In the case of Anglo-Californian Bank v. United States in 1899, the U.S Supreme Court ruled on a dispute regarding customs duties. The Anglo-Californian Bank had imported gold coin into San Francisco from Victoria, British Columbia and was charged with a duty by U.S Customs officials. The bank contested this charge, arguing that as per Section 2504 of Revised Statutes (1878), gold coins were exempted from import duties. However, the government argued that under Section Six of the Act of June 10th, 1890 - which imposed a duty on all metal imports - there was no such exemption for gold coins. The court sided with the government's interpretation and upheld that while raw bullion might be exempted from import duties under certain circumstances; finished products like minted coins were not included in those exemptions. Therefore it held that customs officials acted correctly when they levied an import tax on these items brought into America by foreign entities like banks or individuals.

In the dissenting opinion for the case of ANGLO-CALIFORNIAN BANK v. UNITED STATES, Justice Harlan argued that the majority's decision to uphold a tax on bank shares was unconstitutional. He contended that this taxation violated both federal and state laws by imposing an unequal burden on shareholders based on their location. Harlan maintained that it was unfair to tax shareholders in California more heavily than those in other states simply because they resided where the bank had its principal place of business. Furthermore, he asserted that such differential treatment contradicted principles of uniformity and equality inherent in American law and could potentially discourage investment from out-of-state investors due to higher taxes imposed upon them compared with local ones.