dissenting.
I think that the exemption, from the tax, of net income from money loaned within the state at not more than 5%, like the exemption of income from dividends of *437corporations earned within the state, does not deny equal protection or infringe any privilege or immunity of citizens of the United States, and that the judgment should be affirmed in its entirety. Unless the constitutional validity of the exemptions is to turn upon the ground that we approve laws enacted to avoid taxing the same economic interest twice, but disapprove those to encourage residents to invest their funds at home, it would seem that the considerations which have led to upholding the one exemption would not admit of condemning the other. See Southwestern Oil Co. v. Texas, 217 U. S. 114, 127.
1. It is not denied that the effect of both exemptions is to place a burden on income derived from sources or investments made without the state which they do not place on income derived from like sources or investments made within it. But that affords no ground for saying that either is invalid. The equal protection clause does not forbid inequalities in state taxation. A state may select the objects to be taxed and selection, which is but the converse of exemption, involves the imposition of a tax burden on some which is not placed on others. As this Court has repeatedly held, inequalities resulting from the singling out of one particular class for taxation or exemption, regardless of the reason for the choice, or even if there is no discernible reason, are not to be pronounced invalid where there is no clear indication that the purpose or effect is a hostile or oppressive discrimination against particular persons or classes. American Sugar Refining Co. v. Louisiana, 179 U. S. 89; Board of Education v. Illinois, 203 U. S. 553; Beers v. Glynn, 211 U. S. 477; Southwestern Oil Co. v. Texas, supra; Quong Wing v. Kirkendall, 223 U. S. 59; Citizens Telephone Co. v. Fuller, 229 U. S. 322; Heisler v. Thomas Colliery Co., 260 U. S. 245; Lawrence v. State Tax Comm’n, 286 U. S. 276; Concordia Fire Insurance Co. v. Illinois, 292 U. S. 535.
*438The end sought by the classification is of significance in passing upon the constitutionality of the tax only insofar as it serves to show that the discrimination is not invidious. If it appears or may fairly be assumed that it is for the purpose of promoting a permissible public aim, it cannot be condemned because one class must pay a tax which another does not. Where the public interest is served one business may be left untaxed and another taxed, in order to promote the one, American Sugar Refining Co. v. Louisiana, supra; Heisler v. Thomas Colliery Co., supra; Aero Mayflower Transit Co. v. Georgia Commission, 295 U. S. 285, or to restrict or suppress the other, Magnano Co. v. Hamilton, 292 U. S. 40; Fox v. Standard Oil Co., 294 U. S. 87; Quong Wing v. Kirkendall, supra; Singer Sewing Machine Co. v. Brickell, 233 U. S. 304; Alaska Fish Co. v. Smith, 255 U. S. 44, 48. But it is not necessary to go so far to support the present exemption. There is no serious contention that its purpose or effect is to suppress the lending of money without the state or to injure appellant or his fellow residents of Vermont who may prefer to invest their funds elsewhere. Nor can it be said that the exemption was not granted in furtherance of a permissible state policy, which was the legislative objective rather than an invidious discrimination against appellant and others similarly situated.
It seems to be conceded that if the statute had placed upon the tax gatherers the burden of ascertaining whether money loaned within the state is invested in property there, and had limited the exemption to money so loaned and invested, the tax would be sustained because of the benefit which would result from the increase of wealth in the state and the enlarged opportunity to obtain additional revenue. The attack is thus narrowed to the single objection that there are exempted loans, some of which, although made within the state, are or may be withdrawn and used elsewhere. It is assumed that money thus loaned *439and withdrawn can be of no possible benefit to the state, and it is declared that since such transactions may occur the Court cannot determine whether the exemption will have any beneficent effect and that it is therefore invalid.
