The physical power to get the money does not seem to me a test of the right to tax. Might does not make right even in taxation. To hold that what the use of official authority may get the state may keep, and that if it cannot get hold of a nonresident stockholder it may hold the company as hostage for him, is strange constitutional doctrine to me.
International Harvester Co. v. Wisconsin Dept. of Taxation, 322 U.S. 435, 450 (1944) - Judicial opinions