Gulf Caribe Maritime, Inc. v. Mobile County Revenue Commissioner

The vessels in question are instrumen-talities of interstate commerce.6 A state may tax such vessels without impermissi-bly burdening interstate commerce when the tax “[(1)] is applied to an activity with a substantial nexus with the taxing State, [(2)] is fairly apportioned, [(3)] does not discriminate against interstate commerce, and [(4)] is fairly related to the services provided by the State.” Complete Auto Transit, Inc. v. Brady, 430 U.S. 274, 279, 97“ S.Ct. 1076, 51 L.Ed.2d 326 (1977) (emphasis added). As a corollary, a domiciliary state is precluded from imposing an ad valorem tax on…