Scandinavian Airlines System, Inc. v. County of Los Angeles et al.

Abstract

States as international persons — Composite States — Federal States — Foreign relations of — Position of component states — Power of such states to impose taxation discriminating between foreign nations — The law of the United States of America.

Treaties — Special kinds of — Double taxation treaties — Application to ad valorem taxes on movables — Taxation of aircraft registered in one contracting State with home port in that State operating in international commerce — Tax imposed by state statute in federal State — Supremacy of federal treaty over state law — Double Taxation Conventions between United States and Sweden, Denmark and Norway — The law of the United States of America.

Jurisdiction — Territorial — Over property — Taxation — State personal property tax — Application on apportionment basis to foreign registered aircraft — Aircraft foreign — owned and operating in international commerce — Whether tax valid — Whether tax in violation of Treaties to avoid double taxation between United States and Sweden, Denmark and Norway — The law of the United States of America.