How Congress can turn tariff lemons into lemonade: A border-adjustment tax

President Donald Trump’s efforts to impose widespread tariffs on imports (widely condemned by economists) can be half of a good idea. A better idea would be to pair the tariffs with an equivalent export subsidy, thus creating a tax regime (called a border-adjustment tax or BAT) similar to the one used by many other countries. 

Enacting this plan would reduce the trade gap, increase GDP, raise significant revenue, and make America the world’s best place to invest and build businesses. And unlike unilateral tariffs alone, this combination would be justifiable under international trade rules, avoid costly trade wars, and limit the effects on consumer prices and inflation. Ideally (but not necessarily), the tariff and subsidy rate would be set at 21% to match the corporate tax rate and would be designed to replace America’s complicated and inefficient international business tax system. 

This is not a new idea. It was proposed in a 2005 Presidential Advisory Panel on tax reform and resembles a proposal made by House Republicans in 2016 to replace the corporate income tax with a destination-based cash flow tax (DBCFT), which would include border adjustments that exempted exports but included imports in tax bills. That proposal went nowhere, but it’s still the germ of a good idea.

Trump’s proposed tariffs are intended to combat unfair advantages foreign companies enjoy over domestic businesses, to increase U.S. business activity and employment, and to reduce the trade deficit. The current U.S. international tax system is an important contributor to all these problems. Goods and services produced in the U.S. are subject to domestic income and payroll taxes (wherever they are sold), whereas the same goods and services produced elsewhere and sold in the U.S. or abroad avoid those taxes. This makes U.S.-made goods and services more expensive and less competitive and shifts activity and income that should occur in the U.S. to foreign countries.

All other developed countries address this problem by imposing a tax on imported goods and services and, so as not to disadvantage home-country businesses selling abroad, by providing a credit for taxes paid on exported goods. This tax-and-credit treatment of imports and exports is called a border adjustment, and the American tax system should have one, too.

While other countries impose these border adjustments in the context of value-added taxes (VAT) rather than the income and payroll taxes that prevail in the U.S., this is a distinction without a difference. “Value-added” is simply another way of saying “wages plus business income.” Arithmetically, value-added equals compensation plus businesses revenues minus input costs (which is how the tax base is generally defined in the U.S.). The major difference is that our system only imposes these taxes on goods and services produced in the U.S., whereas the rest of the world uses border adjustments to apply the tax based only on where goods and services are sold. Our system makes it more advantageous to make things in other countries than in the U.S.

If Trump and Congress enacted this border adjustment—say, with a 21% import tariff and a symmetric 21% export subsidy at the same rate as the corporate tax—this change would be a natural and practical addition to the U.S. tax system and would achieve Trump’s major economic goals:

• It would fulfill his promise to impose tariffs on imports.
• As we will show, it would raise substantial revenue—on the order of $1.4 trillion over 10 years—which could be used to pay for other tax reform goals.
• It would reduce the trade gap by roughly 31% (several hundred billion dollars per year), raising U.S. GDP by an equivalent amount (Guvenen et al. 2022).
• It would extract the U.S. from the boondoggle of international tax and trade negotiations, which have cost U.S. businesses billions of dollars in taxes that, ironically, are paid to foreign governments like Ireland rather than to the U.S.

However, unlike unilaterally-imposed, country-by-country tariffs on goods alone, imposing the tax across all goods and services and providing an equivalent subsidy to U.S. exports has several advantages.

