In the case of International Paper Company v. Commonwealth of Massachusetts (1917), the U.S. Supreme Court ruled in favor of Massachusetts, upholding its right to tax a foreign corporation for doing business within its borders. The International Paper Company, incorporated in New York but with property and operations in several states including Massachusetts, argued that it was being unfairly taxed by multiple states for the same income. However, the court held that each state has sovereign power to tax businesses operating within their jurisdiction as long as there is no double taxation on specific properties or assets; rather than taxing total corporate income indiscriminately across all jurisdictions where a company operates. This ruling reinforced principles of federalism and state sovereignty over taxation matters.

The dissenting opinion in the case of International Paper Company v. Commonwealth of Massachusetts argued that the majority's decision to uphold a tax on tangible property located outside the state was unconstitutional. The dissenters believed this violated due process rights as outlined by the Fourteenth Amendment, which prohibits states from depriving any person or corporation "of life, liberty, or property without due process of law." They contended that Massachusetts had no jurisdiction over properties located in other states and thus could not impose taxes on them. Furthermore, they disagreed with the majority's interpretation of 'jurisdiction,' arguing it should be based on geographical boundaries rather than economic benefits derived from such properties. In their view, allowing taxation under these circumstances would lead to double taxation and infringe upon interstate commerce regulations.