64
Opinion of the Court
well, 814 S. W. 2d 29, 34 (1991). Instead, the court held, Congress merely prohibits the imposition of federal customs duties on containers, and that prohibition does not pre-empt Tennessee's sales tax, which is not a customs duty. Id., at 35-36.
Itel also claimed that Tennessee's tax violates the Foreign Commerce Clause principles announced in Japan Line, Ltd. v. County of Los Angeles, supra, because the tax "prevents the Federal Government from 'speaking with one voice when regulating commercial relations with foreign governments' " and "creates a substantial risk of international multiple taxation." Id., at 451. The state court rejected this argument because the tax is imposed only upon a discrete transaction— the transferred possession of cargo containers within Tennessee—and therefore does not risk multiple taxation or impede federal regulation of foreign trade. 814 S. W. 2d, at 36-37.
Last, Itel argued that the tax violates the Import-Export Clause because it prevents the Federal Government from speaking with one voice in international affairs and is a tax on exports that is per se impermissible under Richfield Oil Corp. v. State Bd. of Equalization, 329 U. S. 69 (1946). The court dismissed Itel's one voice argument for reasons similar to those given in its Commerce Clause analysis, 814 S. W. 2d, at 38, and held the Tennessee tax does not violate Richfield's per se restriction because it is not a direct tax on the value of goods destined for export. 814 S. W. 2d, at 33. We granted certiorari, 502 U. S. 1090 (1992), and now affirm.
II
Itel's primary challenge is that the imposition of the Tennessee sales tax is proscribed by both the 1972 and 1956 Container Conventions. The Conventions restrict the authority of signatories to tax cargo containers by requiring signatory nations to grant the containers "temporary admission" into their borders, subject to exportation "within three months
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