Cite as: 517 U. S. 843 (1996)
Opinion of the Court
taxes to the transactions at issue because each tax was, in effect, a tax on exports. The type of charter contract at issue in Hvoslef was "in contemplation of law a mere contract of affreightment," 237 U. S., at 16, and we found that the tax, as applied to charters for exportation, "was in substance a tax on the exportation; and a tax on the exportation is a tax on the exports," id., at 17. Likewise, in Thames & Mersey, we found that "proper insurance during the voyage is one of the necessities of exportation" and that "the taxation of policies insuring cargoes during their transit to foreign ports is as much a burden on exporting as if it were laid on the charter parties, the bills of lading, or the goods themselves." 237 U. S., at 27.
Shortly after Hvoslef and Thames & Mersey, the Court rejected an attempt to shield from taxation the net income of a company engaged in the export business. William E. Peck & Co. v. Lowe, 247 U. S. 165 (1918). In accordance with the analysis set out in Turpin, we found both that the tax was nondiscriminatory and that "[i]t is not laid on articles in course of exportation or on anything which inherently or by the usages of commerce is embraced in exportation or any of its processes." 247 U. S., at 174.
Only a few years later the Court struck down the application of a tax on the export sale of certain baseball equipment. See A. G. Spalding & Bros. v. Edwards, 262 U. S. 66 (1923). Although the tax was clearly nondiscriminatory, we explained that the goods being taxed had entered the course of exportation when they were delivered to the export carrier. Id., at 70. Because the taxable event, the transfer of title, occurred at the same moment the goods entered the course of exportation, we held that the tax could not constitutionally be applied to the export sale. Id., at 69-70.
The Court has strictly enforced the Export Clause's prohibition against federal taxation of goods in export transit, and we have extended that protection to certain services and activities closely related to the export process. We have not,
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