In the 1938 case of Hale, Chairman, et al. v. Bimco Trading, Inc., et al., the United States Supreme Court dealt with a dispute over taxation on imported goods and their subsequent resale within Native American reservations. The State of Washington had imposed a tax on an import company (Bimco Trading) for canned salmon it sold to Tulalip Tribes residing in federally recognized Indian reservations. Bimco contested this tax arguing that such transactions were exempt from state taxes under federal law which grants sovereignty rights to tribal lands. The court ruled in favor of Bimco Trading stating that while states have broad powers to impose taxes, these powers do not extend into actions that infringe upon national interests protected by federal law or policy - including trade with Native American tribes within reservation boundaries. Therefore, Washington's imposition of a sales tax was deemed unconstitutional as it violated the principle of tribal sovereignty and interfered with commerce between U.S citizens and members of federally-recognized tribes.

In the dissenting opinion for Hale, Chairman, et al. v. Bimco Trading Inc., et al., it was argued that the majority's decision to uphold a tax on foreign corporations doing business in New York State violated both due process and equal protection clauses of the Fourteenth Amendment. The dissenters believed that this tax unfairly discriminated against out-of-state businesses by imposing an additional burden not faced by domestic companies. They also contended that there was no rational basis for such discrimination since all corporations operating within state boundaries utilized similar public services and infrastructure regardless of their origin or incorporation status. Furthermore, they asserted that this kind of taxation could potentially discourage interstate commerce which is contrary to federal interests and principles enshrined in the Constitution.