continent it was the same. were at first levied only on land. But at the close of the twelfth century, the land tax had already been merged into the general property tax-or, as it was called, the tax on property in possessionibus, agris, domibus, censibus et rebus quibuscunque.1 In other towns it was called simply a tax of so much per posse or pro bonorum facultate.2 In most of the German towns also the general property tax was combined with the poll tax.3 And in the Swiss cantons the tax was even called the Hab-, Gut-, und Kopfsteuer. The only distinction between England and the continent was that in England the property tax remained for centuries the sole local tax, while in France and Germany we find in addition the local excises or octrois. But for a long time the general property tax was the measure of the individual's capacity.

In the German towns the taxes

The general state taxes followed in the wake of the municipal taxes. Already in 1166 a tax on movables was levied throughout almost all Europe for the purposes of the first crusade.5 But the first real general property tax, into which all the older contributions from the land soon merged, was the Saladin tithe of 1188 on the occasion of the second crusade. In England from this time on the grants of rents and movables (de redditibus et mobilibus, or, as they were sometimes called, de redditibus et catallis) became more and more common until they finally superseded the older methods of securing revenue. The fractional parts of the property granted varied from a fortieth (1201) to a fourth (1193). But from 1290 it became customary to tax the nobility and clergy only two-thirds as much as the In 1334 the proportion was fixed as the fifteenth and the tenth. This meant a higher nominal rate for movables

commons.

1 Zeumer, Die deutschen Städtesteuern . . . im XII. und XIII. Jahrhundert, pp. 86-89.

2 Christian Meyer, Augsburger Stadtbuch, pp. 75, 313.

3 Schönberg, Finanzverhältnisse der Stadt Basel im XIV. und XV. Jahrhundert, S. 134.

4 Blumer, Staats- und Rechtsgeschichte der schweizerischen Democratien, II, 295 et seq.

5 Sinclair, History of the Public Revenue, I, 88.

than for land. But in reality there was a substantial equality of taxation, because the assessment of chattels was not strictly enforced. This is apparent from the dissatisfaction shown with the tax of 1275, when the people were assessed ad unguem, i.e. up to the full value of their movables.1 In the succeeding grants the old easy practice was resumed. As the tax on lands, however, could be levied on actual rents, it was not apt to be so leniently assessed. Thus a substantial equality was probably reached.

Just as the tallages merged into the fifteenths and. tenths in England, so in France the feudal charges on the land developed into the general property tax, which however still retained the old name taille. The ordinances of 1254-56 attempted to regulate the assessment, and provided that movables should be charged only half as much as immovables.2 France thus endeavored to attain by law what England effected by custom. During the fourteenth century the taille came to be the chief direct tax, and in 1439 it was made a permanent annual tax. In Germany also the imperial and state direct taxes, in so far as there were any, took the form of the general property tax. The Bede, the gemeiner Pfennig, the Landschoss, the Landsteuer, etc., all followed the example of the local property tax.

In the Italian republics the commonwealth was at first supported by the general property tax. In Milan, under the name stima e catastro de beni, it is found as early as 1208, and afterwards was levied with such severity that the assessment book was known as the libro del dolore. In Genoa it was called

1 Dowell, History of Taxation and Taxes in England (2d ed.), I, 68.

2 Clamageran, Histoire de l'impôt en France, I, 264.

3 At first a feudal land payment; Hüllmann, Deutsche Finanzgeschichte des Mittelalters, p. 133.

Lang, Historische Entwickelung der teutschen Steuerverfassungen seit der Karolinger, p. 182.

Schmoller, Die Epochen der preussischen Finanzpolitik, in Jahrbuch für Gesetzgebung, Verwaltung und Volkswirtschaft, I, 35, 42.

• Hoffmann, Geschichte der direkten Steuern in Baiern vom Ende des XIII. Jahrhunderts, pp. 11, 17, 39.

7 Carli, Relazione del censimento dello stato di Milano, in Custodi's Scrittori classici italiani, parte moderna, XIV, 184, 185.

colletta.1 In Florence it was known as estimo and played an important role in politics.2 And finally we find in the Netherlands from the earliest times the general property tax known as the schot or the tenth, etc., on bezittungen (possessions) — a tax of especial interest because it served as the model of the general property tax in the New Netherlands.

3

The general property tax thus existed throughout all Europe. It was moderately successful because well suited to the period. Although involving an inquisitorial search into every article of the scanty medieval stock, as can readily be seen from the detailed schedules of assessment still in existence, the tax was levied chiefly on tangible, physical objects not capable of easy concealment. With the exception of countries like France, where the tax was emasculated by the system of exemptions, it resulted on the whole, during this early period of society, in a tax fairly proportional to the individual faculty. There was a general property tax because there was a very slight differentiation of property.

