Nevertheless, it is to be anticipated that, with the passage of time, economic pressure will compel all states to adopt reciprocal statutes or their equivalent. There is, however, one serious problem of double taxation not remedied by such legislation. Not infrequently more than one state claims to be the decedent's domicile. The federal courts have ordinarily declined jurisdiction to solve the issue or to interfere with inconsistent decisions of the courts of different states. Thus, it has been impossible for an executor to find relief from the judgments of the highest courts of different states, which judgments vary in their finding as to domicile.
Double taxation is the unfortunate result.
The appended Uniform Acts are designed to make it possible to solve this difficulty. The first Act empowers the tax authorities of the claimant states, with the consent of the executor or administrator, to compromise the amount of the tax. Under such an agreement each claimant state would receive something, although less than the full amount of its claim. The second Act provides for a system of voluntary arbitration in the event of failure to compromise. Such an arbitration is had only where the claimant States and the executor are willing, and the arbitrators themselves must be unanimously selected by the said States and the executor.