Metropolitan Life Insurance v. Rouillard

The plaintiff is a mutual life insurance company duly licensed to transact business in this state. The defendants are the Insurance Commissioner and the State Treasurer.

Section 60 of chapter 275 of the Public Laws provides that every foreign life insurance company shall pay annually to the State Treasurer “a tax of two per cent upon the gross premiums received by it from residents of the state” during the year, “less payments to residents of this state on account of death losses paid within the year.” The term “gross premiums received by it” is defined by the succeeding section (originally…