In the case of Corn Products Refining Company v. Eddy et al., 1918, the U.S Supreme Court was tasked with determining whether a state could impose a tax on goods manufactured within its borders but destined for export to foreign countries. The Corn Products Refining Company had been taxed by New Jersey on glucose it produced in that state and then exported abroad. The company argued this violated the Export Clause of the Constitution which prohibits states from taxing exports to foreign countries without Congress's consent. The Supreme Court ruled against Corn Products Refining Co., stating that while states cannot directly tax exports, they can levy taxes on activities related to production or manufacturing before an item becomes an 'export'. In this case, New Jersey's taxation of glucose during its manufacture did not violate constitutional protections because at that point it was not yet considered an 'export'. This ruling clarified how far-reaching constitutional protections against export taxation were and affirmed states' rights to collect revenue from businesses operating within their jurisdiction.

In the dissenting opinion for Corn Products Refining Company v. Eddy et al., it was argued that the majority's decision to uphold a tax on corn syrup products, despite an exemption in Illinois law for "sugar," contradicted established principles of statutory interpretation. The dissent contended that because corn syrup is commonly understood as a type of sugar and used interchangeably with cane or beet sugar in many food products, it should be included under the legal definition of "sugar" and thus exempt from taxation. They also pointed out inconsistencies in how other similar substances were treated under tax law, further highlighting what they saw as arbitrary distinctions made by the majority. Ultimately, they believed this ruling would unfairly burden businesses like Corn Products Refining Company who produce these types of goods.