Chancellor I’Ashea L. Myles, Chief Judge (Middle Grand Division)
Chancellor John C. Rambo (Eastern Grand Division)
Chancellor Vicki H. Hoover (Western Grand Division)
This is a constitutional challenge brought by the Financial Technology Association (Plaintiff) against David Gerregano, Commissioner of the Tennessee Department of Revenue (Defendant), seeking a declaratory judgment and permanent injunction. The Plaintiff alleges that 2026 Tenn. Pub. Acts ch. 1035 (formerly H.B. 2502), which imposes a sales tax solely on international money transmissions originating in Tennessee, is unconstitutional. The Plaintiff argues that the tax discriminates against foreign commerce by taxing only international money transfers and not domestic ones, in violation of the Commerce Clause and the Import-Export Clause of the United States Constitution.