In Hamilton Company v. Massachusetts, the Supreme Court of the United States was asked to decide whether a state could impose a tax on a foreign corporation doing business within its borders. The Hamilton Company, a foreign corporation, had been doing business in Massachusetts for several years and had been paying taxes to the state. However, the company argued that the state had no authority to impose a tax on a foreign corporation. The Supreme Court held that the state had the authority to impose a tax on a foreign corporation doing business within its borders. The Court reasoned that the state had the power to regulate the activities of foreign corporations within its borders, and that the tax was a reasonable exercise of that power. The Court also noted that the tax was not discriminatory and did not place an undue burden on the company. The Court's decision in Hamilton Company v. Massachusetts established that states have the authority to impose taxes on foreign corporations doing business within their borders. This decision has been cited in numerous subsequent cases involving the taxation of foreign corporations.

In Hamilton Company v. Massachusetts, the Supreme Court was asked to decide whether a state could impose taxes on out-of-state companies that had no physical presence in the state. The majority opinion held that states did have this power and upheld the tax imposed by Massachusetts on an Ohio company doing business within its borders. In his dissenting opinion, Justice Field argued that such taxation violated both the Due Process Clause of the Fourteenth Amendment and Article I of the Constitution which gives Congress exclusive authority over interstate commerce. He reasoned that since there was no physical presence for taxation purposes, it would be impossible for any out-of-state company to defend itself against such a tax in court or even know when they were being taxed until after it had already been collected from them. Therefore he concluded that allowing states to impose these kinds of taxes would lead to unfairness and confusion among businesses operating across multiple jurisdictions without any recourse available to them under federal law.