But there are benefits other than the increase of its taxable wealth which a state is at liberty to stimulate by its taxing policy, and exemptions have been sustained on the broader ground that they foster some form of domestic industry. New York v. Roberts, 171 U. S. 658; Magnano Co. v. Hamilton, supra; Fox v. Standard Oil Co., supra; Aero Mayflower Transit Co. v. Georgia Commission, supra. If Vermont chooses to encourage, by tax exemption, loans at favorable rates of interest within the state, because it believes that local interests will be benefited, it can hardly be said for that reason to be contravening a constitution that has known a protective tariff for more than one hundred years. See Alaska Fish Co. v. Smith, supra, 48; Rast v. Van Deman & Lewis Co., 240 U. S. 342, 347. It is true that a state may not lay taxes on imports or burden interstate commerce, Welton v. Missouri, 91 U. S. 275, but it is too late for this Court to declare that a state may not favor domestic interests by granting exemptions in the exercise of its taxing power.
It is not for us to say that the Vermont legislature was unmindful of these broader advantages, or to declare that the presence within the state of investment funds offered at 5% or less to borrowers there, including those who are carrying on the business and industry of the state, is not beneficial; or that if any loans made within the state are used elsewhere they are or ever would be more than negligible in amount; or if they were that they could not have a favorable effect on interest rates within the state, which is a matter of state concern. When the Vermont legislature adopted the present exemption, it had before it the reports of two committees specially appointed to inves*440tigate the tax system of the state, which clearly indicate their judgment, based on a study of conditions in the state, that the existing system was driving investment capital from the state or into secured and non-commercial loans, and that ,a tax exemption embracing both secured and commercial loans would tend to increase the supply of investment capital for both and to reduce interest rates in the state.1 This Court has no basis for saying that those committees were wrong ,and no authority to say it. The state supreme court has stated in the present case that the legislature did have in mind these broader advantages, for it rested its decision on the ground that the exemption was made “ in the interest of thrift and state development ” and “ for the assistance of the agricultural and industrial interests of the state.”
If in the face of so much which is persuasive of the legitimate purpose and effect of this legislation, we are to declare that we cannot say whether the benefits intended either will' or will not result, it does not follow that the Vermont legislature is similarly uninformed. We must assume that it is not, unless we are to discard the salutary principle of decision, that, out of a decent respect to an independent branch of the government, legislative acts must be taken to be based on facts which support their constitutional validity unless the contrary reasonably ap*441pears. This Court, it is true, has held discriminations invalid where, upon the facts disclosed by the record or within the range of judicial notice, it has felt able to say that there could be no state of facts which could rationally support them. Royster Guano Co. v. Virginia, 253 U. S. 412; Heiner v. Donnan, 285 U. S. 312; Louisville Gas & Electric Co. v. Coleman, 277 U. S. 32; Liggett Co. v. Lee, 288 U. S. 517. But in no case has it rendered such a judgment where it has declared that it is unable to say that consequences which would justify the discrimination will not result. Erb v. Morasch, 177 U. S. 584, 586; Middleton v. Texas Power & Light Co., 249 U. S. 152, 158; Stebbins v. Riley, 268 U. S. 137, 143; Swiss Oil Corp. v. Shanks, 273 U. S. 407, 413, 414; Fort Smith Light & Traction Co. v. Paving District No. 16, 274 U. S. 387, 391, 392; Clarke v. Deckebach, 274 U. S. 392; Silver v. Silver, 280 U. S. 117, 123; O’Gorman & Young, Inc. v. Hartford Fire Ins. Co., 282 U. S. 251, 257, 258; Board of Tax Commissioners v. Jackson, 283 U. S. 527, 537-541; Hardware Dealers Mut. Fire Ins. Co. v. Glidden Co., 284 U. S. 151, 158; Boston & Maine R. R. v. Armburg, 285 U. S. 234, 240; Lawrence v. State Tax Comm’n, supra, 283; Concordia Fire Insurance Co. v. Illinois, supra, 547, 548; Metropolitan Casualty Insurance Co. v. Brownell, 292 U. S. 620; Fox v. Standard Oil Co., supra. Unless, as we profess not to do, Standard Oil Co. v. City of Marysville, 279 U. S. 582, we are to sit as a super-legislature, or as triers of the facts on which a legislature is to say what shall and what shall not be taxed, we are not free to say that the exemption will not induce residents to offer to lend their funds within the state and at lower interest rates than they otherwise would, or that opportunities thus afforded will not be availed of by borrowers requiring funds for carrying on the commerce and industry of the state.
