delivered the opinion of the Court.
Thе Connecticut succession tax act of 1923 contains the following provisiоn:
“All property and any interest therein owned by a resident of this state at the timе of his decease, . . . which shall pass by will or inheritance under the laws of this .state; and all gifts of such property by deed, grant or other conveyance, made in contemplation of the death of the grantor or donor, or intended to take effect in possession or enjoyment at or after the deаth of such grantor or donor, shall be subject to the tax herein prescribed.” Chаp. 190, Pub. Acts, 1923, § 1.
On December 28, 1926, while this act was in force, Harriet D. Sewell executed an irrevocable deed of trust to appellant, transferring certain sеcurities, by which deed it was provided that the trustee collect the income and pay it to Mrs. Sewell during her life. Thereafter, the income was to be pаid to her husband for his life, and upon his death the trustee was directed to pay and transfer the *512 principal of the trust absolutely to their daughter if she survived, but if not, then tо the issue of the daughter, with a gift over in default of such issue. Mrs. Sewell died May 20, 1930, domicilеd in Connecticut.
The state supreme court held that the statute recognized the distinction between talcing effect in possession or enjoyment and vesting in right, title or interest, and intended to reach a shifting of the enjoyment of property although such shifting followed necessarily from a prior transfer of title
inter vivos;
that within the meaning and description of the statute, the transfer in question was a gift intended tо take effect in possession or enjoyment at or after the death of the donor, and, therefore, was subject to the succession tax; and that thе imposition of such tax did not offend against the Fourteenth Amendment or any othеr provision of the federal Constitution.
Appellant first contends that while the court below expressly upheld the tax under the ,act of 1923, it nevertheless gave effect to the later and more specific act of 1929 (Pub. Acts, c. 299, §§ 1 and 2), and thereby the contract impairment clause of the federal Constitution was infringed. This contention must be rejected. We are not at liberty to disregard the explicit holding of the state court ,as to the basis of its decision, except for convincing reasons, which here we are unable to find. Compare
Columbia Ry.
v.
South Carolina,
*513
Since the court below construed the act of 1923, without regard to the act of 1929, ,аs embracing the event sought to be taxed, and since in that view the question of contract impairment does not arise, we are bound by the decision'of that court as though the meaning as fixed by the court had been expressed in the statute itself in specific words.
Great Northern Ry. Co.
v.
Sunburst Oil & Refining Co., ante,
p. 358;
Knights of Pythias
v.
Meyer,
In that view the tax was imposed upon an event gеnerated by the death of the decedent. That such a tax does not cоnflict with any provision of the federal Constitution is clearly stated by this court in
Coolidge
v.
Long,
Judgment affirmed.