In the case of Barclays Bank PLC v. Franchise Tax Board of California, 1993, the U.S. Supreme Court ruled in favor of California's method for taxing multinational corporations. The dispute centered around whether or not a state could use its own formula to determine how much income from an international corporation was subject to taxation within that state - a practice known as "worldwide combined reporting." Barclays Bank argued this violated both federal law and international treaties by potentially leading to double taxation. However, the court held that there was no explicit preemption by Congress against such practices and thus states were free to tax businesses operating within their borders as they saw fit unless explicitly prohibited by federal law.

The dissenting opinion in the Barclays Bank PLC v. Franchise Tax Board of California case argued that the Court's decision to uphold California's worldwide combined reporting method for taxing multinational corporations was incorrect. The justices believed this approach violated federal law and interfered with the federal government’s ability to conduct foreign policy, as it could potentially lead to international discord due to its extraterritorial nature. They also pointed out that Congress had repeatedly expressed disapproval of such tax methods but had not explicitly outlawed them because they assumed courts would find them unconstitutional under existing laws. Furthermore, they disagreed with the majority's reliance on Japan Line Ltd v County of Los Angeles (1979), arguing that it should be limited only to cases involving direct taxation of foreign commerce by states rather than being extended into income taxation matters.