The case of United States v. First National Bank of Detroit, Minnesota in 1913 revolved around the issue of whether a national bank could be held liable for taxes on its shares that were owned by non-residents. The Supreme Court ruled in favor of the U.S., stating that under federal law, states have the right to tax shares in national banks as long as they do not discriminate against out-of-state shareholders. This decision was based on an interpretation of Section 5219 Revised Statutes which allows state taxation "not at a greater rate than is assessed upon other moneyed capital." The court found no discrimination because all shareholders, regardless if they are residents or non-residents, were taxed equally according to their share ownerships.

The dissenting opinion in the case of UNITED STATES v. FIRST NATIONAL BANK OF DETROIT, MINNESOTA argued that the majority's decision was a misinterpretation of the National Bank Act. The dissenters believed that this act did not grant national banks immunity from state taxation but instead provided a method for such taxation to occur without interfering with federal operations. They contended that allowing states to tax these entities would not infringe upon federal sovereignty or impede its functions, as long as it is done within reasonable limits and does not discriminate against national banks compared to other corporations. Furthermore, they pointed out inconsistencies in previous court decisions regarding similar issues and emphasized the need for clearer guidelines on matters involving state versus federal jurisdiction over financial institutions.