The opinions in three other cases, all decided by the Texas Court of Appeals, flesh out the law in this area. Like many states, Texas imposes a premium tax on in-state companies when they purchase insurance from an out-of-state insurance company, known as the Independently Procured Insurance Tax (commonly known as the "premium tax"). The only connection that Todd Shipyards' insurance had with Texas is that Todd Shipyards had property in Texas which was covered by non-Texas insurance policies. The Texas State Board of Insurance sought to collect the Texas 5% premium tax against Todd Shipyards. This is what Todd Shipyards did by purchasing insurance outside of Texas, even if that insurance covered Texas property.

Source: Forbes May 27, 2018 18:56 UTC