8  The  1913  Law  which  was  repealed  by  the  1916  Law,  imposed
a  tax  on  the  net  income  of  non-resident  aliens  "from  all  property
owned  and  every  business,  trade  or  profession  carried  on  in  the
United  States."  This  language  was  held,  under  two  opinions  of
the  Attorney  General,  not  to  include  interest  or  dividends  received
hy  non-resident  alien  investors  from  domestic  corporations,  but
on  March  21,  1916  the  Treasury  Department  reversed  this  holding
and  thereafter  claimed  the  tax  from  non-resident  aliens  on  the
classes  of  income  in  question.  T.  D.  2313.  In  DeGanay  v.  Lederer,
239  Fed.  568,  the  District  Court  held  a  non-resident  alien  taxable
on  such  income  if  the  stock  certificates  and  bonds  were  kept  in
this  country,  as  then  they  acquired  a  situs  here  for  purpose  of
the  income  tax.  The  language  of  the  1916  Law  expressly  includes
ouch  income,  regardless  of  whero  the  securities  may  be  kept.
