464
Opinion of the Court
The Tribe seeks to block the State from exercising its ordinary prerogative to tax the income of every resident; in particular, the Tribe seeks to shelter from state taxation the income of tribal members who live in Oklahoma outside Indian country but work for the Tribe on tribal lands.13 For
the exception the Tribe would carve out of the State's taxing authority, the Tribe gains no support from the rule that Indians and Indian tribes are generally immune from state taxation, McClanahan v. Arizona Tax Comm'n, 411 U. S. 164 (1973), as this principle does not operate outside Indian country. Oklahoma Tax Comm'n v. Sac and Fox Nation, 508 U. S. 114, 123-126 (1993).
Notably, the Tribe has not asserted here, or before the
Court of Appeals, that the State's tax infringes on tribal self-governance. See Brief in Opposition 9-10 ("infringement" question is not presented to this Court); Brief for Respondent 42, n. 37; see also Sac and Fox, 508 U. S., at 126 (reserving question "whether the Tribe's right to self-governance could operate independently of its territorial jurisdiction to pre-empt the State's ability to tax income
Tax Project: International Aspects of United States Income Taxation 6 (1987).
Concerning salaries of United States resident "diplomats and employees of international organizations," post, at 470, the dissent speaks of "treaties" as the wellsprings of "an exception" to otherwise governing tax law. That is not quite right. It is dominantly United States internal law that sets the ground rules for exemptions accorded employees of foreign governments and international organizations. In return for exemption of foreign government employees from United States federal taxation, § 893 of the Internal Revenue Code requires that the employer government grant equivalent exemption to United States Government employees performing similar services abroad. 26 U. S. C. § 893(a)(3); see Toll v. Moreno, 458 U. S. 1, 15-16 (1982) (identifying statutory genesis of § 893 exemption); 1 J. Isenbergh, International Taxation 393-394 (1990).
13 The Tribe's claim, as presented in this case, is a narrow one. The Tribe does not assert here its authority to tax the income of these tribal members. Nor does it complain that Oklahoma fails to award a credit against state taxes for taxes paid to the Tribe.
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