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Opinion of the Court
tiny); Northwest Airlines, Inc. v. County of Kent, 510 U. S. 355, 373, and n. 19 (1994) (same).
2
As in Container Corp. and Wardair, we discern no "specific indications of congressional intent" to bar the state action here challenged. Our decision upholding California's franchise tax in Container Corp. left the ball in Congress' court; had Congress, the branch responsible for the regulation of foreign commerce, see U. S. Const., Art. I, § 8, cl. 3, considered nationally uniform use of separate accounting "essential," Japan Line, 441 U. S., at 448, it could have enacted legislation prohibiting the States from taxing corporate income based on the worldwide combined reporting method. In the 11 years that have elapsed since our decision in Container Corp., Congress has failed to enact such legislation.
In the past three decades—both before and after Container Corp.—Congress, aware that foreign governments were displeased with States' worldwide combined reporting requirements,22 has on many occasions studied state taxation
22 The governments of many of our trading partners have expressed their strong disapproval of California's method of taxation, as demonstrated by the amici briefs in support of Barclays from the Government of the United Kingdom, and from the Member States of the European Communities (Belgium, Denmark, France, Germany, Greece, Ireland, Italy, Luxembourg, the Netherlands, Portugal, and Spain) and the governments of Australia, Austria, Canada, Finland, Japan, Norway, Sweden, and Switzerland. Barclays has also directed our attention to a series of diplomatic notes similarly protesting the tax. See, e. g., App. in No. 92-1384, at A-92 to A-123, A-127 to A-128, A-131 to A-138; see also p. A-603 (letter from Secretary of State George Schultz to California Governor Deukmejian (Jan. 30, 1986)) ("The Department of State has received diplomatic notes complaining about state use of the worldwide unitary method of taxation from virtually every developed country in the world."). The British Parliament has gone further, enacting retaliatory legislation that would, if implemented, tax United States corporations on dividends they receive from their United Kingdom subsidiaries. See Finance Act 1985, pt. 2, ch. 1, § 54, and sch. 13, ¶5 (Eng.), reenacted in Income and Corporation Taxes Act 1988, pt. 18, ch. 3, § 812 and sch. 30, ¶¶ 20, 21 (Eng.).
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