William Howard Taft

“ Considerations of policy toward foreign countries may very well justify an exemption of the foreign corporations from taxes that might legitimately be imposed on them, but which Congress does not think it wise to exact. Such considerations justify a different classification of foreign corporations doing business in the United States either of manufacture or purchase and making profit out of that business in other countries from that which would apply to its own corporations. ”

“ The power of Congress to make a difference between the tax on foreign corporations and that of domestic corporations is not measured by the same rule as that for determining whether taxes imposed by one state upon the profits of a manufacturing corporation are an imposition of tax upon a subject-matter not within the jurisdiction of the taxing state. ”

“ Gains, profits and income derived from the purchase of personal property within and its sale without the United States or from the purchase of personal property without and its sale within the United States, shall be treated as derived entirely from the country in which sold. ”