In other words, the principle was declared that the government, by its very nature, benefits the citizen and his property, wherever found, and therefore has the power to make the benefit complete. Or, to express it another way, the basis for the power to tax was not and cannot be made dependent upon the situs of the property in all cases, it being in or out of the United States, nor was not and cannot be made dependent upon the domicile of the citizen, that being in or out of the United States, but upon his relation as a citizen of the United Sates, and the relation of the latter to him as a citizen. The consequence of the relations is that the native citizen who is taxed may have domicile, and the property from which his income is derived may have situs, in a foreign country, and the tax be legal, -- the government having power to impose the tax. [George W. Cook v. Galen L. Tait, 68 L.Ed. 895, 898] [265 U.S. 47 (1924) (emphasis added)] # # #
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Cook v. Tait