• It would dramatically limit the costs imposed on U.S. businesses. Business that import goods also tend to export, with firms engaged in both activities accounting for 84% of total exports and 91% of total imports (Kamal 2024). The tax adjustment would (other things equal) still encourage businesses to reduce imports and increase exports, but the effect on their bottom line would be mitigated because the taxes and subsidies would mostly offset each other. This is particularly important for U.S. manufacturers who import substantial intermediate parts but export final products.
• It would be compliant with international trade agreements and avoid retaliation. Unilateral tariffs are sure to spark retaliatory trade wars, but all developed economies already have border adjustments. While our system would be different and would certainly exasperate our trading partners, it would be difficult for them to argue that we were breaking the rules and deserve reprisal.
• The effects on consumer prices, inflation, and business profits would be mitigated because exchange rates would adjust. All other countries that imposed a border adjustment experienced appreciation in their home currencies (Freund and Gagnon 2017). While the tax would clearly increase the post-tariff price of imports, the appreciation of the dollar would reduce the pre-tax price, limiting its pass-through effects on consumer prices and business costs.
• It would eliminate the existing system’s incentive for multinational businesses to shift profits (and the associated tax payments) abroad to tax havens and lower-tax jurisdictions like Ireland. By eliminating the incentive for profit shifting, the existing costly and complicated international tax rules would be obsolete, and Trump could then extract the U.S. from international tax rules that have enriched European treasuries at the expense of U.S. companies.

A border adjustment would be enforceable, administrable, and defensible under international agreements. It would benefit American businesses and workers by making the U.S. the best place to locate and grow multinational agreements. Further, the import and export taxes and subsidies would be symmetric and offsetting in the aggregate and would apply only to a narrow range of U.S.-sold goods and services, and thus their impacts on U.S. consumers and consumer prices would be muted.

How it would work

As an example, imagine goods and services imported into the U.S. would be subject to a 21% import tariff. Corporate and non-corporate businesses and importers selling directly to consumers would be required to remit the tax upon import, as is currently done with tariffs (and, elsewhere around the world, with VATs). Businesses (and workers) would complete their taxes as they normally do.

The most significant change would be crediting businesses for exported goods and services. In countries with VATs, exporters receive a credit against VAT taxes paid. In the U.S., the export credit could be applied against income and payroll tax withholding. Specifically, when making quarterly tax payments, firms (including C and S corporations, partnerships, and self-employed individuals) would be credited a flat 21% to account for payroll and income taxes already paid on the exported goods and services. Importantly, this credit would be fully refundable to ensure that exporters received the full value of the credit, regardless of domestic input costs.

Viewed this way, the 21% rebate is not a subsidy, it simply reflects a rebate for the embedded payroll and income taxes that are baked into U.S. exports. Individuals and businesses filing their annual returns would treat the credits the same as ordinary withholding. Businesses with excess credits should be able to seek a refund or, at least, be able to transfer excess credits to upstream suppliers. Compliance would require documentation of export and could be monitored by the Treasury Department (via Customs and Border Patrol and the IRS).

In 2016 policymakers considered an alternative method for implementing a border adjustment—excluding both exports and imports from the taxable base—with their proposal to institute a destination-based cash flow tax (DBCFT). The import tax-export subsidy is the border adjustment mechanism employed by most of the world’s advanced economies as a crucial complement to their domestic VAT systems.

The most important element of both of these mechanisms is the need for symmetry in the treatment of imports and exports. In the case of a tax-and-subsidy, the rates must be the same, but these rates need not match other rates already in place in the U.S. tax system. Moreover, the rates must be uniform across all imports and exports—rates that vary by country-by-country will create barriers to trade. Finally, export subsidies must be fully refundable. The feasibility of full refundability becomes salient in the context of firms that engage in substantial cross-border transactions and motivates our proposal to credit the export subsidy against income and payroll tax withholding—most businesses remit substantial withholdings on a quarterly basis to the federal government, making a withholding credit an efficient mechanism to fully refund this tax.

Consider a U.S. manufacturing company that produces widgets with the use of $500 of domestic equity capital and $500 of domestic labor. The company then sells all widgets to Canadian consumers for $2,000. Under current law, the firm withholds 15.3% of wages for payroll taxes and roughly 12% for income taxes (about 27% of $500 or $135). In addition, the firm has corporate liability of 21% on the $1,500 of profits ($315). Under the proposed policy, this firm would be eligible for an export subsidy of 21% of its export sales, or $420, which it could use to offset its $450 liability. (The firm would be required to apply the credit proportionately to offset employee tax withholding).