Even if we are to assume, in the absence of any actual knowledge, that money loaned in the state at favorable *442rates would not benefit it if used elsewhere, and further that in fact some money is so loaned and used, there is no discernible reason why those circumstances should be deemed to invalidate the tax and none is stated by the Court. It is irrelevant that the state, which has selected domestic loans for exemption in furtherance of a state policy, has not excluded from the exemption every transaction which conceivably might not advance its purpose. Whether the legislative object is completely achieved is of no concern to this Court, once it appears that the exemption is made for a permissible end and bears some reasonable relation to that end. Purpose or motive of the selection of the objects of taxation and exemption is material only so far as it is needful to ascertain whether the discrimination is invidious. If the choice is not condemned for that reason, it has never been held that an exemption must fail because it may benefit some who do not advance the legislative purpose. A classification for a permissible end is not to be condemned because it operates to prohibit transactions in themselves harmless, or fails to reach others which are harmful. Powell v. Pennsylvania, 127 U. S. 678; Purity Extract Co. v. Lynch, 226 U. S. 192; Hebe Co. v. Shaw, 248 U. S. 297; Jacob Ruppert, Inc. v. Caffey, 251 U. S. 264; Miller v. Wilson, 236 U. S. 373; Hawley v. Walker, 232 U. S. 718.
All taxes must of necessity be levied by general rules capable of practical administration. In drawing the line between the taxed and the untaxed the equal protection clause does not command the impossible or the impractical. Unless the line which the state draws is so wide of the mark as palpably to have no reasonable relation to the legitimate end, it is not for the judicial power to reject it and say that another must be substituted. Citizens’ Telephone Co. v. Fuller, supra, 329; Miller v. Wilson, 236 U. S. 373, 384; Clark v. Titusville, 184 U. S. 329, 331; Metropolis Theatre Co. v. Chicago, 228 U. S. *44361, 69, 70; see also Salomon v. Tax Commission, 278 U. S. 484; McCray v. United States, 195 U. S. 27; Quong Wing v. Kirkendall, supra; Bell’s Gap R. Co. v. Pennsylvania, 134 U. S. 232, 237.
As the purpose of the exemption appears to be to encourage the lending of money within Vermont by its residents, at low rates of interest, and as it appears reasonably calculated to have that effect, and as we cannot say that such loans will not be of benefit to the state by tending to establish the interest rate at 5% or less, and by stimulating loans to borrowers for the purpose of carrying on business and industry within the state, the conclusion seems inescapable that the equal protection clause does not forbid it.
2. Feeble indeed is an attack on a statute as denying equal protection which can gain any support from the almost forgotten privileges and immunities clause of the Fourteenth Amendment. The notion that that clause could have application to any but the privileges and immunities peculiar to citizenship of the United States, as distinguished from those of citizens of states, has long since been rejected. Slaughter-House Cases, 16 Wall. 36. It created no new privileges and immunities of United States citizenship, Bartemeyer v. Iowa, 18 Wall. 129, 133, and, as they are derived exclusively from the Constitution and laws enacted under it, the states were powerless to abridge them before the adoption of the Fourteenth Amendment as well as after. See Crandall v. Nevada, 6 Wall. 35.
Before the Amendment the privilege of passing from state to state for the purpose of approaching the seat of the national government, of transacting business with it, and of gaining access to its courts, its public offices and its ports, was declared in Crandall v. Nevada, supra, 44, to be a right of national citizenship which could be exercised independently of the will of the state. Upon this *444ground was placed the decision in that case that a state capitation tax on passengers transported out of the state by railroad or stage coach infringed the Constitution. No one could doubt that if the decision had been made at any time after Railroad Co. v. Maryland, 21 Wall. 456, 472 (1874), and until the present moment, it would have been rested on the commerce clause. This Court has many times pointed out that movements of persons across state boundaries are a part of interstate commerce, subject to the regulation and entitled to the protection of the national government under the commerce clause. Caminetti v. United States, 242 U. S. 470; Hoke v. United States, 227 U. S. 308; Mayor of Vidalia v. McNeely, 274 U. S. 676; Gloucester Ferry Co. v. Pennsylvania, 114 U. S. 196; cf. Passenger Cases, 7 How. 283. And it has specifically pointed out that Crandall v. Nevada, supra, is overruled so far as it referred the protection of such commerce to the privileges and immunities clause rather than to the commerce clause. Helson and Randolph v. Kentucky, 279 U. S. 245, 251.
