Cite as: 507 U. S. 60 (1993)
Opinion of the Court
The first and third components in this formulation mirror inquiries we have already undertaken as part of our Foreign Commerce Clause analysis. That is, the one voice component of the Michelin test is the same as the one voice component of our Japan Line test. Japan Line, 441 U. S., at 449-450, n. 14. And the state harmony component parallels the four Complete Auto requirements of the Foreign and Domestic Commerce Clause. Department of Revenue of Wash. v. Association of Wash. Stevedoring Cos., 435 U. S. 734, 754-755 (1978) ("The third Import-Export Clause policy . . . is vindicated if the tax falls upon a taxpayer with a reasonable nexus to the State, is properly apportioned, does not discriminate, and relates reasonably to services provided by the State"). Having concluded that the Tennessee tax survives Commerce Clause scrutiny, we must conclude the tax is consistent with the first and third component of our Michelin test.
This leaves only Michelin's second component: ensuring that import revenues are not being diverted from the Federal Government. We need not provide a detailed explanation of what, if any, substantive limits this aspect of Michelin places on state taxation of goods flowing through international channels, for the tax here is not a tax on importation or imported goods, but a tax on a business transaction occurring within the taxing State. The tax does not draw revenue from the importation process and so does not divert import revenue from the Federal Government. For similar reasons, we reject the argument that the tax violates the prohibition on the direct taxation of imports and exports "in transit," the rule we followed in Richfield Oil, 329 U. S., at 78-79, 84. Even assuming that rule has not been altered by the approach we adopted in Michelin, it is inapplicable here. Tennessee's sales tax is levied on leases transferring temporary possession of containers to third parties in Tennessee; it is not levied on the containers themselves or on the goods being imported in those containers. The tax thus does not divert import revenue from the Federal Government because
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