On the other hand, consider a firm that was a low-margin re-seller that exports U.S.-produced goods that it did not produce. In this case, the firm might have large exports but neither employee withholding nor large enough taxable income to absorb the credit. In order to receive the subsidy, this firm would either need to receive a direct refund or be able to transfer the credit to an up-stream producer.

Refundability, in either form, is essential for achieving trade-neutrality under a BAT. However, implementing full refundability reveals a key challenge in designing a BAT within the current U.S. tax system, whether through an import tax-export subsidy regime or by excluding imports and exports from taxable income (as was proposed under the DBCFT). The corporate income tax does not refund taxable losses; instead, losses can be carried forward (without interest) to reduce future taxable income. This asymmetric treatment of profits and losses distorts investment and financing decisions (Auerbach and Poterba, 1987; Altshuler and Auerbach, 1990). As a result, implementing a BAT through income tax exclusions creates additional complexities due to the lack of refundability in the corporate income tax system. By contrast, tying refundability to the employer payroll tax offers a simpler and more well-targeted solution. Furthermore, this approach is not without precedent: The Families First Coronavirus Response Act (FFCRA) included refundable employer tax credits for expenses associated with emergency paid leave, presumably to ensure that expenses incurred by businesses for offering this leave to their employees were refunded as quickly as possible.

Why would this be a good idea? The economic case

A border adjusted tax (BAT) would be simpler, more economically efficient, and would encourage more investment, production, and growth in the U.S.

Simplicity: Effects on profit shifting, anti-avoidance rules, and international tax agreements

Currently, U.S. businesses have strong incentives to shift activities and profits abroad to lower-tax jurisdictions like Ireland to avoid U.S. taxes. Likewise, for the same reasons, foreign corporations would rather produce goods and services abroad and import them into the U.S. rather than produce and sell in the U.S. To address these intrinsic problems, the U.S. has implemented a host of complicated and cumbersome tax rules and subsidies and cooperative agreements:

• a tax on Global Intangible Low-Taxed Income (GILTI), to prevent U.S.-headquartered multinationals from parking high-return intangible assets (and corresponding profits) in low-tax jurisdictions;
• a preferential rate on Foreign-Derived Intangible Income (FDII), to encourage U.S. companies to keep intellectual property in the U.S. by granting a preferential tax rate to income from exporting goods or services tied to U.S.-based intangibles;
• a Base Erosion and Anti-Abuse Tax (BEAT) to prevent corporations from eroding the U.S. tax base by making large deductible payments (like interest and royalties) to related foreign affiliates;
• rules to prevent U.S. companies from deferring U.S. tax on certain kinds of easily movable foreign income earned by their Controlled Foreign Corporations under Subpart F;
• and foreign tax credits, which are intended to prevent double taxation when the same income earned by a U.S. company is also taxed by a foreign country.

In addition to these U.S.-imposed rules, the international community has negotiated broad cooperative agreements to police profit shifting. For example, the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (BEPS) intends to layer additional complexities and burdens on U.S. companies. These are global agreements designed to address perceived shortcomings in existing international tax rules—particularly for digital services and highly mobile income. They are often called “Pillar 1” and “Pillar 2” for short. Pillar 1 intends to reallocate some taxing rights over multinational enterprises (MNEs) from their home countries to markets/jurisdictions where they have consumers (even without a physical presence). Pillar 2 intends to establish a global minimum effective tax rate (commonly set at 15%) on large MNEs, aiming to reduce incentives for profit shifting to low-tax jurisdictions.

