobile tires, carriages, wagons, etc., metal manufactures, not gilt or silvered, leather boots and shoes and clothing and fabrics not considered luxurious, untrimmed hats, most foodstuffs and raw materials are among the products which may now be imported without a license.

CANADA.

Regulations for Importation of Wool and Hair. The quarantine regulations governing the importation of wool and hair, dated September 27, 1920, do not apply to American domestic wool. Domestic wool originating in the United States may be imported into Canada without disinfection, subect to the provisions of the customs tariff and payment of the sales tax.

Duty on Ships' Equipment.

Appraisers' Bulletin No. 2223, October 21, 1920, gives articles of equipment for ships and vessels made in Canada, and such articles are therefore not entitled to free entry of dutyrunder tariff item 470.

It is not to be considered as a complete list of ships' equipment which is made in Canada, but only represents such articles as have been officially before the department of Customs.

Drawback on Materials for the Manufacture
of Oleomargarine.

The following regulations have been established by an order in council dated November 1, 1920, under the provisions of section 286 of the customs act:

When imported materials, not including machinery, are used on and after September 1, 1920, and prior to September 1, 1921, in the manufacture of oleomargarine as described in the diary industry act, 1914, and amendments thereto, there may be paid a drawback of 99 per cent of the customs duties paid on the materials so used.

Provided, however, the said drawback shall not be paid unless the duty has been paid on the materials so used as aforesaid within 12 months of the manufacture of oleomargarine subject to the following conditions, viz:

(a) The quantity of material used and amount of customs duties paid thereon shall be ascertained.

(b) Satisfactory evidence shall be furnished in respect to the manufacture in Canada of the oleomargarine.

The claims for drawback shall be verified under oath before a collector of customs to the satisfaction of the Minister of Customs and Inland Revenue, in such form as he shall prescribe, within one year after the manufacture of the oleomargarine. The minister may also require in any case the production of such further evidence, in addition to the usual averments, as he deems necessary to establish the bona fides of the claim. Claims for drawback under the above regulations should be made on Form K 151⁄2.

Remission of Excise Taxes on Goods.

According to Customs Memorandum No. 2440-B, of December 20, 1920, by an order in council in effect from December 20, the excise taxes imposed under the provisions of section

19BB of the act to amend the special war revenue act, 1915, are remitted, with the exception of those on the following goods: Confectionery, playing cards, spirituous alcohol, lime and fruit juices, fortified spirits and strong waters, and perfumery and toilet preparations. None of the taxes so remitted shall be collected. The sales tax remains in full force and effect. CEYLON.

Removal of Prohibition on Tea.

Under date of September 30, 1920, the Government revoked the Proclamation of August 8, 1917, prohibiting the importation into Ceylon of tea, whether for local consumption or for transshipment, except under license from the principal collector of customs.

COLOMBIA.

Changes in Duties on Paper and Cotton Yarns.

By a decree of November 20, 1920, printing paper, white or colored, in sheets, not less than 60 by 90 centimeters in size, may be imported into Colombia free of duty if the originat price does not exceed 45 pesos in gold for every 100 kilos (item 1291). When the original price exceeds 45 pesos (item 1292), an import duty of $0.03 per kilo must be paid. There is in addition a surtax of 7 per cent of the duty.

The same decree increases the duties on cotton yearns as follows:

(Item 1424) Bleached yarn for looms and other weaving machines, increased from $0.08 to $0.12 per kilo; (item 1425) unbleached yarn for looms and other weaving machines, increased from $0.05 to $0.09 per kilo; (item 1426) colored yarns for looms and other weaving machines, increased from $0.10 $0.15 per kilo.

COSTA RICA.

New Duty on Matches and Cigarette Paper. According to a decree of June 8, 1920, matches and cigarette paper imported into Costa Rica are now subject to a duty of 50 centimes ($0.23) per kilo of 2.2 pounds. This decree repeals article 7 of decree No. 3, December 14, 1918, which established a Government monopoly on the manufacture and Importation of matches and cigarette paper for national consamption.

CUBA.

Extension of Embargo on Rice.

