In the 1893 case of Imperial Fire Insurance Company v. Coos County, the U.S Supreme Court ruled in favor of Imperial Fire Insurance Company. The dispute arose when Coos County, Oregon claimed that it was entitled to taxes on a sum held by the insurance company for a policyholder who had not yet made a claim. The court decided that until such time as the policyholder made their claim and received payment from the insurer, no actual debt existed which could be taxed under state law. Therefore, since there was no taxable property or asset within its jurisdiction at this point in time, Coos County's tax assessment against Imperial Fire Insurance Company was deemed invalid by the court.

The dissenting opinion in the case of Imperial Fire Insurance Company v. Coos County argued that the majority's decision was inconsistent with previous rulings and principles of law regarding tax obligations for foreign corporations operating within a state. The dissent contended that, as per past decisions, only property physically located within a state could be taxed by it; however, the majority had allowed Oregon to tax an insurance company based on its total assets worldwide rather than just those in Oregon. This approach was seen as violating both due process rights and interstate commerce protections because it imposed taxes on property outside of the jurisdictional reach of the taxing authority (Oregon). Furthermore, this taxation method did not account for debts or liabilities against these global assets which might reduce their value significantly. Thus, according to this view point, such an assessment would result in unjust taxation.