Minimum tax rules like GILTI and the OECD’s global minimum tax have successfully shifted profits out of traditional tax havens like Bermuda and the Cayman Islands, but those profits—and the taxes on them—haven’t returned to the U.S. Instead, they’ve shifted to places like Ireland, whose Treasury is now flush with taxes paid by American companies. While these rules aim to police profit shifting, they rely on complex compliance requirements and substantial international cooperation, which has often worked to the disadvantage of U.S. businesses. The OECD’s Pillars, for example, disproportionately impact large, successful American companies and shift tax revenues to foreign governments rather than the U.S. This approach has allowed European governments to claim a larger share of tax revenues from U.S. multinationals, and continuing on this path risks further eroding GILTI revenues as more profits are taxed abroad under Pillar 2.

A BAT eliminates the incentive for U.S. multinationals to locate profit overseas. First, the export subsidy eliminates the incentive to manipulate the prices of exports and imports between U.S. parents and their foreign subsidiaries. This transfer-pricing has allowed large multinationals to reduce taxes on an estimated $2 trillion in multinational profits between 2017 and 2020 worldwide, likely costing the U.S. government more than $100 billion per year in lost tax revenue (Clausing, 2020; Hugger, Gonzalez Cabral, and O’Reilly, 2024). By subsidizing the full value of exports and taxing the full value of imports, these price manipulations no longer affect U.S. taxes.

Second, the BAT eliminates the incentive to relocate multinational operations overseas. Currently, U.S. multinationals have at least two incentives to place tangible assets in low-tax countries. First, doing so allows them to shift profits to those countries, reducing their U.S. tax bill. Second, under the TCJA’s GILTI rules, the tax that U.S. multinationals pay on profits earned from intangible assets (patents, trademarks, etc.) located overseas decreases as they invest more in physical assets (buildings, machinery, etc.) in those countries. The BAT removes the tax advantage of producing products overseas that are destined for U.S. consumption by taxing those products when they are imported. For this reason, Congress could repeal GILTI, FIIDI, and BEAT because they’d be unnecessary.

Finally, a BAT is neutral with respect to the operation of domestic businesses. Because the BAT applies uniformly to all goods and services sold in the U.S., it does not favor one industry or business model over another. Instead, the BAT puts domestic producers on a level playing field with their foreign competitors. Moreover, the BAT simplifies tax compliance for multinationals without otherwise affecting domestic businesses.

Economic effects

From an economic perspective, these incentives aren’t simply tax compliance issues: They affect the location of investment, employment, production, and the location of business activity.

Between the effects on U.S. investment and profit shifting, the magnitude of the distortion is large. As a result, reported exports are lower and imports higher, raising the trade deficit, and U.S. GDP is correspondingly lower. Instead, this GDP accrues to low-tax foreign countries.

Eliminating the incentives for profit shifting would thus bolster measured U.S. GDP by reattributing the share of income that currently “disappears” into foreign affiliates of U.S. multinational enterprises. Guvenen et al. (2022) estimate that profit shifting peaked at roughly $200 billion in 2010 and has averaged around $150 billion per year, most of it tied to intangible-intensive industries like electronics, pharmaceuticals, and information technology. Bringing these profits back into U.S. national accounts could increase business-sector value added by up to 1–2% in certain peak years.

Notably, a BAT would also reduce the measured trade deficit. For example, reassigning shifted profits in 2016 would have shrunk the deficit from 2.6% of GDP to 1.8%. Meanwhile, measured productivity (value added per worker) would see a modest uptick at the aggregate level—an extra 13 basis points of annual growth in some periods—but a much larger boost in R&D-intensive industries.

Exchange rate effects, prices, and profits

Currency adjustments caused by a BAT lead to changes in real exchange rates that reduce the impact on real economic activity, trade, and prices faced by businesses and consumers. These exchange rate changes are predicted by theory and confirmed by empirical research. And, in the short run, a BAT is likely to raise tax revenue given the current position of the U.S. economy as a net importer.

