In the case of People of Porto Rico v. Emmanuel, Baron Du Laurens D'Oisela (1914), the U.S Supreme Court ruled on a matter involving inheritance laws in Puerto Rico. The defendant, Baron Du Laurens D'Oisela, was accused by the government of Puerto Rico for not paying taxes on an inherited estate from his late wife who was a resident of Puerto Rico at her time of death. He argued that he should be exempted from these taxes because he is a French citizen and resides in France. However, the court held that regardless of his nationality or place residence, as long as his wife's property is located within their jurisdiction - which it was - then they have every right to tax him accordingly under local law. This decision affirmed that territorial governments like Puerto Rico can impose inheritance taxes even if beneficiaries live abroad.

In the dissenting opinion for the case of People of Porto Rico v. Emmanuel, Baron du Laurens d'Oisela (1914), Justice Oliver Wendell Holmes Jr. argued that Puerto Rico should be considered a territory rather than a foreign country in relation to U.S law. He disagreed with the majority's decision which held that Puerto Rico was not part of the United States for purposes of constitutional restrictions on taxation and thus could impose taxes on imported goods from mainland US without violating Constitution’s Uniformity Clause. Holmes believed this interpretation was inconsistent with previous rulings regarding territories acquired by the U.S., such as those following Spanish-American War, where it had been determined they were subject to American laws despite their unique status as non-state territories.