Rowe v. Braden

The question, for decision in this case, broadly stated, is whether the state of Ohio has the power and authority under the so-called “Intangible Tax Law,” Section 5323 and related sections of the General Code (114 Ohio Laws, 714), to tax the equitable, beneficial interest of a resident beneficiary under a trust the corpus of which is located outside this state and the trust held by a nonresident trustee.

In a consideration of the questions involved it is essential to give a brief summary of the sections relevant to the issue. The portions of the statutes applicable are as follows:

Section…