It is quite true that the appellant could not assert any title to a farthing of the dividend he received until it was declared. Until that moment it was part of the company's assets, although as profits the whole fund from which it came was available for distribution if the company thought fit to distribute it. But that, though true, is not the complete truth. Moulton L.J., in Gramophone and Typewriter Ltd. v. Stanley[6], states the position in a few words. He says: - "The profits of the corporation are not profits of any business carried on by him in a foreign country, because the individual corporator does not carry on the business of the corporation. He is only entitled to the profits of that business to a certain extent, fixed and ascertained in a certain way depending on the constitution of the corporation and his holding in it." If the argument of the appellant is sound and sufficient, then if an English company is formed for working gold, silver or copper mines in Australia, with its registered office and directorate in London, and draws every penny of its wealth from this Commonwealth, the members among whom it is distributed do not derive in any degree from an Australian source, but wholly and exclusively from an English source. That strikes one as a strange and unnatural conclusion. Is there any doctrine of law compelling its acceptance? We are not aware of any. The argument treats the income of the individual as necessarily springing from the one source, an indivisible source, either the place of declaration of dividends or the locale of the company, its principal residence, where it is said every individual corporator's "share" is situated. But that, in the first place, is quite contrary not merely to the language and scheme of the Act, as we have quoted it, but also to the general view of the subject as expressed by the Court of Appeal in Gilbertson v. Fergusson[7]. The Imperial Ottoman Bank was a Turkish corporation, and carried on business at Constantinople, London, Paris and elsewhere. It resided at Constantinople. It made profits in London, which was only a branch. It also made profits in Turkey. Dividends were declared at general meetings, which were held in London[8]. The amounts necessary to pay English shareholders were held by the London agency. The question was as to the liability of the agency itself (1) for the English profits and (2) for the amount of dividends declared and payable to individual shareholders in England. The basis of the second claim was that the individuals were entitled to the dividends and that the agency were intrusted with the payment of them. Brett L.J.[9] recognized that from a general standpoint - that is, within the Bank - the Bank's profit was "one profit and one profit only, and which is to be divided in dividends." "But," said the Lord Justice, "when one comes to apply the income tax to it the Statute obliges one to divide that profit into two. Each person resident in England, who is to receive a dividend out of that profit, receives part of such dividend in respect of profit arising from business carried on in England, and part in respect of profit arising from business carried on in Turkey." Cotton L.J. says[10]: - "When a corporation carries on its business in more than one place, the dividends are not a share of the profits arising on the transactions in any one place, but of the profits made by the entire business of the corporation, and unless for any purpose it is necessary to analyse the source from which the dividends arise, it must be taken that the dividends are not paid out of any particular fund, but out of the sum which on the whole transactions of the corporation is the profit during the year." The Lord Justice[11] proceeded to say what is very important to remember is that sec. 10 of the Act 16 & 17 Vict. c. 34, under which the question arose, was not a clause imposing on the Bank, or the English agency on behalf of the Bank, a liability to pay duty in respect of profits coming to them, but was "a mode of collecting the duty which would be chargeable on the persons who are to receive the dividends." So the decision is very much in point here. All through the judgment we find that the Lord Justice speaks of the dividends being "in respect of profits," and the Court held they were divisible according to their source. That is quite inconsistent with the argument that the place where the profits are earned by the company cannot be considered the place of the source of the shareholder's dividend, and is quite opposed to the view that under the English law, at all events, it is the place of the "share" or of the declaration of dividend that constitutes the locality of the source. We know of nothing that differentiates the English law from the Commonwealth law in this respect.