330
Opinion of the Court
of the percentage deduction provision from the intangibles tax scheme. Id., at 504-505, 430 S. E. 2d, at 501-502.
Both parties appealed to the Supreme Court of North Carolina, which reversed. Fulton Corp. v. Justus, 338 N. C. 472, 450 S. E. 2d 728 (1994). Without addressing whether the intangibles tax was facially discriminatory, the court read Darnell to compel a conclusion that the scheme here imposed a valid compensating tax, 338 N. C., at 477-480, 450 S. E. 2d, at 731-734, and it rejected Fulton's contention that Darnell had been overruled implicitly by this Court's more recent decisions on interstate taxation. 338 N. C., at 480- 482, 450 S. E. 2d, at 734-735. The court reasoned, moreover, that corporate income is generally related to the value of corporate stock, and that in practice, the burden on interstate commerce imposed by the intangibles tax was less than that placed on intrastate commerce by the corporate income tax. Id., at 479-480, 450 S. E. 2d, at 733-734.
We granted certiorari, 514 U. S. 1062 (1995), and now reverse.
II
The constitutional provision of power "[t]o regulate Commerce . . . among the several States," U. S. Const., Art. I, § 8, cl. 3, has long been seen as a limitation on state regulatory powers, as well as an affirmative grant of congressional authority. See, e. g., Oklahoma Tax Comm'n v. Jefferson Lines, Inc., 514 U. S. 175, 179-180 (1995); Gibbons v. Ogden, 9 Wheat. 1 (1824) (Marshall, C. J.) (dictum). In its negative aspect, the Commerce Clause "prohibits economic protectionism—that is, 'regulatory measures designed to benefit in-state economic interests by burdening out-of-state competitors.' " Associated Industries of Mo. v. Lohman, 511 U. S. 641, 647 (1994) (quoting New Energy Co. of Ind. v. Limbach, 486 U. S. 269, 273-274 (1988)). This reading effectuates the Framers' purpose to "preven[t] a State from retreating into economic isolation or jeopardizing the welfare of the Nation
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