Cite as: 508 U. S. 114 (1993)
Opinion of the Court
registration fee. See Okla. Stat., Tit. 47, § 1125(C) (Supp. 1990) (exempting "visiting nonresident[s]" from registration and hence from payment of both taxes).
We agree with the Court of Appeals that the excise tax and registration fees strongly resemble the taxes that we held pre-empted in Washington v. Confederated Tribes of Colville Reservation, 447 U. S. 134 (1980). Prior to Colville, we held in Moe v. Confederated Salish and Kootenai Tribes of Flathead Reservation, 425 U. S. 463 (1976), that Montana could not apply its personal property tax to motor vehicles owned by tribal members who lived on the reservation. Id., at 480-481. To avoid the Moe holding, in Colville Washington described its motor vehicle taxes as "excise tax[es] for the 'privilege' of using the covered vehicle in the State." Colville, supra, at 162. Although Washington called its taxes "excise taxes," those taxes, like the taxes we held pre-empted in Moe, were "assessed annually at a certain percentage of fair market value" of the vehicle, and the State sought to impose them "upon vehicles owned by the Tribe or its members and used both on and off the reservation." 447 U. S., at 162. In Colville, we rejected Washington's distinction of Moe because the only difference between the Washington taxes and the Montana taxes was their names. 447 U. S., at 163. We did "not think Moe and McClanahan c[ould] be this easily circumvented. While Washington may well be free to levy a tax on the use outside the reservation of Indian-owned vehicles, it may not under that rubric accomplish what Moe held was prohibited." Ibid.
Oklahoma's taxes are no different than those in Moe and Colville. Like the taxes in both those cases, the excise tax and registration fee are imposed in addition to a sales tax; the two taxes are imposed for use both on and off Indian country; and the registration fees are assessed annually based on a percentage of the value of the vehicle. Oklahoma may not avoid our precedent by avoiding the name "personal
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