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In the 1934 case of Detroit International Bridge Co. v. Corporation Tax Appeal Board of Michigan, the U.S Supreme Court ruled in favor of the Detroit International Bridge Company (DIBC). The DIBC had been assessed a tax by Michigan based on its entire capital stock value, despite part of their property being located in Canada. The company argued that this was unconstitutional as it violated due process rights under the Fourteenth Amendment and also infringed upon federal jurisdiction over foreign commerce. The court agreed with DIBC's argument that only those assets within Michigan could be taxed by state authorities, not those outside its borders or jurisdiction - including another country like Canada where part of their bridge infrastructure was situated. This decision reinforced principles regarding states' taxation powers and limits thereof concerning interstate and international business operations.
In the dissenting opinion for Detroit International Bridge Co. v. Corporation Tax Appeal Board of Michigan, Justice Stone argued that the majority's decision was inconsistent with previous rulings regarding interstate commerce and taxation. He contended that the tax imposed by Michigan on a Canadian corporation operating an international bridge should not be considered as burdening interstate commerce since it is levied equally on all corporations doing business within its jurisdiction regardless of whether their operations are local or extend beyond state lines. Furthermore, he pointed out that this case differs from others in which taxes were invalidated because they discriminated against foreign corporations or those engaged in interstate commerce, neither of which applies to this situation. In his view, there was no constitutional barrier preventing Michigan from taxing a foreign corporation for carrying on a local business within its borders even if part of its property used in conducting such business extends into another country.