Cite as: 507 U. S. 60 (1993)
Opinion of the Court
diction claimed the right to tax a given value in full, and another taxing jurisdiction claimed the right to tax the same entity in part—a combination resulting necessarily in double taxation." 463 U. S., at 188. That the Japan Line Court adopted a rule requiring States to forgo assessing property taxes against foreign-owned cargo containers "was by no means unfair, because the rule did no more than reflect consistent international practice and express federal policy." Container Corp., supra, at 190.
Second, we noted that "in [Container Corp.], unlike Japan Line, the Executive Branch ha[d] decided not to file an amicus curiae brief in opposition to the state tax." 463 U. S., at 195. Together with our conclusion that the California income tax did not result in automatic double taxation, the Government's nonintervention suggested that the tax presented no serious threat to United States foreign policy. See id., at 196.
B
Before reconciling the holdings of Japan Line and Container Corp., we first address the Complete Auto test, a test we assumed, arguendo, was satisfied by the tax in Japan Line. 441 U. S., at 451. A state tax satisfies the Complete Auto Domestic Commerce Clause test "when the tax is applied to an activity with a substantial nexus with the taxing State, is fairly apportioned, does not discriminate against interstate commerce, and is fairly related to the services provided by the State." Complete Auto, supra, at 279. Because Itel accepts the Supreme Court of Tennessee's conclusion that "Tennessee's sales tax meets the four-fold requirements of Complete Auto," 814 S. W. 2d, at 36, we need not retrace that court's careful analysis. We do note, however, that Tennessee's compliance with the Complete Auto test has relevance to our conclusion that the state tax meets those inquiries unique to the Foreign Commerce Clause. That the tax is a fair measure of the State's contacts with a given commercial transaction in all four aspects of the Complete Auto test
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