The U.S. Supreme Court case Asiatic Petroleum Co., Ltd. v. Insular Collector of Customs in 1935 revolved around the issue of import duties on petroleum products brought into the Philippines by the Asiatic Petroleum Company, a British corporation. The company argued that under an agreement between Britain and America, it was exempt from paying these taxes as they were not imposed on similar American companies operating in Britain due to reciprocal trade agreements between both countries at that time. However, the court ruled against this argument stating that such exemptions did not apply to foreign corporations doing business within U.S territories like Philippines which had its own set of customs laws separate from those governing mainland United States.

The dissenting opinion in the case of Asiatic Petroleum Co., Ltd. v. Insular Collector of Customs argued that the majority's decision to uphold a tax on foreign corporations doing business in the Philippines was unjust and inconsistent with previous rulings. The dissenting justices believed that this tax violated principles of international law, as it discriminated against foreign companies by imposing an additional burden not faced by domestic corporations. They also pointed out inconsistencies between this ruling and earlier decisions which had struck down similar taxes as unconstitutional under U.S law governing its territories, including the Philippines at that time. Furthermore, they contended that such discriminatory taxation could potentially harm diplomatic relations with other nations whose businesses were affected.