Cite as: 527 U. S. 423 (1999)
Opinion of Breyer, J.
nance requires the employer, obliged to withhold the tax, to determine where the employee has spent each working day and apportion related wages accordingly. Ordinance No. 1120, §§ 3, 4. The task of apportioning an employee's workday is more complicated and more closely connected to official duties than simply determining where an employee resides—the conventional "income tax" recordkeeping requirement. Similarly, a tax liability that arises from having worked on a particular day in a particular place, together with related and complex recordkeeping requirements, creates a risk that the tax will have a practical influence upon official decisions in a way that an ordinary income tax will not. (Consider, for example, a federal criminal case in which the defendant seeks a change of venue to Jefferson County. E. g., United States v. Tokars, 839 F. Supp. 1578 (ND Ga. 1993); see Jefferson County v. Acker, 92 F. 3d 1561, 1573, and n. 18 (CA11 1996).) Further, the ordinance's language says it is unlawful for a federal employee who has not paid the tax to perform his work—that is, it prohibits "engag[ing]" in that work. Ordinance No. 1120, § 2. This language, which I assume could not actually authorize an injunction against the performance of federal work, could nonetheless have an unwelcome impact on a conscientious but tax-delinquent judge who has sworn to uphold the law.
I recognize that one might find income taxes that embody one or two of the features that I have just discussed. Income taxes come in many shapes and sizes. But I do not claim that any one or two of the considerations I have mentioned is sufficient to prove my point. Rather, it is all these features taken together that tip the balance.
The majority either ignores or attempts to distinguish each of these features on its own, as by itself potentially unconsitutional or found in other income taxes. Ante, at 439-442. But it is a consideration of the whole, not of each separate part, that leads to my conclusion. To properly characterize a tax, all of its distinguishing features must be
453
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