mines; while Alabama and Missouri had a general limit of ten million dollars.  The general tendency is clearly to have no limitation whatever.  Commonly only a nominal proportion of the capital stock is to be paid in before the company begins business, but the stockholders are always liable to creditors for the amount unpaid.  As already remarked, stock may usually be paid up in property, labor, or services, or, indeed, any legal consideration; and though most States provide that such property, etc., shall be taken at its actual cash value, such laws, except in Massachusetts, are not believed to be effectual.

[Footnote 1:  A valuable report on this subject, brought down to 1903, prepared by F.J.  MacLeod, of Massachusetts, will be found in the “Report of the Committee on Corporation Laws,” above referred to, at pp. 207-295.]

[Footnote 2:  MacLeod, pp. 165-166.]

[Footnote 3:  MacLeod, p. 169.]

That stockholders are individually liable to the extent of the unpaid balance on their stock is merely a statutory statement of the ordinary rule in equity.  It is, therefore, law without statute.  Apparently only Indiana and Kansas now impose a double liability, the law in Ohio having been recently altered by constitutional amendment.  In several States, however, they are liable for debts due for labor; in California they are absolutely liable for such proportion of all liabilities of the corporation as their stock bears to the total capital stock, while in Nevada they are expressly exempted from any liability whatever.

We can trace two other decided tendencies in recent legislation about corporations.  First, the increasing effort to bring about publicity of all such matters as well as of the annual books and accounts, well exemplified in the Massachusetts statute; second, the usual strong prohibitions against consolidations to permit trusts or contracts to further monopoly.  There has also been a still more recent line of legislation to prevent corporations from holding stock in other corporations, or, at least, in competing companies; and to prevent alien corporations from holding land.[1] Under the strict common law no corporation could own or hold stock in another corporation or in itself.  This has been completely departed from in practice in this country, and though not affirmatively recognized in most statutes—­the Massachusetts statute, for instance, carefully avoids providing that the corporation may own stock in other companies—­yet the practice has been universally ratified by the courts, if not by the implications of legislation.  This new tendency to forbid it therefore is merely a return to common-law doctrine.  Thus,[2] in 1903 only five States—­Connecticut, Delaware, Maine, New Jersey, and Pennsylvania—­provided generally that a corporation might own stock in another corporation; two States—­Indiana and Minnesota—­so provided as to manufacturing or mining companies.  In New York, Ohio, and other States, a corporation