The privileges and immunities clause has consistently been construed as protecting only interests, growing out of the relationship between the citizen and the national government, created by the Constitution and federal laws. In re Kemmler, 136 U. S. 436, 448; McPherson v. Blacker, 146 U. S. 1, 38; Giozza v. Tiernan, 148 U. S. 657, 661; Duncan v. Missouri, 152 U. S. 377, 382. Appeals to this Court to extend the clause beyond these limitations have uniformly been rejected, and even those basic privileges and immunities secured against federal infringement by the first eight amendments have been held not to be protected from state action by the privileges and immunities clause. Walker v. Sauvinet, 92 U. S. 90; Presser v. Illinois, 116 U. S. 252; O’Neil v. Vermont, 144 U. S. 323; Maxwell v. Dow, 176 U. S. 581; Twining v. New Jersey, 211 U. S. 78; cf. Hurtado v. California, 110 U. S. 516; West v. Lou*445isiana, 194 U. S. 258. The protection and control of intercourse between the states, not carried on in pursuance of the relationship between the citizen and thé national government, has been left to the interstate commerce clause, to the due process and equal protection, clauses of the Fourteenth Amendment, and to Art. IV, § 2, guaranteeing to the citizens of each state the privileges and immunities of citizens in the several states. See Williams v. Fears, 179 U. S. 270. In no case since the adoption of the Fourteenth Amendment has the privileges and immunities clause been held to afford any protection to movements of persons across state lines or other form of interstate transaction.
The reason for this reluctance to enlarge the scope of the clause has been well understood since the decision of the Slaughter-House Cases, supra. If its restraint upon state action were extended more than is needful to protect relationships between the citizen and the national government, and it did more than duplicate the protection of liberty and property secured to persons and citizens by the other provisions of the Constitution, it would enlarge judicial control of state action and multiply restrictions upon it to an extent difficult to define, but sufficient to cause serious apprehension for the rightful independence of local government. That was the issue fought out in the Slaughter-House Cases, supra, with the decision against the enlargement. Since the adoption of the Fourteenth Amendment at least forty-four cases 2 have been *446.brought to this Court in which state statutes have been assailed as infringements of the privileges and immunities clause. Until today none has held that state legislation infringed that clause.
If its sweep were now to be broadened to include protection of every transaction across state lines, regardless of its connection with any relationship between the citizen and the national government, a step would be taken, the gravity of which might well give us concern. But it is necessary to go much further before the present tax can be condemned. If protection of the freedom of the citizen to pass from state to state were the object of our solicitude, that privilege is adequately protected by the commerce clause, even though the purpose of his going be to effect insurance or transact any other kind of business which is in itself not commerce. But protection of the citizen’s freedom of movement, whether by the privileges and immunities clause or by the commerce clause, will afford appellant no relief from the present tax. The record does not show that he was ever outside the State of Vermont and for aught that appears he acquired his extra-state investments, which are in the form of negoti*447able corporate securities, by gift or purchase in Vermont. Nor does it appear that the physical securities or payments of income of which appellant has had the benefit have crossed state lines. He can be saved from the tax only by the extension of the immunity to his income merely because the property from which it has been derived, or the corporation paying it, is located in another state.
Such is the contention now made: that the privilege of acquiring, owning and receiving income from investments without the state is a privilege of federal citizenship. And the suggestion is that the privilege is infringed by taxing this income just as the commerce clause is infringed by state taxation burdening the privilege of carrying on commerce across state lines. In any case the privileges and immunities clause is said to be infringed by taxing this income at a different rate than income from investments made within the state.
