In the case of Cudahy Packing Company v. State of Minnesota, 1917, the U.S Supreme Court ruled in favor of the state's right to tax a foreign corporation for property located within its borders. The Cudahy Packing Company, an Illinois-based meatpacking firm with operations in various states including Minnesota, argued that it was being unfairly taxed by Minnesota on goods which were only temporarily stored there before being shipped elsewhere. However, the court held that as long as these goods remained within Minnesota's jurisdiction and benefited from its laws and protections they could be subjected to taxation regardless of their ultimate destination or how long they stayed in-state. This decision affirmed states' rights to levy taxes on corporations operating within their boundaries even if those companies are headquartered elsewhere.

The dissenting opinion in the case of Cudahy Packing Company v. State of Minnesota argued that the state had no right to tax a foreign corporation for property located outside its jurisdiction. The justice contended that such taxation was an infringement on interstate commerce and violated constitutional principles. They believed it was unjust for Minnesota to levy taxes on goods stored in public warehouses, as these goods were not part of the company's capital stock within the state but rather products intended for sale elsewhere. The dissenters also pointed out inconsistencies with previous court rulings which they felt undermined this decision, particularly those stating that a state cannot tax property beyond its borders or interfere with interstate commerce through taxation measures.