Understanding how the BAT affects exchange rates is essential to understand trade neutrality (Table 1). The export subsidy in isolation will increase demand for U.S. exports by reducing their pre-tax price; this makes U.S. exports more competitive, strengthening the value of the dollar. The stronger dollar will also increase demand for U.S. imports because the stronger dollar reduces the pre-tax cost of imports, making them relatively cheaper (row 1). A tariff, in isolation, will reduce demand for U.S. imports because they become comparatively more expensive, again strengthening the value of the dollar. A stronger dollar increases the cost of U.S. exports to foreign buyers, reducing demand for exports (row 2). Under the assumption that exchange rates fully adjust, the combination of a tariff and a subsidy, however, brings this system into balance; if the dollar strengthens enough to fully offset these adjustments, U.S. exports and imports are unaffected.

Note, however, that these exchange rate effects apply to international transactions between unrelated buyers and sellers. As we described above, a significant share of cross-border transactions are between related parties (e.g., within multinational companies), are influenced by profit shifting, or are otherwise influenced by tax incentives about where to locate business activity, production, and investment. A border adjustment will still reduce these incentives, reducing trade deficits and increasing reported GDP and U.S. business activity.

The trade neutrality of a BAT does not mean that there would not be winners and losers of the currency effects that accompany this policy. Currency fluctuations affect the value of dollar-denominated securities and debt held by foreigners, including foreign governments. Foreigners holding dollar-denominated securities would be enriched by the appreciation in their value. On the other hand, foreigners holding dollar-denominated debt will face a greater burden because the dollar appreciation increases the cost of repaying that debt in their own currencies. This cost may be particularly acute for foreign governments with significant dollar denominated debt, which tend to be those with emerging markets and developing economies.

U.S. BAT: A working example

To fix ideas, consider a domestic-only business under the current system that produces $100 worth of goods using $15 worth of labor and $60 worth of capital (Table 1, Column 1). This business would earn $25 in profit and would pay $5.25 in U.S. corporate taxes. Compare this with a U.S. importer (column 2) that uses $40 worth of domestic capital and imports an additional $20 worth of inputs. The U.S. importer has the same profit and the same U.S. tax bill because imports are a deductible business cost. Finally, compare these businesses with a U.S. exporter (column 3) that sells $80 worth of goods domestically and exports an additional $20 worth of goods. The U.S. exporter has the same profit and the same U.S. tax bill because exports, ultimately, face a 21% U.S. corporate tax rate.

Now, suppose that the U.S. imposes a 21% BAT. As previously described, the dollar will strengthen to hold the U.S. trade balance fixed. Table 2 describes the profitability and tax position of the same US importer (2) and exporter (3), in addition to a company that has both imports and exports (4) under the BAT, assuming that there was parity between the dollar and the euro prior to the imposition of the BAT.

While the U.S. importer now benefits from cheaper imports due to the strengthening of the dollar compared to the Euro, the total cost of imports has not changed due to the currency adjustment: The importer now pays $16.53 for imported inputs but owes $3.47 in the tariff, returning the total cost of imports to $20, as before the imposition of the BAT. Likewise, the U.S. exporter is also held harmless: The exporter sells $16.53 worth of exports, but receives a $3.47 export subsidy, returning the total revenue from imports to $20. Finally, the importer-export is not only held harmless, but the value of the tariff that they face is exactly offset by the value of the export subsidy, providing an easy mechanism to transmit the export subsidy (rebating it against the tariff). In all cases, the profitability of the company is unchanged under the BAT.¹

Some are skeptical that the exchange rate would fully adjust to offset the import and export taxes and subsidies. However, if exchange rates only partially adjusted, that would somewhat increase net-of-tax import prices, and somewhat reduce net-of-subsidy export prices, which is a stated goal of the policy.

In addition, recall that most importers are also exporters in the U.S. In the case where an importer imports exactly as much as it exports, it does not matter whether the tariff and subsidy are included in the tax base or not—the importer-exporter is held completely harmless with or without a BAT.

