City of Houston v. Morgan Guaranty International Bank

OPINION

DUGGAN, Justice.

This is an appeal from a summary judgment enjoining the collection of city and school district ad valorem taxes on shares of a federally-chartered Edge Act corporation. Although the corporation maintains a branch office at the tax situs, its shares are wholly owned by a non-resident foreign corporation which maintains its home office in Florida.

Appellees, Morgan Guaranty International Bank (“MGIB”) and Morgan Guaranty Trust Company of New York (“MGT”), filed suit against appellants, the City of Houston (“City”), the Houston Independent School District (“HISD”), their…