The novel application thus given to the clause, and the arguments used to support it, leave one in doubt whether it is thought to preclude all differences of taxation of the two classes of income, or only to forbid such inequality as is in some sense arbitrary and unreasonable. If the former, the clause becomes an inexhaustible source of immunities, incalculable in their benefit to taxpayers and in their harm to local government, by imposing on the states the heavy burden of an exact equality of taxation wherever transactions across state lines may be involved. If the latter, it would seem to add nothing to the guarantee of the equal protection clause, which extends to all “ persons,” including citizens of the United States. In that case discourse upon the privileges and- immunities clause would appear to be a gratuitous labor of supererogation.
If the privilege of making investments without the state is one protected by the privileges and immunities clause *448and a tax upon the income derived from them is analogous to a tax upon the privilege of carrying on interstate commerce, we must not only accept the view that the privilege is infringed by the present tax, but it would follow that any taxation of the income is forbidden. The answer is, of course, that a state tax on net income derived from interstate commerce has never been regarded as a burden on commerce or as an infringement of the commerce clause. See United States Glue Co. v. Oak Creek, 247 U. S. 321; Shaffer v. Carter, 252 U. S. 37; cf. Peck & Co. v. Lowe, 247 U. S. 165; Wagner v. Covington, 251 U. S. 95. Far less could it be thought that a tax on property, or income from it, is an interference with commerce because the property had at some time been or might some time become the subject of such commerce. Cf. Heisler v. Thomas Colliery Co., supra. In applying the privileges and immunities clause, as now interpreted, no ground is suggested, or well could be, for regarding a tax on income from investments without the state as infringing the privilege of carrying on interstate transactions, any more than a tax on net income derived from interstate commerce or from property which had at some time moved in interstate commerce infringes the commerce clause.
The contention that a state tax indirectly affecting transactions carried on across state lines, not forbidden by the commerce clause or by Art. IV, § 2, can be condemned under the privileges and immunities clause, was definitely rejected by this Court in Williams v. Fears, supra. There a state occupation tax upon those engaged in hiring laborers for employment outside the state was held not to infringe the privileges and immunities clause or the equal protection clause.
So far as the objection is addressed to bare inequality of taxation affecting interstate transactions, if valid, it must be accepted as compelling equality of taxation by *449the state of the citizen’s residence and as well by the state into which the transaction extends. More than this, since the exercise of the privilege involves both states, it would seem to be infringed not only by an unequal tax imposed by either, but by any tax imposed at the normal rate by both.
Starting with the dubious assumption that the protection of every movement of the citizen interstate, an acknowledged subject of the commerce clause, is independently a subject of the privileges and immunities clause, the protection afforded by the latter is expanded until it affords a refuge to the citizen from taxation which has no necessary relation to his movements interstate and is in fact not shown to impose any restraint upon them. A tax immunity created avowedly for the protection of the citizen’s privilege of movement from state to state is thus pressed far beyond the requirements of the interest put forward to justify it, and to a point which has never been thought needful or even desirable for the protection of the commerce of the nation. It is a transition effected only by ignoring the decision of this Court in Williams v. Fears, supra.
If mere difference in taxation is made the test of infringement, the iron rule of equality of taxation which the equal protection and due process clauses have failed to impose, see Bell’s Gap R. Co. v. Pennsylvania, supra, 237, is the first fruit of this expansion of the protection of the privileges and immunities clause. To gain the benefits of its shelter the citizen has only to acquire, by a transaction wholly intrastate, an investment outside his state. I can find in the language and history of the privileges and immunities clause no warrant for such a restriction upon local government and policy. Citizens of the United States are given no privilege not to pay taxes. It would seem that a subordination of state taxing power to the *450interests of the individual, of such debatable wisdom, could be justified only by a pointed command of the Constitution of plain import.
