Cite as: 508 U. S. 114 (1993)
Opinion of the Court
to the earnings tax. Ch. 4, § 402. The motor vehicle tax and registration provisions apply to "all motor vehicles owned by a resident of, and principally garaged within the jurisdiction of the Sac and Fox Tribe of Indians of Oklahoma." Ch. 8, § 802.
The Oklahoma Tax Commission (Commission) also administers income taxes and motor vehicle taxes and fees. Oklahoma Income Tax Act, Okla. Stat., Tit. 68, § 2351 et seq. (1981 and Supp. 1990). All residents, and nonresidents of Oklahoma who receive income in the State, are subject to the Oklahoma income tax. §§ 2362, 2368. Oklahoma contends that the tax applies equally to members of Indian tribes and to nonmembers. Thus, it claims that those residents of Oklahoma who also reside within Sac and Fox jurisdiction are subject to both state and tribal income taxes.
Pursuant to the Vehicle Excise Tax Act, Okla. Stat., Tit. 68, § 2101 et seq. (1981 and Supp. 1990), the State levies an excise tax, calculated as a percentage of a vehicle's value, "upon the transfer of legal ownership of any vehicle registered in th[e] state and upon the use of any vehicle registered in th[e] state." § 2103(A). The Commission collects the tax "at the time of the issuance of a certificate of title for any such vehicle." Ibid. Finally, the Commission assesses a vehicle registration fee for all vehicles registered with the State of Oklahoma, see Oklahoma Vehicle License and Registration Act, Okla. Stat., Tit. 47, § 1101 et seq. (Supp. 1990), at the annual rate of $15 plus a percentage of the value of the car, § 1132(A)(1). Like the vehicle excise tax, see Tit. 68, § 2102, the vehicle registration fees are to provide funds for "general governmental functions," Tit. 47, § 1103.
The Commission contends that tribal members must register their vehicles with the State, just as everyone else who lives within Oklahoma must do. The Tribe, however, requires Sac and Fox tribal members who live and garage cars within Sac and Fox territory to register those cars with the Tribe and to use tribal license plates. Oklahoma considers
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