vestigation then proved that the raising of gophers by citizens of the State for the procurement of bounties had become a regular industry. A like experience in British India is also worthy of note. Some years since the Government, with a view of arresting the mortality among its native population from the bites of poisonous serpents, offered a bounty on their proved destruction; when it was found that for the sake of obtaining the bounties the cultivation of the "cobra" and other like snakes had been actually entered upon.
Third. The sphere of taxation should be limited to persons, property, and business exclusively within the territorial jurisdiction of the taxing power. It would seem to be in the nature of a self-evident proposition, although in fact it is by no means so regarded, that the power of every state or government to tax must be exclusively limited to subjects within its territory and legal jurisdiction. "All subjects," says Chief-Justice Marshall, in giving the opinion of the Supreme Court in the case of McCullough vs. Maryland (4 Wheaton, 431), "over which the sovereign power of the state extends are objects of taxation; but those over which it does not extend are, on the soundest principles, exempt from taxation." And again, "the sovereign power of the state extends to everything which exists by its own authority or is introduced by its permission." "Every nation," says Wheaton, "possesses and exercises exclusive sovereignty and jurisdiction throughout the full extent of its territory. It follows, from this principle, that the laws of every state control, of right, all the real and personal property within its territory. The second general principle is, that no state can, by its laws, directly affect, bind, or regulate property beyond its own territory. This is a consequence of the first general principle; a different system, which would recognize in each state the power of regulating persons or things beyond its territory, would exclude the equality of rights among different states, and the exclusive sovereignty which belongs to each of them." (Wheaton's International Law, chap, ii, § 2; Fœlix International Prisé,§§ 9 and 10.) And in a decision of more recent date (State Tax on Foreign-held Bonds, 15 Wallace, 306, 328), the United States Supreme Court said: "The power of taxation, however vast in its character and searching in its extent, is necessarily limited to subjects within the jurisdiction of the state. Property lying beyond the jurisdiction of the state is not a subject upon which her taxing power can be legitimately exercised. Indeed, it would seem that no adjudication should be necessary to establish so obvious a proposition."
The principle under consideration has also been made the subject of adjudication by the United States Supreme Court in a case of historic as well as of legal and economic interest. In Septem-
