In Burnet, the Supreme Court held that the State of New South Wales was a "foreign country" within the meaning of ยง 238(a) of the 1921 Revenue Act, which granted a credit for taxes paid by a domestic corporation to "any foreign country."
In Slater, the Supreme Court acknowledged the ability of a federal court to adjudicate the case, but it restricted the action to apply only the Mexican-law standard of care.