Western & Southern Life Ins. Co. v. State Bd. of Equalization of Cal.

California imposes two insurance taxes on insurance companies doing business in the State. A premiums tax, set at a fixed percentage of premiums paid on insurance policies is*650sued in the State, is imposed on both foreign and domestic insurance companies and a “retaliatory” tax, set in response to the insurance tax laws of the insurer’s home State, is imposed on some foreign insurance companies. This case presents the question of the constitutionality of retaliatory taxes assessed by the State of California against appellant Western & Southern Life Insurance Co., an Ohio corporation, and paid…