In the 1915 case of Ackerlind, Administrator of Lind v. United States, the Supreme Court addressed a dispute over inheritance tax law. The decedent was a Swedish citizen who had resided in Illinois for many years before returning to Sweden shortly before his death. He left behind property and assets within both jurisdictions. The issue at hand was whether or not U.S federal government could impose an inheritance tax on all of his estate, including those properties located outside the country (in Sweden). The court ruled that it could not; only those properties physically located within U.S borders were subject to American taxation laws according to existing legislation at that time.

The dissenting opinion in the case of Ackerlind, Administrator of Lind v. United States argued that the majority's decision to uphold a lower court ruling denying an inheritance tax refund was incorrect. The dissenters believed that the deceased, who had been a Swedish citizen residing in New York at his time of death, should not have been subject to U.S. estate taxes on property located abroad because he did not intend to become an American citizen and therefore never truly abandoned his domicile in Sweden. They contended that for taxation purposes, one’s domicile is determined by their intent and actions rather than mere physical presence or residence status. Thus, they felt it was unjust to impose U.S taxes on assets held outside America when there was no clear evidence indicating abandonment of foreign domicile by the decedent.