What is the test for establishing jurisdiction for a crime committed elsewhere?

"New York", United States of America

The following excerpt is from People v. Werblow, 148 N.E. 786, 241 N.Y. 55 (N.Y. 1925):

There was no suggestion that the same acts would have served without more to establish jurisdiction for a crime completed elsewhere. Hyde v. United States and Brown v. Elliott, supra. Whether they would have laid such a basis, we need not now consider. They approached closer to the stage of execution than the acts relied on here. Enough for present purposes that this was not the point decided.

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