Cite as: 524 U. S. 103 (1998)
Opinion of the Court
Burke Act proviso," 502 U. S., at 259, had held that state tax laws applied to the Indian allottee at the expiration of the trust period: "[I]t was the alienability of the allotted lands . . . that the [Goudy] Court found of central significance." Id., at 263 (emphasis deleted). And we reiterated Goudy's point that, although it is possible for Congress to render reservation land alienable and still forbid States to tax it, this unlikely arrangement would not be presumed unless Congress "clearly manifested" such an intent. 502 U. S., at 263 (internal quotation marks and citation omitted).
The Court of Appeals thus erred in concluding that our holding in Yakima turned on the Burke Act proviso's express reference to taxability. Yakima, like Goudy, stands for the proposition that when Congress makes reservation lands freely alienable, it is "unmistakably clear" that Congress intends that land to be taxable by state and local governments, unless a contrary intent is "clearly manifested." 502 U. S., at 263.
The foregoing principle controls the disposition of this case. In §§ 5 and 6 of the Nelson Act, Congress provided for the public sale of pine lands and agricultural "homestead" lands by the Federal Government to non-Indians. Congress thereby removed that reservation land from federal protection and made it fully alienable. Under Goudy and Yakima, therefore, it is taxable. Indeed, this conclusion flows a fortiori from Goudy and Yakima: Those cases establish that Congress clearly intended reservation lands conveyed in fee to Indians to be subject to taxation; hence Congress surely intended reservation lands conveyed in fee to non-Indians also to be taxable. The Court of Appeals' contrary holding attributes to Congress the odd intent that parcels conveyed to Indians are to assume taxable status, while parcels sold to the general public are to remain tax exempt.
The Band essentially argues that, although its tax immunity lay dormant during the period when the eight parcels were held by non-Indians, its reacquisition of the lands in
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