In the case of New York Life Insurance Company v. Deer Lodge County, 1913, the U.S. Supreme Court ruled that a state cannot tax life insurance policies issued by companies not incorporated in that state to residents of said state if those policies were delivered outside the boundaries of the taxing jurisdiction. The court held that such taxation would violate due process rights under the Fourteenth Amendment as it would be an attempt to regulate commerce and contracts beyond its borders. This decision was based on previous rulings which established that states have no power over acts done or contracts made in other jurisdictions unless brought within their reach by being owned or possessed within their territory at some point during ownership.

In the dissenting opinion for New York Life Insurance Company v. Deer Lodge County, it was argued that the majority's decision to exempt insurance companies from taxation in Montana contradicted previous rulings and principles of fairness. The dissent emphasized that corporations doing business across state lines should not be immune from local taxes simply because they are incorporated elsewhere. They pointed out that such a ruling would create an unfair advantage for foreign corporations over domestic ones, undermining states' rights to tax businesses operating within their borders. Furthermore, they disagreed with the majority's interpretation of "home office" as only referring to a company’s headquarters rather than any place where significant business activity occurs. This narrow definition could potentially allow large corporations to avoid paying taxes in many jurisdictions where they operate by claiming their main offices were located elsewhere.