In  other   words,  the  principle  was  declared  that  the
government, by  its very  nature, benefits  the citizen  and  his
property, wherever found, and therefore has the power to make the
benefit complete.   Or,  to express it another way, the basis for
the power  to tax  was not  and cannot be made dependent upon the
situs of  the property  in all  cases, it  being in or out of the
United States,  nor was not and cannot be made dependent upon the
domicile of  the citizen,  that being  in or  out of  the  United
States, but  upon his  relation as a citizen of the United Sates,
and the  relation of  the latter  to  him  as  a  citizen.    The
consequence of  the relations  is that  the native citizen who is
taxed may  have domicile,  and the property from which his income
is derived   may have situs, in a foreign country, and the tax be
legal, -- the government having power to impose the tax.

             [George W. Cook v. Galen L. Tait, 68 L.Ed. 895, 898]
                            [265 U.S. 47 (1924) (emphasis added)]


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Cook v. Tait