Cite as: 532 U. S. 645 (2001)
Opinion of the Court
government." Id., at 137-138 (quoting Exxon Corp. v. Department of Revenue of Wis., 447 U. S. 207, 228 (1980)).
Merrion, however, was careful to note that an Indian tribe's inherent power to tax only extended to " 'transactions occurring on trust lands and significantly involving a tribe or its members.' " 455 U. S., at 137 (emphasis added) (quoting Washington v. Confederated Tribes of Colville Reservation, 447 U. S. 134, 152 (1980)). There are undoubtedly parts of the Merrion opinion that suggest a broader scope for tribal taxing authority than the quoted language above.4 But Merrion involved a tax that only applied to activity occurring on the reservation, and its holding is therefore easily reconcilable with the Montana-Strate line of authority, which we deem to be controlling. See Merrion, supra, at 142 ("[A] tribe has no authority over a nonmember until the nonmember enters tribal lands or conducts business with the tribe"). An Indian tribe's sovereign power to tax—whatever its derivation—reaches no further than tribal land.5
4 Merrion v. Jicarilla Apache Tribe, 455 U. S. 130 (1982), for example, referenced the decision of the Court of Appeals for the Eighth Circuit in Buster v. Wright, 135 F. 947 (1905). But we have never endorsed Buster's statement that an Indian tribe's "jurisdiction to govern the inhabitants of a country is not conditioned or limited by the title to the land which they occupy in it." Id., at 951. Accordingly, beyond any guidance it might provide as to the type of consensual relationship contemplated by the first exception of Montana v. United States, 450 U. S. 544, 566 (1981), Buster is not an authoritative precedent.
5 We find misplaced the Court of Appeals' reliance upon 18 U. S. C. § 1151, a statute conferring upon Indian tribes jurisdiction over certain criminal acts occurring in "Indian country," or "all land within the limits of any Indian reservation under the jurisdiction of the United States Government, notwithstanding the issuance of any patent, and, including rights-of-way running through the reservation." See also Duro v. Reina, 495 U. S. 676, 680, n. 1 (1990). Although § 1151 has been relied upon to demarcate state, federal, and tribal jurisdiction over criminal and civil matters, see DeCoteau v. District County Court for Tenth Judicial Dist., 420 U. S. 425, 427, n. 2 (1975) ("While § 1151 is concerned, on its face, only
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