Arnson & Another v. Murphy, Collector was a United States Supreme Court case that dealt with the issue of whether a state could impose a tax on a foreign corporation. The case was brought by two foreign corporations, Arnson & Another, who argued that the state of New York had no authority to impose a tax on them. The Supreme Court held that the state of New York did have the authority to impose a tax on foreign corporations, as long as the tax was not discriminatory and was applied in a uniform manner. The Court also held that the tax imposed by New York was not discriminatory and was applied in a uniform manner, and thus was valid. The Court also held that the tax was not a burden on interstate commerce, as it was applied uniformly to all foreign corporations. This decision established the precedent that states have the authority to impose taxes on foreign corporations, as long as the tax is not discriminatory and is applied in a uniform manner.

In Arnson & Another v. Murphy, Collector, the Supreme Court was asked to decide whether a tax imposed by Congress on distilled spirits manufactured in the United States was constitutional. The majority opinion held that it was not unconstitutional and upheld the tax. However, Justice Field dissented from this decision and argued that Congress did not have authority under Article I of the Constitution to impose such a tax without apportionment among states according to their population. He further argued that if Congress had intended for such taxes to be imposed without apportionment then they would have made specific provisions for them in Article I or elsewhere in the Constitution instead of leaving it up to interpretation by courts or other branches of government. In conclusion, Justice Field believed that since no clear language existed granting Congress power over taxation without apportionment then any attempt at imposing such taxes should be deemed unconstitutional as per existing Constitutional law at the time