Whether Utah's tax code discriminates against foreign commerce in violation of the dormant Commerce Clause

QUESTION PRESENTED Utah’s tax code extends a credit for income taxes paid to other States but does not extend a similar credit for income taxes paid to foreign countries or make other adjustments for foreign income. The result is a double taxation of income that state residents earn from foreign commerce. The question presented is whether this scheme discriminates against foreign commerce in violation of the dormant Commerce Clause. (i)