Cite as: 517 U. S. 843 (1996)
Opinion of the Court
"The States are forbidden to lay a duty on exports, and the United States are forbidden to lay a tax or duty on articles exported from any State. There is some diversity in language, but none is perceivable in the act which is prohibited." Brown v. Maryland, 12 Wheat. 419, 445 (1827).
See also Kosydar v. National Cash Register Co., 417 U. S. 62, 67, n. 5 (1974); Hvoslef, supra, at 13-14; Cornell, 192 U. S., at 427-428; Turpin, 117 U. S., at 506-507. The Government argues that our longstanding parallel interpretations of the two Clauses require judgment in its favor. We disagree.
In Michelin, we addressed whether a State could impose a nondiscriminatory ad valorem property tax on imported goods that were no longer in import transit. Michelin, which imported tires from Canada and France and stored them in a warehouse, argued that Georgia could not constitutionally assess ad valorem property taxes against its imported tires. We explained that "[t]he Framers of the Constitution . . . sought to alleviate three main concerns": (i) ensuring that the Federal Government speaks with one voice when regulating foreign commerce; (ii) preserving import revenues as a major source of federal revenue; and (iii) preventing disharmony likely to be caused if seaboard States taxed goods coming through their ports. Michelin, supra, at 285-286. The Court found that nondiscriminatory ad valorem taxes violate none of these policies. A century earlier, however, the Court had ruled that, under the "original package doctrine," a State could not impose such a tax until the goods had lost their character as imports and had been incorporated into the mass of property in the State. Low v. Austin, 13 Wall. 29, 34 (1872). The Michelin Court overruled Low and held that the nondiscriminatory property tax levied on Michelin's inventory of imported tires did not violate the Import-Export Clause because it was not an impost or duty on imports. 423 U. S., at 301. See also Limbach v. Hooven & Allison Co., 466 U. S. 353 (1984) (reaffirming that
853
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