Cite as: 527 U. S. 423 (1999)
Opinion of the Court
As Howard indicates, whether Jefferson County's license tax fits within the Public Salary Tax Act's allowance is a question of federal law. The practical impact, not the State's name tag, determines the answer to that question. See also Detroit v. Murray Corp. of America, 355 U. S. 489, 492 (1958) ("[I]n determining whether th[e] ta[x] violate[s] the Government's constitutional immunity we must look through form and behind labels to substance."); cf. Ohio Oil Co. v. Conway, 281 U. S. 146, 159 (1930) (compatibly with the Fourteenth Amendment, a State "may impose different specific taxes upon different trades and professions"; "[i]n levying such taxes, the State is not required to resort to close distinctions or to maintain a precise, scientific uniformity with reference to composition, use or value"). This much is beyond genuine debate.
B
The judges acknowledge that Jefferson County's Ordinance is valid if it "impose[s] a true tax on . . . income," but argue that the Ordinance ranks instead as an impermissible licensing scheme. Brief for Respondents 13-14, 27-33. Two aspects of the Ordinance, they say, remove the tax from the Public Salary Tax Act shelter for "taxation of pay or compensation for personal service," 4 U. S. C. § 111, and render the tax unconstitutional. First, the judges urge, the very words of the Ordinance make it unlawful for them and others to engage in their occupations without paying the license fee. Second, they maintain, the complete exclusion of persons who hold other Alabama licenses, however low the fee in comparison to Jefferson County's tax, is inconsistent with a true tax on income, but entirely consistent with a regulatory scheme requiring persons to have one and only one occupational license in a State. We are not persuaded.
Jefferson County's Ordinance declares it "unlawful . . . to engage in" a covered occupation (as pertinent here, to carry out the duties of a federal judge) without paying the license fee. Ordinance No. 1120, § 2. Based on the quoted words,
439
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