The U.S. Supreme Court case Liverpool & London & Globe Insurance Company v. Board of Assessors for the Parish of Orleans in 1910 revolved around a dispute over taxation between an insurance company and a local government body in Louisiana. The Liverpool, London, and Globe Insurance Company argued that its property was being unfairly taxed by the Board of Assessors for the Parish of Orleans because it included assets located outside the state's jurisdiction. The court ruled in favor of the insurance company, stating that only properties within Louisiana could be subjected to tax assessment by local authorities there. This decision reinforced principles regarding jurisdictional limits on taxation powers.

In the dissenting opinion for Liverpool & London & Globe Insurance Company v. Board of Assessors for the Parish of Orleans, Justice Holmes disagreed with the majority's interpretation that insurance companies were not subject to taxation by states where they did business but were not incorporated. He argued that this ruling was inconsistent with previous decisions and could have far-reaching implications on state tax laws. Holmes believed that it was within a state's rights to impose taxes on businesses operating within its borders, regardless of their place of incorporation or domicile. The justice also expressed concern over potential abuse if corporations could avoid taxation simply by incorporating in different states while continuing operations elsewhere.