If we turn from the reasoning by which this application of the privileges and immunities clause to state taxation is supported to the decision now actually made, it seems that the clause is thought to prohibit only those inequalities in taxation which are considered to be arbitrary and unreasonable. The exemption of dividends derived from corporate business carried on within the state, and the taxation of similar dividends from without the state, is held not to be an infringement of the clause. Exemption of income from investments in property within the state and taxation of like income from without the state is thought to be valid. But the privileges and immunities clause, it is declared, forbids any difference in the taxation of income from investment made within the state and income from investment made without, a conclusion which can only be attributed to the belief that this discrimination, as distinguished from the others, is arbitrary and unreasonable.
We are thus returned to the point of beginning, to a discussion of the question whether the exemption in the present tax is so unreasonable, so without support of a permissible state policy, as to infringe constitutional limitations. If the exemption does not merit condemnation as a denial of the equal protection which the Fourteenth Amendment extends to every person, nothing can be added to the vehemence or effectiveness of the denunciation by invoking the command of the privileges and immunities clause.
The judgment should be affirmed.
Mr. Justice Brandéis and Mr. Justice Cardozo concur in this opinion.The committee appointed in 1900 by the Governor of Vermont to investigate double taxation and to recommend measures for its relief found that the existing taxing system was driving capital from the state or .into tax exempt savings banks, and suggested an exemption of loans secured by property returned for taxation in the state. Double Taxation in Vermont; Report of Special Committee Appointed to Report a Measure for its Relief to the Legislature of 1900, pp. 4, 15. In 1908 a similar committee recognized the same evils but did not favor the exemption of secured loans alone, because it would increase interest rates on unsecured loans and cause a dearth of commercial credits. Vermont — Commission on Taxation — Report 1908, pp. 43 ff.
Slaughter-House Cases, 16 Wall. 36; Bradwell v. State, 16 Wall. 130; Bartemeyer v. Iowa, 18 Wall. 129; Minor v. Happersett, 21 Wall. 162; Walker v. Sauvinet, 92 U. S. 90; Kirtland v. Hotchkiss, 100 U. S. 491; Presser v. Illinois, 116 U. S. 252; Mahon v. Justice, 127 U. S. 700; In re Kemmler, 136 U. S. 436; Crowley v. Christensen, 137 U. S. 86; McElvaine v. Brush, 142 U. S. 155; McPherson v. Blacker, 146 U. S. 1; Giozza v. Tiernan, 148 U. S. 657; Duncan v. Missouri, 152 U. S. 377; Miller v. Texas, 153 U. S. 535; In re Lockwood, 154 U. S. 116; Iowa Central Ry. v. Iowa, 160 U. S. 389; Plessy *446v. Ferguson, 163 U. S. 537; Orient Insurance Co. v. Daggs, 172 U. S. 557; Cumming v. Board of Education, 175 U. S. 528; Maxwell v. Dow, 176 U. S. 581; Williams v. Fears, 179 U. S. 270; Orr v. Gilman, 183 U. S. 278; Cox v. Texas, 202 U. S. 446; Board of Education v. Illinois, 203 U. S. 553; Ballard v. Hunter, 204 U. S. 241; Western Turf Assn. v. Greenberg, 204 U. S. 359; Halter v. Nebraska, 205 U. S. 34; Wilmington Star Mining Co. v. Fulton, 205 U. S. 60, 73; Twining v. New Jersey, 211 U. S. 78; Western Union v. Commercial Milling Co., 218 U. S. 406; Missouri Pacific Ry. Co. v. Castle, 224 U. S. 541; Graham v. West Virginia, 224 U. S. 616; Selover, Bates & Co. v. Walsh, 226 U. S. 112; Rosenthal v. New York, 226 U. S. 260; Waugh v. Board of Trustees, 237 U. S. 589; Porter v. Wilson, 239 U. S. 170; Crane v. Campbell, 245 U. S. 304; Armour & Co. v. Virginia, 246 U. S. 1; Omaechevarria v. Idaho, 246 U. S. 343; Maxwell v. Bugbee, 250 U. S. 525; Ownbey v. Morgan, 256 U. S. 94; Prudential Ins. Co. v. Cheek, 259 U. S. 530; Hamilton v. Regents, 293 U. S. 245.