In the case of Bass, Ratcliff & Gretton, Limited v. State Tax Commission in 1924, the U.S Supreme Court was tasked with determining whether a New York state law that imposed higher taxes on foreign corporations than domestic ones violated the Equal Protection Clause of the Fourteenth Amendment. The plaintiff was a British corporation engaged in selling ale and beer both within and outside of New York. They argued that they were being unfairly taxed compared to their domestic counterparts. However, after careful consideration, the court ruled against them stating that there is no constitutional requirement for states to tax all businesses equally regardless of where they are incorporated or based out from. It held that it's permissible for states to impose different tax rates on foreign corporations if such differential treatment serves a legitimate state interest - which according to them included protecting local industries from potential disadvantages caused by competition with larger foreign entities.

The dissenting opinion in the case of Bass, Ratcliff & Gretton, Limited v. State Tax Commission argued that the majority's decision was inconsistent with previous rulings and interpretations of the Commerce Clause. The dissent contended that a state cannot tax goods imported from another country or state while they remain in their original packages for sale. They believed this to be an infringement on federal authority over foreign and interstate commerce as established by precedent cases such as Brown v Maryland (1827). Furthermore, they disagreed with the majority’s interpretation of “original package”, arguing it should include not just individual bottles but also crates or other containers used for transport and storage until sale. This broader definition would exempt more items from taxation under state law according to them. Lastly, they expressed concern about potential negative impacts on trade due to states imposing taxes inconsistently.