| Foreword | |
| 1 | Introduction | 1 |
| 2 | Tariffs, Taxes, and Locational Neutrality | 6 |
| The Harms to Be Avoided | 6 |
| The Definition of a Tax and Its Significance for Locational Neutrality | 10 |
| The Comparative Value of Locational Neutrality and Tax Neutrality in General | 15 |
| Broader Ramifications of Locational Neutrality | 18 |
| Administrative and Compliance Costs of Disparate State and Local Taxation | 30 |
| Responding to the Problems Caused by Locational Disparity | 38 |
| 3 | The Exercise of Federal Judicial Review to Bar Discrimination Against Outsiders Or Interstate Commerce | 42 |
| Why Bar Discrimination While Permitting Other Locational Disparity? | 43 |
| Theoretical and Historical Difficulties in Defining Discrimination | 48 |
| Attempts to Make the Discrimination Standard Coherent | 58 |
| The Constitutional Grounds for Federal Judicial Review of State and Local Taxation | 65 |
| 4 | Political Factors Affecting the Practice of Federalism in Taxation | 68 |
| Congress and the Political Efficacy of the "Positive" Commerce Clause | 68 |
| State and Local Governments and the Need for a Commerce Clause | 71 |
| Preserving Broad State and Local Government Autonomy | 77 |
| 5 | Conclusion and Recommendations | 95 |
| Congress | 97 |
| The Federal Courts | 111 |
| About the Author | 117 |