The United States Supreme Court case of United States ex rel. Girard Trust Co., Trustee, v. Helvering, Commissioner of Internal Revenue in 1936 revolved around the issue of taxation on trust income. The Girard Trust Company was a trustee for an estate that had been established by Stephen Girard's will and held stocks in corporations which paid dividends from sources outside Pennsylvania where the trust resided. The IRS sought to tax this dividend income as part of gross income under federal law but the trustees argued it should be exempt because it came from sources outside the U.S.. However, the court ruled against them stating that all net income derived from any source is taxable unless explicitly excluded by Congress and there was no such exclusion for foreign-source dividends received by domestic estates or trusts.

In the dissenting opinion for United States ex rel. Girard Trust Co., Trustee, v. Helvering, Commissioner of Internal Revenue (1936), it was argued that the majority's decision to tax a trust as an association rather than as a trust contradicted previous rulings and interpretations of the law by both Congress and courts. The dissenters believed that trusts should not be taxed in the same way corporations are because they do not have shareholders or directors and cannot engage in business activities like corporations can. They also pointed out that taxing trusts as associations could lead to double taxation since beneficiaries would also be liable for taxes on their income from the trust. Furthermore, they disagreed with how broadly the majority interpreted "association," arguing this interpretation went beyond what Congress intended when it wrote tax laws.