Cite as: 512 U. S. 298 (1994)
Opinion of the Court
see Container Corp., 463 U. S., at 184, we proceed to the "additional scrutiny" required when a State seeks to tax foreign commerce. Id., at 185. First of the two additional considerations is "the enhanced risk of multiple taxation." Ibid.
In Container Corp., we upheld application of California's combined reporting obligation to "foreign subsidiaries of domestic corporations," id., at 193 (emphasis added), against a charge that such application unconstitutionally exposed those subsidiaries to a risk of multiple international taxation.15 Barclays contends that its situation compels a different outcome, because application of the combined reporting obligation to foreign multinationals creates a " 'more aggravated' risk . . . of double taxation." Brief for Petitioner in No. 92-1384, at 32, quoting Nos. 325059 and 325061 (Super. Ct. Sacramento Cty., Aug. 20, 1987) (reprinted in App. to Pet. for Cert. in No. 92-1384, p. A-26). Barclays rests its argument on the observation that "foreign multinationals typically have more of their operations and entities outside of the United States [compared to] domestic multinationals, which typically have a smaller share of their operations and entities outside of the United States." Brief for Petitioner in No. 92-1384, at 33.16 As a result, a higher proportion of the income of a foreign multinational is subject to taxation by foreign sovereigns. This reality, Barclays concludes, means that for the foreign multinational, which must include all its foreign operations in the California combined reporting group, "the breadth of double taxation and the degree of burden on foreign commerce are greater than in the case of domestic multinationals." Ibid.
15 We reserved judgment on whether an altered analysis would be required where the taxpayer was part of a foreign-based enterprise. See Container Corp., 463 U. S., at 189, n. 26; id., at 195, n. 32.
16 To illustrate, Barclays points to its own operations: only 3 of the more than 220 entities in the Barclays Group did any business in the United States. Brief for Petitioner in No. 92-1384, at 33.
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