In the case of McGoldrick v. Compagnie Generale Transatlantique, 1939, the U.S. Supreme Court ruled in favor of New York City's Comptroller Joseph D. McGoldrick and upheld a city tax on fuel oil delivered at Brooklyn docks to foreign steamships owned by French company Compagnie Generale Transatlantique (CGT). The court held that this did not violate the Import-Export Clause or Commerce Clause of the Constitution as CGT argued because it was not an import tax but rather a sales tax applied equally to all similar transactions within city limits regardless of whether goods were destined for export or domestic use. This decision affirmed local governments' rights to levy taxes on commercial activities involving imported goods once they have entered into common mass of property within their jurisdiction.

In the dissenting opinion for McGoldrick v. Compagnie Generale Transatlantique, Justice McReynolds argued that New York City's tax on imports was unconstitutional as it interfered with federal authority over foreign commerce. He believed that the city's tax on goods imported from abroad and intended for immediate export violated the Import-Export Clause of the Constitution which prohibits states from imposing taxes on imports or exports without Congress' consent. According to him, this case represented a clear example of state interference in an area reserved exclusively for federal regulation - international trade policy. Furthermore, he contended that allowing such taxation would lead to chaotic conditions due to potential conflicting regulations by different local jurisdictions across America affecting import-export businesses negatively.