discriminatory tax

A tax may be invalid even though it does not fall directly on the United States if it operates so as to discriminate against the Government or those with whom it deals. A State may not impose a higher tax on lessees of federally owned lands than on similarly situated lessees of state-owned lands; it does not seem too much to require that the State treat those who deal with the Government as well as it treats those with whom it deals itself. Such a discriminatory tax is void and may not be exacted.