In accordance with a decree signed by the Chief Executive on March 22, 1921, the prohibition on the importation of rice into Cuba, originally decreed on September 7, 1920, is to remain in force until 80 per cent of the merchantable rice in Cuba at the time of the promulgation of the decree shall have been disposed of. In order to enable the authorities to ascertain the amount of rice in stock and the progress of its disposal, the decree provides for reports on existing stocks of merchantable rice within eight days after the promulgation of the decree and subsequent biweekly reports on sales. The requirement in regard to reports is restricted to holders of merchantable rice in amounts exceeding 500 tons at port of entry. CZECHOSLOVAKIA.

Method of Payment of Customs Duties. From December 1, 1920, all customs duties will be payable in Czech crowns at the following increased rates:

1. Duties leviable, according to the customs tariff "in francs" which have hitherto been paid in Czech crowns plus a surtax of 500 per cent, are now payable in Czech crowns plus a surtax of 900 per cent.

2. Duties leviable, according to the customs tariff, “in crowns with surtax", hitherto paid in crowns plus a surtax of 300 per cent, are now payable in crowns with a surtax of 600 per cent.

3. Duties leviable, according to the customs tariff, “in crowns without surtax" which have hitherto been paid in crowns plus a surtax of 100 per cent, are now payable in crowns with a surtax of 200 per cent.

Removal of Restrictions and Duty on Cotton.

The prohibition against the importation of cotton waste has been removed. License applications will be granted automatically. These commodities will be admitted free of duty. A manipulation fee of one-half per cent is the only payment required. DENMARK.

Restricted Imports.

The following goods may be imported only under a license: Sugar and all products containing sugar; live geese, spirits (imported only by special license from the customs authorities, Generaltolddirectoratet, Copenhagen); wheat and rye and products of the same; and arms.

Removal of Restrictions on Fireworks and Certain

Chemicals.

The prohibition against the importation of fireworks and the following raw materials has been removed by a decree of December 28, 1920: Nitric, sulphuric, oxalic, and carbolic acids nitrates (nitrous salts), chlorates (chlorous salts), perchlorates oxalates (oxalic salts), glycerine, naphtalene, aniline, benzoline, toluol, cymol, sulphur, mercury, phosphorus, iodine, metallic potassium and sodium, aluminum powder, calcium phosphide, sulphuric antimony, oxide of lead, and manganese. DOMINICAN REPUBLIC.

Restriction on Textiles.

A decree has been issued by the Government by which no individual, firm or corporation may import textiles into the Republic unless this individual, firm or corporation imported textiles into the country during the past year. ECUADOR.

Drug Regulations.

By a law of November 7, 1920, published December 1, 1920, regulating apothecaries' shops and drug stores in Ecuador, the following provision were made with regard to drugs, medicines, etc:

Art. 23. The importation of drugs, chemical products, serums and vaccines will be permitted only in the case of apothecaries' shops, drug stores, hospitals, asylums, clinics, and boards of health. Industrial establishments may, however, import the materials necessary for the business in which they are engaged. FINLAND.

Changes in Duties.

The Government has been authorized to increase by not more than 200 per cent during 1921 the duties fixed by the tariff of 1919 for certain articles of luxury on which an export embargo has been temporarily placed. The duty on most woolen textiles will be increased 100 per cent. On most other articles the increase will be 200 per cent over the 1919 rates, as was the case during 1920. Tea, lard, bacon, most cereals, agricultural machinery, and tools various classes of cotton textiles, and certain kinds of footwear will not be affected by this increase in duty.

Removal of Restrictions.

Beginning April 1, 1921, all import restrictions are abol

ished. FRANCE.

Restoration of Increased Duties on Railway Materials. A decree of December 18, 1920, published in "Le Journal Officiel" for December 27, reestablishes, with the corresponding coefficient, the import duty on rails, fishplates, bridges, and parts thereof which was suspended by decree of November 30, 1914, and March 3, 1915, in cases where such materials were required for repairs on railways, etc, necessary for national defense. Removal of Coefficients for Certain Paper.

A decree of January 11, 1921, published January 18 in "Le Journal Officiel", removed the coefficient of increases of the import duty (item ex461) on paper (other than so-called fancy paper), machine made, weighing above 30 grams per square meter, and fancy white coated paper.

Increased Coefficients for Duty.

