Cite as: 512 U. S. 298 (1994)
Opinion of the Court
tioned; (3) discriminates against interstate commerce; or (4) is not fairly related to the services provided by the State. Complete Auto Transit, Inc. v. Brady, 430 U. S. 274, 279 (1977).
In "the unique context of foreign commerce," a State's power is further constrained because of "the special need for federal uniformity." Wardair Canada Inc. v. Florida Dept. of Revenue, 477 U. S. 1, 8 (1986). " 'In international relations and with respect to foreign intercourse and trade the people of the United States act through a single government with unified and adequate national power.' " Japan Line, Ltd. v. County of Los Angeles, 441 U. S., at 448, quoting Board of Trustees of Univ. of Ill. v. United States, 289 U. S. 48, 59 (1933). A tax affecting foreign commerce therefore raises two concerns in addition to the four delineated in Complete Auto. The first is prompted by "the enhanced risk of multiple taxation." Container Corp., 463 U. S., at 185. The second relates to the Federal Government's capacity to " 'speak with one voice when regulating commercial relations with foreign governments.' " Japan Line, 441 U. S., at 449, quoting Michelin Tire Corp. v. Wages, 423 U. S. 276, 285 (1976).
California's worldwide combined reporting system easily meets three of the four Complete Auto criteria. The nexus requirement is met by the business all three taxpayers— Barcal, BBI, and Colgate—did in California during the years in question. See Mobil Oil Corp. v. Commissioner of Taxes of Vt., 445 U. S. 425, 436-437 (1980).10 The "fair apportion-10 Amicus curiae the Government of the United Kingdom points to Quill Corp. v. North Dakota, 504 U. S. 298 (1992), which held that the Commerce Clause demands more of a connection than the "minimum contacts" that suffice to satisfy the due process nexus requirement for assertion of judicial jurisdiction. Brief for Government of United Kingdom as Amicus Curiae in No. 92-1384, pp. 24-25. Noting the absence of "any meaningful contact" between California and the activities of Barclays Group members operating exclusively outside the United States, id., at 25, the United Kingdom asserts that the trial court erred if it concluded
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