In the case of Rowan Companies, Inc. v. United States (1980), the U.S Supreme Court ruled in favor of Rowan Companies, a drilling company that had deducted from its taxes helicopter expenses used for transporting workers to and from offshore oil rigs. The Internal Revenue Service (IRS) argued these costs should be allocated between deductible transportation expenses and non-deductible capital expenditures related to the construction of facilities on those rigs. However, the court held that under Section 263 of the Internal Revenue Code, which allows deductions for ordinary and necessary business expenses but not capital expenditures, all such costs were fully deductible as they were incurred for moving employees rather than goods or materials integral to construction work at sea platforms.

The dissenting opinion in the case of Rowan Cos., Inc. v. United States argued that the majority's decision to deny tax deductions for payments made by Rowan Companies, Inc. to foreign governments was incorrect and inconsistent with previous court rulings on similar matters. The dissent emphasized that these payments were necessary business expenses incurred while conducting operations abroad, and thus should be considered deductible under U.S tax law as they would have been if made within the United States itself. They contended that denying such deductions essentially penalized American companies for doing business overseas, which contradicted established principles of international commerce and taxation fairness.