Before long a change set in. In England the fifteenths and tenths changed from a percentage to an apportioned tax. Every locality had to raise a definite lump sum. But the old methods

of assessment fell into disuse. Each town and county made its own arrangements and treated personal property with such leniency that the total product of the tenth and the fifteenth continually decreased. The consequence was an attempt on the part of the crown to supplement the old tax by a new general property tax, called the subsidy. The early efforts met with failure. Finally, in 1514, the first general subsidy was granted, as a tax of sixpence in every pound of property. The pound rate was afterwards fixed at four shillings on lands, and two shillings eight pence on goods. But the subsidy went through precisely the same development as the fifteenth and the tenth.

1 "Le imposte straordinarie si possono di questa epoca [1252] comprendere in una sola, la colletta." Canale, Storia dei Genovesi, I, 318 (edition of 1844).

2 Villani tells us that it was levied on "cio che chiascuno havea di stabile e di mobile e di guadagno." Istorie fiorentine fino al anno 1348, book x, chap. 17 (vol. vi, p. 26 of Milan edition of 1803).

3 Engels, De Geschiedenis der Belastingen in Nederland, pp. 60–65.

At first really a percentage tax, it was soon practically converted into an apportioned tax of a stated lump sum. No assessment of the districts took place, but every locality was supposed to pay the same sum year after year. All the growing wealth thus entirely slipped out of the lists. Exemption after exemption was made, and personal property was so loosely assessed that the total yield continually declined. The most arbitrary methods were employed. Only the old "subsidymen" were taxed; allowances were made in a multitude of cases; and the assessments of personalty were so low and partial that the subsidy became a perfect farce. As Bacon said, "the Englishman is master of his own valuation."1 Sir Robert Cecil stated in 1592 that there were not five men in London assessed on their goods at £200; and Sir Walter Raleigh stated in 1601 that "the poor man pays as much as the rich.” 2 Although nominally a general property tax, the subsidy thus came to be levied chiefly on the land, and became an unequal land tax; so unequal that it finally disappeared in 1663.

Under the Commonwealth an attempt was made to revive the general property tax, under the name of commonwealth monthly assessments. The improvement was so marked that the old subsidies were completely abandoned and replaced by the assessments. But the reform was short-lived and the assessments of personal property continually diminished. Sir William Petty, after complaining of this, nevertheless held, as do some of our rural legislators to-day, that "assessments upon personal estates, if given in as elsewhere upon oath, would bring that branch which of itself is most dark to a sufficient clearness." 4 After the Revolution the tax was levied as the so-called property tax. By its terms it was assessed on the persons possessed of personal property, real estate or public offices or positions of profit.

1 And, he adds, "the least bitten in purse of any nation in Europe."

2 Report on Public Income and Expenditure, 1869, II, 415.

8 Tayler, The History of the Taxation of England, p. 21.

...

* Petty, Verbum Sapienti; or . . . the method of raising taxes in the most equal manner, p. 17. (Appended to the Political Anatomy of Ireland, edition of 1691.) 5 4 William III, cap. 1.

54

But the yield decreased

And it was at first a percentage tax. so enormously that Parliament in 1697 fixed the sum a rate should produce, i.e. it became an apportioned tax of stated amount. Moreover, the difficulty of assessing personalty and the impossibility of reaching intangible property were now so apparent that the tax became almost exclusively a land tax. The name itself was first applied in 1697. The "annual land tax" of England (which since 1798 has become simply a redeemable rent charge on land) was thus intended to be a general property tax and for a long time continued to be so legally.1 The provision taxing personal property continued to exist on the statute book until 1833, and the clause taxing public offices and positions of profit was not finally repealed until 1867. The year before its repeal it had yielded the enormous sum of £823!2 Such was the ludicrous result of the attempt to maintain mediæval customs. The general property tax, which had started out as a land tax, reverted in name as well as in fact to its earliest form.

In

In other countries the history of the property tax is identical. In France the taille was of two kinds, the taille réelle which was levied in name as well as in fact only on lands in the pays d'état, and the taille personnelle, nominally a general property tax levied in the pays d'élection, i.e. the greater portion of France. reality the taille personnelle was levied only on the families or households of the non-nobles (roturiers), and it practically became a land tax like the taille réelle; for the wealthy owners of personalty soon acquired the same privileges as the nobility. Vauban tells us that the taille as a tax on movables was assessed only on the poorest classes. Sully, indeed, endeavored in 1660 to restore the principles of the general property tax and to assess

1 Adam Smith, Wealth of Nations, book v, chap. ii: "By what is called the land tax, it was intended that stock should be taxed in the same proportion as land." (Rogers' ed. II, 553.)

2 Report of the Commissioners of Inland Revenue, 1867.

3 "En résumé la taille était un impôt territorial qui n'atteignait que les propriétaires les plus pauvres du royaume, et une taxe mobilière qui portait exclusivement sur les classes les moins riches de la société." Dîme Royale, p. 32 of Daire's edition.