In the 1952 case of De La Rama Steamship Co., Inc. v. United States, the U.S Supreme Court ruled in favor of the United States government over a dispute regarding tax liabilities. The De La Rama Steamship Company, a Philippine corporation, had claimed that it was exempt from paying taxes on income derived from its shipping operations between ports in the Philippines and other countries under Section 262 of Revenue Act of 1936. However, this claim was rejected by both lower courts and eventually by the Supreme Court as well. The court held that since De La Rama operated ships not only within but also outside Philippine waters (an area where U.S law applies), it could not be considered exclusively engaged in foreign commerce and thus did not qualify for exemption under section 262. Furthermore, they found no evidence to suggest Congress intended to extend such exemptions to corporations operating beyond territorial limits defined by domestic laws when enacting this legislation. This decision clarified how tax laws apply to international businesses with operations partly conducted within territories subject to American jurisdiction.

In the dissenting opinion for De La Rama Steamship Co., Inc. v. United States, it was argued that the majority's decision to uphold a tax on foreign corporations operating within U.S. territories was incorrect and inconsistent with previous rulings of the court. The dissenting justices believed that this ruling unfairly targeted foreign businesses and could potentially discourage international trade and investment in U.S territories, which would be detrimental to their economies. They also pointed out that there were other ways for these territories to raise revenue without imposing such taxes on foreign entities doing business within their borders.