I believe the "fundamental limitation" on the doctrine of implide powers is and forever different for all levels. In some cases power, is the ability to control the masses or the media. In other cases, it's the secrets you behold that can save, or destroy lives of others singularly, or in multitudes, whether figuratively or literally. Implide powers is in a sense who ever can win over the masses or better decieves the masses, has less limited powers.
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a doctrine that federal powers should be curtailed and returned to the individual states
Your question did not specify any countries, but the Monroe Doctrine sought to put all of the Western Hemisphere off limits to European political or military activity.
President James Monroe.
He made a small military intervention to ward off the European powers, proclaimed his famous Roosevelt Corollary to the Monroe Doctrine, and in 1905 obtained Dominican agreement for U.S. administration of Dominican customs,
Congressional powers not expressed are implied powers.