if only for the reason of not having been challenged in the case, "We have considered the act only in respect of the tax on income derived from real estate, and from invested personal property") were to be treated as direct taxes. Because the statute in question had not apportioned income taxes on income from property by population, the statute was ruled unconstitutional. Finally, ratification of the Sixteenth Amendment to the United States Constitution in 1913 made possible modern income taxes, by limiting the Sixteenth Amendment income tax to the class of indirect excises (i.e. excises, duties, and imposts) – thus requiring no apportionment, a practice that would remain unchanged into the 21st century. Employment-based head taxes Various cities, including Chicago and Denver, have levied head taxes with a set rate per employee targeted at large employers. After Cupertino postponed head tax proposals to 2020, Mountain View became the only city in Silicon Valley to continue to pursue such type of taxes. In 2018, the Seattle city council proposed a "head tax" of $500 per year per employee. The proposed tax was lowered to $275 per year per employee, was passed, and became "the biggest head tax in U.S. history," though it was repealed less than a month later. See also Corvée Fixed tax Hut tax Constrained equal losses - a similar rule in the context of bankruptcy problems. References External links Middle Ages Poll Tax Pictures by Paul Ross, who witnessed the riots The battle that brought down Thatcher – a perspective by the Trotskyist Militant group Taxation in the United Kingdom Taxation in the United States