Cooper-Jarrett, Inc. v. Porterfield

Ohio exacts a franchise tax equally against all corporations, both foreign and domestic, operating within its borders, upon three alternative occasions:

1. For the privilege of doing business in this state;

2. For owning or using a part or all of its capital or property in this state; or

3. For holding a certificate of compliance with the laws of this state authorizing it to do business here during the calendar year in which the fee for such certificate is payable. Section 5733.01, Revised Code.

By virtue of the federal Constitution, the appellant corporation engages in its admittedly wholly…