Border Adjustments and the Conservation of Tax Planning

10 Pages Posted: 17 Jul 2017

Date Written: June 5, 2017


This article is based on Schizer’s keynote address at the 17th annual NYU-KPMG Tax Symposium on March 10.

In this article, Schizer argues that U.S. corporate and shareholder taxes need to be reformed, and the corporate rate should be much lower. In reforming this dysfunctional regime, according to Schizer, Congress should keep both of these taxes as a form of built-in redundancy; if one tax is avoided, the other can still be collected. More generally, Congress should be wary of Utopian solutions. Tax reform is more likely to change tax planning than to eliminate it entirely, Schizer concludes. For instance, although border adjustments would foreclose some strategies, they would encourage others.

Keywords: Corporate Tax, Border Adjustment, Tax Rate

Suggested Citation

Schizer, David M., Border Adjustments and the Conservation of Tax Planning (June 5, 2017). Tax Notes, Vol. 155, No. 10, June 2017; Columbia Law and Economics Working Paper No. 569. Available at SSRN: or

David M. Schizer (Contact Author)

Columbia University - Law School ( email )

435 West 116th Street
New York, NY 10027
United States
212 854 2599 (Phone)
212 854 9740 (Fax)

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