The case of Mellon, Secretary of the Treasury of the United States, et al. v. Orinoco Iron Company in 1924 revolved around a dispute over tax payments. The Orinoco Iron Company was incorporated in Delaware but operated primarily in Venezuela and claimed that its income from operations abroad should not be subject to U.S taxation under existing laws at that time. However, Andrew W. Mellon, then Secretary of the Treasury argued otherwise stating that as a US corporation it owed taxes on all its income regardless where earned . The Supreme Court ruled against Orinoco Iron Company's claim by upholding an earlier decision made by lower courts which stated that American corporations were liable for federal taxes on their worldwide incomes irrespective of where they are generated or if double taxation may occur due to foreign tax liabilities.

In the case of Mellon, Secretary of the Treasury of The United States, et al. v. Orinoco Iron Company (1924), Justice Holmes dissented from the majority opinion. He argued that Congress had not intended to exempt corporations like Orinoco from paying income tax on dividends received from foreign subsidiaries when it passed a 1918 law providing such an exemption for domestic corporations receiving dividends from other domestic companies. According to Justice Holmes, this interpretation was supported by both the language and legislative history of the statute in question. Furthermore, he contended that if Congress had meant to extend this benefit to all types of corporations regardless their source country or nature they would have done so explicitly rather than leaving it up for judicial interpretation.