posadas national city bank new york argued decided january wm cattron rigby washington petitioner carl mead harry forbes new york city respondent justice sutherland delivered opinion national city bank new york organized national banking act amended time time since enactment bank complying requirements section federal reserve act december stat amended september stat infra established branches manila cebu philippine islands tax levied paid philippine government net income branches first six months year amended controversy philippine government however addition levied capital deposit taxes permitted section paid bank protest action brought first instance manila recover amount gave judgment favor bank part additional taxes philippine upon appeal reversed judgment far bank ordered refund entire amount section federal reserve act supra reproduced margin far pertinent authorizes establishment branches associations foreign countries dependencies doubted viewing section without regard later legislation branches question lawfully established appear later point opinion philippine islands included words view matter additional taxes imposed philippine government invalid domenech national city bank talbott silver bow county asserted effect legislation subsequent passage federal reserve act shall examine moment case disposed without detail upon authority cases domenech case held laws extended puerto rico tax branch national bank tax bank puerto rico dependency except permitted tax national bank since agency talbott case involved power territory impose tax upon national bank held first place power taxation respect national banks exists territories second place power taxation territories limited provisions section although terms section refers find nothing original organic act early statutes relating philippines referred petitioner take islands controlling rule domenech case may tax sovereign come remaining point deem necessary discuss petitioner contends subsequent legislation effect repealing abrogating section act permitting establishment national bank branches far philippine islands concerned later legislation consists certain provisions organic act philippine islands august stat act september supra amending designated sections original federal reserve act examine statutory provisions chronological order section act seen national banks authorized establish branches philippine islands organic act provides statutory laws hereafter enacted subsequent august shall apply philippine islands except specifically provide provided act chapter laws force philippines august shall continue force effect except altered amended modified herein chapter altered amended repealed legislative authority herein provided chapter act congress section obviously taken say conferring power local legislature deal local laws course confers power local legislature alter nd repeal act congress laws parts laws applicable philippines conflict provisions act hereby continued force effect sections clear section federal reserve act conflict provision organic act continued full force effect september nine days passage new organic act act amend federal reserve act supra passed first observed respect amending act purport enact substitute federal reserve act rpeal reenact portion amend certain specific sections thereof old act contains thirty sections act september amends sections subsection section second paragraph section sections federal reserve act section revised statutes introductory words section section hereby amended read follows stat original section copied change addition far question concerned insertion words insular possessions word reason appears anything called attention aware reason addition words since comprehensive term seem include insular possessions event philippine islands constituted dependency possessions merely possession held right cession spain undoubtedly power legislation government see nancy seq compare substantial change made old section addition provision authorizing association invest stock banks corporations chartered incorporated laws state engaged international foreign banking banking dependencies insular possessions fairly plain addition constituted sole reason amending section amending act described contains words repeal effected repeal section act implication cardinal rule repeals implication favored two acts upon subject effect given possible two categories repeals implication provisions two acts irreconcilable conflict later act extent conflict constitutes implied repeal earlier one later act covers whole subject earlier one clearly intended substitute operate similarly repeal earlier act either case intention legislature repeal must clear manifest otherwise least general thing later act construed continuation substitute first act continue speak far two acts time first enactment law subject stated finds abundant support decisions well lower federal state courts enough direct attention decisions large number tynen wall justice field speaking stating general rule said two acts repugnant provisions latter act without repealing clause operates extent repugnancy repeal first even two acts express terms repugnant yet latter act covers whole subject first embraces new provisions plainly showing intended substitute first act operate repeal act meant statement say casual reading might suggest mere fact latter act covers whole subject embraces new provisions demonstrates intention completely substitute latter act first made apparent decision henderson tobacco wall term opinion delivered justice strong said must observed doctrine tynen case asserts former statute impliedly repealed far provisions subsequent statute repugnant far latter statute making new provisions plainly intended substitute powers directions several acts may well subsist together implication repeal allowed italics original two cases others briefly reviewed red rock henry justice woods conclusion stated follows result authorities cited affirmative statute contains expression purpose repeal prior law repeal unless two acts irreconcilable conflict unless later statute covers whole ground occupied earlier clearly intended substitute intention legislature repeal must clear manifest implication cases speak must necessary implication wood pet sufficient said justice story case establish subsequent laws cover even cases provided prior act may merely affirmative cumulative auxiliary question whether statute repealed later one containing repealing clause ground repugnancy substitution question legislative intent ascertained application accepted rules ascertaining intention claflin eastern extension tel even face repealing clause circumstances may justify conclusion later act repeating provisions earlier one continuation rather abrogation reenactment earlier act bear lake irrigation garland petitioner relies murdock memphis wall sufficient say rule quoted red rock henry supra formulated case mind since specifically mentioned principle embodied statutes general effect provisions prior statute far reproduced later one construed continuation provisions new enactment see barrows people gaslight coke co statutes declaratory rule common law dallmann dallmann julien model see also ely others holton moore mausert et longlois longlois et ind people new york applying rule established foregoing authorities see nothing terms federal reserve amending act provisions new organic act history philippine legislation justifies conclusion amendment congress intended repeal old section federal reserve act amendment made form indeed many compel constitutional repeating language original section additions heretofore called attention unless contrary plainly appear employment form amendment simply serve causes venience certainty say carrying full text forward task searching bringing together various fragments go make completed whole specific eliminations additions amendment rendered unnecessary possible doubt precise terms law amended avoided chief judge denio said ely others holton supra short attribute effect plan amendment original section except one suggested preserving harmonious text future editions shall published scattered members shall easily adjust follows parts original section copied amended section thereby repealed immediately reenacted continued uninterruptedly law amendment precisely section organic act supra terms relates laws thereafter enacted must put aside applicable judgment affirmed footnotes section revised statutes amended ed provides legislature state may tax said shares include dividends derived therefrom taxable income owner holder thereof tax associations net income according measured net income provided certain specified conditions complied national banking association possessing capital surplus may file application federal reserve board upon conditions regulations may prescribed said board purpose securing authority establish branches foreign countries dependencies furtherance foreign commerce act required fiscal agents application shall specify addition name capital banking association filing place places banking operations proposed carried amount capital set aside conduct foreign business federal reserve board shall power approve reject application judgment amount capital proposed set aside conduct foreign business inadequate reasons granting application deemed inexpedient stat