In the Gonzales v. Buist case of 1911, the U.S. Supreme Court ruled on a matter concerning inheritance tax law and its application to property located outside of the United States owned by an American citizen who died abroad. The decedent was a resident of South Carolina but had significant assets in Argentina at his time of death. His will was probated in both countries, with each imposing their respective inheritance taxes on his estate's assets within their jurisdictions. The executor paid all Argentinean taxes but contested South Carolina’s claim for additional taxation when he returned to settle affairs there, arguing that double taxation would be unjust and unconstitutional under international law principles. However, the court held that states have jurisdiction over residents' worldwide estates for purposes of levying inheritance tax regardless if another country has already taxed those same properties or not; it is not considered double-taxation because different sovereigns are involved - one state-level (South Carolina) and one foreign (Argentina). Therefore, it upheld South Carolina's right to impose its own separate inheritance tax on these Argentinian properties.

In the dissenting opinion for Gonzales v. Buist, Justice Oliver Wendell Holmes Jr. disagreed with the majority's interpretation of tax law and its application to U.S.-based income of a foreign resident. He argued that while it is true that Congress has broad power to levy taxes, this does not mean they can impose them on foreigners in relation to their property situated abroad or income derived therefrom. The justice contended that such an interpretation would be contrary to international law principles which respect the sovereignty of other nations over persons residing within their borders and property located therein. Furthermore, he pointed out inconsistencies in how similar cases had been handled by lower courts due to lack of clear guidance from Supreme Court precedent on this issue.