648
Opinion of the Court
ity or incident, and the other upon another, but the sum is the same when the reckoning is closed." Henneford v. Silas Mason Co., 300 U. S. 577, 584 (1937).
To justify any levy as a compensatory tax, "a State must, as a threshold matter, 'identif[y] . . . the [intrastate tax] burden for which the State is attempting to compensate.' " Oregon Waste, ante, at 103 (quoting Maryland, supra, at 758). Respondents urge that the local sales taxes imposed by over a thousand political subdivisions within the State provide the burden on intrastate commerce that Missouri seeks to counterbalance through the use tax in this case. There is no dispute that sales taxes and use taxes such as those at issue here are imposed on "substantially equivalent event[s]." Maryland, supra, at 759. Silas Mason itself approved a system of sales and use taxes, and we have recognized that "[a] use tax is generally perceived as a necessary complement to [a] sales tax." Williams v. Vermont, 472 U. S. 14, 24 (1985). Cf. Halliburton Oil Well Cementing Co. v. Reily, 373 U. S. 64, 66 (1963) ("[T]he purpose of such a sales-use tax scheme is to make all tangible property used or consumed in the State subject to a uniform tax burden irrespective of whether it is acquired within the State . . . or from without the State").
Missouri's use tax scheme, however, runs afoul of the basic requirement that, for a tax system to be "compensatory," the burdens imposed on interstate and intrastate commerce must be equal. As we observed in Maryland v. Louisiana, the "common thread running through the cases upholding compensatory taxes is the equality of treatment between local and interstate commerce." 451 U. S., at 759. See also Halliburton, supra, at 70 ("[E]qual treatment for in-state and out-of-state taxpayers similarly situated is the condition precedent for a valid use tax on goods imported from out-of-state"). Where a State imposes equivalent sales and use taxes, we have upheld the system under the Commerce Clause. See Silas Mason, supra, at 584-587. But in Mis-
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