Taxation and State Taxation -- active
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San Patricio County Appraisal District v. Devon Gas Services, et al.
(Texas Supreme Court)
Opposing Unconstitutional State Taxes on Foreign Exports
On August 28, 2026, the NAM filed an amicus brief urging the Texas Supreme Court to invalidate a series of property taxes that a county attempted to levy against energy manufacturers storing oil on the Texas coast before shipping it to U.S. trading partners abroad. In San Patricio County Appraisal District v. Devon Gas Services, county officials assert that two energy manufacturers owe local property taxes for the oil tank farms they maintain in Corpus Christi, even though the oil temporarily stored in the tanks is a foreign export that is constitutionally exempt from state taxation. In our amicus brief, we emphasize U.S. Supreme Court precedent stating that all goods in the “stream of exports” are covered by the Import-Export Clause of the U.S. Constitution, including goods that are in transit to their final destinations. The staging infrastructure used to temporarily store oil and many other types of goods at ports and coastal staging facilities is necessary for the U.S. to remain a top global exporter.
Related Documents: NAM brief (August 28, 2026)
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