A decree of February 2, 1921, published in "Le Journal Officiel" for February 4, establishes coefficients for increasing the duty on the following commodities: (Item 033) Calcium carbide, coefficient, 4 (item 349) common glass, coefficient, 5 (item 349 bis) extra white or colored glass, coefficient, 4 (item 349 quat) wired glass, coefficient, 5 (item ex 351) common window glass, panes not exceeding 50 square centimeters in area, coefficient, 5 same, over 50 centimeters in area, coefficient 3.5 (item 461) paper (coefficient, 3, (item 462) cardboard in sheets or rough plates, coefficient 3, (item 594) molding of wood, coefficient, 3, (item 594bis) wooden frames, coefficient, 3.

"Le Journal Officiel" for January 13 and 14, 1921, contains two decrees of January 11. Among the most important changes in coefficients made by these decrees are the following:

Chemicals: (Item 0151) oxides of lead, minium and litharge 2.4, other oxides of lead, 1.5, (item 0175) zinc oxide, 2.4, (item 0178) lithopone, 2, (item exo196) distilled glycerin, 2.5, items 0253 to 0339 of the chemical schedule, 3. The coefficient for vinegar, other than perfumed, is 9; on tulles and trimmed straw hats it is 6, while on cotton thread, cotton knit goods, certain furniture, shaped and trimmed felt hats, it is 5. varnish and varnish paints, ochers and earths, bobinet tulles, bent-wood furniture, certain untrimmed straw hats, certain felt fabrics, and untrimmed felt hats, penholders and parts (including fountain pens), metal crayon and pencil holders and certain

On

small wares (taletterie) the coefficient was raised to 4. There are a number of less radical increases on other arti

cles.

License Requirements for Petroleum.

A decree of May 8, 1921, fixes the conditions under which import licenses for petroleum may be obtained. The importers must agree to purchase from Government stocks quantities equal to their imports and from reserve stocks at the Government's disposal quantities equal to one-fourth of their total imports during the 12 preceding months.

Changes in Duties on Ball Bearings.

"Le Journal Officiel" for April 3, 1921, contained a decree, April 1, which provided for a change in the French duty on balls for ball bearings and ball races, dutiable under item 633 sept of the customs tariff. The new rates are 70 per cent ad valorem under the general tariff and 35 per cent under the minimum. Goods proved to have been shipped direct to France prior to the publication of the decree may be admitted at the rate of duty formerly in force.

Changes in Duties.

A decree of March 29, 1921, published in "Le Journal Officiel" for April 3, contains lists of increases in the general import tariff items. The maximum difference between the minimum and general rates on articles affected is increased to 300 per cent GAMBIA.

Hops are prohibited from importation into the United Kingdom under the ministry of food (continuance) act, 1920 subject to the granting of special import licenses "for such quantities as Minister decides are necessary."

All hops imported must, upon arrival in the United Kingdom, come under the jurisdiction of the hop controller, who has instructed all collectors of customs to retain, under embargo, all hops arriving from abroad. Release can only be obtained under special license. Arrivals of hops under the controllers license must be immediately reported in writing by importers to the hop controller, who will thereupon instruct the importer to which licensed warehouse they are to be forwarded, and a permit will be granted the importer to forward them. The owner or occupier of the licensed warehouse must immediately notify the controller of each arrival, giving full particulars as to the country of origin, quantity, year of growth, number of import license, and must hold such hops until authorized to remove them.

The registration fee for imported hops is 5s per pocket, or bale of 2 hundredweight or under, and 10 s for those exceeding 2 hundred-weight, and must be paid on application for license to clear.

Further licenses to import will not be issued at present, and "in the event of foreign hops arriving in this country which have not received the controller's special import license, the controller holds wide power to deal with them at his discretion".

Rulings of Food Ministry.

The Food Ministry has removed all restrictions on the importation and sale of apples and canned salmon from March 31, 1921.

A general license has been issued by the Food Ministry permitting shipments of bacon to the United Kingdom on private account from March 17, 1921, in the case of ports outside of Europe, and from March 31 in case of European ports.

To enable importer to make arrangements for supplies a general license has been issued authorizing from February 15 forward dealings in bacon on private account for shipment o and after the above date.

The Food Minister issued an order December 30, 1920, which provides that no person shall sell or offer or expose for sale, whether by wholesale or retail, as fresh or new laid eggs or under any description of which the words "fresh" or "new laid" form part, any eggs which have been imported into the United Kingdom, unless the word "imported" or the name of the country of origin also forms part of the description.

The Ministry of Food has issued a notice on March 10, 1921, effective at once, that licenses for the importation of fresh