312 THE FISCAL PROBLEM IN MISSOURI

the yield could be increased. For example, the dividends received
 from domestic corporations and foreign corporations
doing businessin the state might be included in taxable income
in their entirety instead of the extent provided at the present
time. Their inclusion is justified on the basis of the ability
theory and is in accordance with the provisions of the Model
State Income Tax Law recommended by the National Tax
Association. Precedents for their inclusion exist in several
income tax states. The inclusion of all dividends received
would make it possible to include the dividends received from
national banks in the personal income tax base without
foregoing the taxation of the banks at the corporation income
tax rate. The federal statute that provides the several waysin
which national banks may be taxed contains a proviso to the
effect that, in addition to a tax on or measured by the net
income of the bank, the dividends of banks located within
the state may be taxed to the recipients to the same extent
that the dividends of domestic corporations are taxed, and
that the dividends of national banks not located within the
state may be taxed to the same extent that the dividends of
other foreign corporations are taxed. Such a change in the
personal income tax base, however, would only mean the
uniform taxation of national bank and other dividends, and
it would not eliminate to any extent the difficulty of taxing
the national banks in a way that would take cognizance of
the small proportion of tangible taxable assets to net capital
assets, as compared with manufacturing or other corporations.
 The taxation of bank stock at general property tax
rates makes it possible to take account of this difference, but
that method of taxing national banks will not be possible if
intangible property is exempted from the general property
tax.
Although at some future time the inclusion of all dividends
of domestic corporations and foreign corporations doing
business in the state in the income tax base may be desirable,
their inclusion could hardly be justified at the present time,
for the reason that the uncovering of the income from other
intangibles will no doubt be a gradual process extending
over a period of years, even though the administrative machinery
 is improved. To tax domestic corporations on their