Joseph McKenna

“ The government, therefore, contends, and rightly contends, that domestic corporations are required to pay a tax on their incomes from all sources while foreign corporations are taxed only on their income from sources within the United States because, to repeat, only that income is earned under the protection of American laws. ”

“ There may be benefit in the inviting of foreign corporations into the United States-benefit in their investments and activities-and as counsel for the government points out, the domestic corporation gets the power of the United States to protect its interests and redress its wrongs in whatever part of the world its business may take it. ”

“ Even if we were to concede, as we cannot, that the Fifth Amendment in enjoining due process of law requires as part thereof equality of taxation, it certainly could not be held to apply to a subject-matter not within this country. ”