EFTA Document EFTA01457974

property, states in part: 'Moneys, credits, securities and other intangible personal property within the state not employed in carrying on any business therein by the owner shall be deemed to be located at the domicile of the owner for purposes of taxation (italics added]." In other words, the opinions reflect Tax Department policy that doesn't necessarily square with the literal language of the underlying law. Stated differently, the opinions are designed to have a chilling effect, and see