382 PARLIAMENTS OF THE DOMINIONS [PART III 
converted into cash.! It may be noted that the Transvaal 
Legislature, in Act No. 28 of 1909 regarding death duties, 
insisted on taxing shares in mining companies, wherever 
registered, carrying on their business in South Africa, though 
the persons owning these shares were not domiciled in 
South Africa: it treats them as assimilated to land as being 
the proceeds of such land; but the provisions, though not 
technically ultra vires, are such as could hardly be held to 
be binding in England if an attempt were made to compel 
transfer of shares without payment of duty, though of course 
the Jaw could require all transfers to be local on pain of 
exclusion from transacting business locally at all. 
3 2. THE RECENT INTERPRETATION OF THE DOCTRINE 
The general doctrine has been of late at once asserted and 
more closely examined by several important judgements of 
the Privy Council, the High Court of Australia, and the 
Supreme Court of New Zealand. 
The most important of these cases is unquestionably 
Macleod v. Attorney-General for New South Wales? In that 
case the interpretation of s. 54 of the Criminal Law Amend- 
ment Act, 1883, of New South Wales was brought into question. 
That section enacts that ‘ whosoever being married marries 
another person during the life of the former husband or 
wife, wheresoever such second marriage takes place, shall 
be liable to penal servitude for seven years’. A Court of 
Quarter Sessions at Sydney in New South Wales convicted 
Macleod for bigamy. It was contended for the appellant 
that the Court had no jurisdiction to try the appellant at all. 
The Act under which he was tried must be interpreted as 
relating to offences committed within the jurisdiction of 
the local Legislature by persons subject at the time of the 
* The power to tax is recognized by s. 20 of the Finance Act, 1894, and 
the attempt to deny the power to tax property outside in the case of 
a domiciled person failed in the case Re Tyson, (1900) 10 Q. L. J. 34; 
Harrison Moore, Commonwealth of Australia®, pp. 335-7. But the effect 
of such laws elsewhere is a different matter 5 cf. Spiller v. Turner, [1897] 
L Ch. 911; Municipal Council of Sydney v. Bull, [1909] 1 K. B. 7. See 
Dicey, Conflict of Laws? pp. 746 seq. 2 [18917 A. C. 455.