In the case of New York ex rel. Edward and John Burke, Limited v. Wells et al., 1907, the U.S Supreme Court ruled on a dispute regarding taxation laws in New York City. The plaintiffs were British citizens who owned property in NYC but resided abroad; they argued that their properties should not be subject to local taxes because they did not personally reside within the city or state. They claimed this was a violation of international law principles protecting foreign nationals from discriminatory treatment by host countries (in this case, the United States). However, the court disagreed with their argument and upheld NYC's right to tax all real estate within its jurisdiction regardless of where owners lived or their nationality status. The ruling affirmed that cities have broad powers to levy taxes for public purposes as long as such actions do not violate constitutional protections against discrimination based on race or national origin.

In the dissenting opinion for New York ex rel. Edward and John Burke, Limited v. Wells et al., Justice Harlan disagreed with the majority's ruling that a foreign corporation could be taxed on its entire capital by a state in which it only conducted part of its business operations. He argued that this interpretation violated both due process and equal protection clauses of the Fourteenth Amendment as it resulted in double taxation - once where the corporation was incorporated and again where it did business. Harlan believed such an approach would discourage interstate commerce by placing undue burdens on corporations operating across multiple states, thus undermining economic growth and development nationally.