William. G. McAdoo, secretary of the treasury, issues Treasury Decision 2313, stating that the domestically earned income of foreigners is subject to the Federal income tax.  This is in conflict with Brushaber v. Union Pacific Railroad, which only addressed the excise (i.e. Indirect tax (“a tax exacted indirectly from a person other than the one on whom the ultimate burden of the tax is expected to fall.” [Such as tariffs on imports, or excises]——Webster’s Unabridged Dictionary Unabridged Dictionary)) nature of the tax.

       [restored 6/11/2022] Thanks to Jim Lorenz for this entry.