In the case of CAMI, Commissioner v. Central Victoria, Ltd., 1924, the United States Supreme Court was tasked with determining whether a British corporation that owned stock in American companies could be taxed by the U.S. government on dividends it received from those companies. The court ruled that under existing tax law at the time, foreign corporations were indeed subject to taxation on income derived from sources within the United States. This included dividends paid by domestic corporations to their foreign shareholders. Therefore, Central Victoria Ltd., despite being a British company and not physically present in America or conducting business there directly, was liable for U.S taxes on its dividend income from American stocks.

The dissenting opinion in the case of CAMI, Commissioner v. Central Victoria, Ltd., 1924 argued that the majority's decision to uphold a tax assessment against Central Victoria was incorrect. The dissenters believed that the company should not be taxed on income derived from its Australian mining operations because it did not have a "permanent establishment" in Australia as defined by U.S.-Australia Tax Treaty. They contended that this interpretation was consistent with international law principles and would prevent double taxation of multinational corporations' profits. Furthermore, they disagreed with the majority's view about how much weight should be given to administrative interpretations of tax treaties by revenue authorities; they felt these interpretations deserved more deference than what was accorded by their colleagues in the majority.