Cite as: 527 U. S. 423 (1999)
Opinion of the Court
have reaffirmed "a narrow approach to governmental tax immunity," New Mexico, 455 U. S., at 735; 7 we have closely confined the doctrine to "ba[r] only those taxes that [are] imposed directly on one sovereign by the other or that discriminat[e] against a sovereign or those with whom it deal[s]," Davis v. Michigan Dept. of Treasury, 489 U. S. 803, 811 (1989). In contracting the once expansive intergovern-mental tax immunity doctrine, we have recognized that the area is one over which Congress is the principal superintendent. See New Mexico, 455 U. S., at 737-738.
Indeed, congressional action coincided with the Graves turnaround. In the Public Salary Tax Act, under consideration before Graves was announced and enacted shortly thereafter, see Davis, 489 U. S., at 811-812, Congress consented to nondiscriminatory state and local taxation of federal employees' "pay or compensation for personal service," 4 U. S. C. § 111.8 Section 111 effectively "codified the result in Graves," and thereby "foreclosed the possibility that subsequent judicial reconsideration . . . might reestablish the broader interpretation of the immunity doctrine." Davis, 489 U. S., at 812; see also id., at 813 (the immunity for which § 111 provides is "coextensive with the prohibition against discriminatory taxes embodied in the modern constitutional doctrine of intergovernmental tax immunity").
7 New Mexico held that New Mexico transgressed no constitutional limit when it required federal contractors to pay the State's gross receipts tax for the "privilege" of doing business with the Federal Government in the State. 455 U. S., at 727, 744 (internal quotation marks omitted).
8 Section 111 provides: "The United States consents to the taxation of pay or compensation for personal service as an officer or employee of the United States, a territory or possession or political subdivision thereof, the government of the District of Columbia, or an agency or instrumentality of one or more of the foregoing, by a duly constituted taxing authority having jurisdiction, if the taxation does not discriminate against the officer or employee because of the source of the pay or compensation."
437
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