Tax State I Ii Clause Taxation Property Sufficient

State's power of taxation may be limited by any or all of (1) CC, (2) 14th A, (3) P&I, (4) Import-Export Clause

(1) CC

(a) Property Taxes: Can you pass tax on property in trucks passing on I-10? (i) yes, so long as no excess burden on interstate commerce; (ii) state needs sufficient interest in property; (iii) tax situs, if has come to rest in state (EX: rail cars just sitting not unloaded in LA for a week, NO; unloaded in LA, YES)

(b) Income Taxes: (i) avoid risk of multiple taxation; (ii) tax needs to be fairly apportioned (EX: can only tax Exxon based on the % of employees or activity in LA)

(c) Sales and Use Taxes: (i) no tax on sale entirely in another state; (ii) can require a foreign seller to charge a "use tax" on good shipped into state if sufficient nexus with taxing state (use tax > sales tax is discrim); (iii) no multiple taxation