Finally, note that these stylized examples focus on individual firms to illustrate how importers who face tariffs are effectively compensated by currency appreciation that make their imported inputs cheaper, and exporters who receives the subsidy are thus spared the “penalty” caused by that same currency appreciation. In these examples, the added tariff and subsidy cancel out for these particular firms because the exchange rate adjusts to leave them with the same after-tax profit.

This, however, does not imply that the government collects nothing on net—only that any tariff paid by the importer in the example is offset by the export subsidy paid to that same (or another) firm. The U.S. is a net importer—and has been since the mid 1970s—and, thus, there will be more aggregate tariff revenue collected than export subsidy paid under a BAT as long as that remains true, raising revenue for the government. Additionally, the border adjustment reduces the incentive for U.S. multinationals to shift profits abroad, increasing the U.S. tax base and further increasing tax revenue.

How much revenue could a BAT raise?

Because the U.S. is a net-importer, the imposition of a BAT would raise revenue in the short-run. Patel and McClelland (2017) estimate that the corporate income tax base would have been 40% larger with a border-adjustment tax in place from 2004–2013, suggesting substantial scope for tax revenue. Moreover, the Tax Policy Center estimated that the border-adjusted cash flow tax proposed by House Republicans in 2016 would raise $1.2 trillion in tax revenue over the ten year window ending with Fiscal Year 2026. The estimate is similar to the Tax Foundation’s $1.1 trillion estimate of the border adjustment within the House plan.

The CBO’s most recent “Budget and Economic Outlook” projects that net imports will total $9,996 billion over the next ten years. Following Guvenen et al (2022), we assume that roughly one-third of this measured trade gap is related to transfer pricing that will no longer occur under a BAT. This implies that the tax base of the BAT is roughly $6,642 billion in net imports, and that roughly $1,395 billion in additional tax revenue could be raised under a 21% BAT rate. 

Moreover, it is likely that a border adjustment would result in dynamic effects that further increase the potential revenue under a BAT because this policy encourages businesses to locate in the U.S. This increases U.S. investment and demand for U.S. workers, which increases U.S. income. While this does not mean that a BAT would “pay for itself,” it does mean that static estimates like those previously cited are likely to under-estimate the total tax revenue that could be raised under a BAT.

What are some of the major implementation concerns about a BAT?

International trade rules: Would a BAT run afoul of WTO rules?

The World Trade Organization (WTO) should be neutral towards a U.S. BAT—more than 140 countries have already implemented this system. Technically, the WTO rules allow for border adjustments only in the context of indirect taxes, like a VAT. Indirect taxes are those imposed on goods and services rather than those imposed on income or profits (direct taxes). While it is true that the U.S. corporate income tax is a direct tax, this is largely a semantic difference rather than an economic one.

The U.S. corporate income tax system, both as currently specified and as specified during the last two decades, has included provisions that make it resemble a cash-flow tax rather than a traditional income tax. A key feature of a cash-flow tax is that it allows for the immediate expensing of capital investments, and the U.S. corporate income tax has allowed for some form of accelerated (bonus) depreciation of capital expenses nearly every year since 2001. Another notable feature of a cash-flow tax is the treatment of financial income and expenses, which are generally removed from the tax base. In 2017, the TCJA capped the amount of interest expense that is deductible for tax purposes, further aligning the U.S. system with a cash-flow tax structure. Patel and McClelland (2017) show that the corporate income tax base would have been similarly sized under a cash-flow tax, underscoring the similarities between these two systems. Importantly, the combination of a cash-flow tax and a labor tax is equivalent to a VAT (Auerbach 2017).

Maintaining uniform tariff rates

Symmetric tariffs and export subsidy rates are critical for a trade-neutral implementation of a BAT. However, the current U.S. tariff system, governed by the Harmonized Tariff Schedule, is highly complex, with rates varying by country and by product. This directly conflicts with the basic principle of the BAT. Furthermore, tariff rates are largely determined by the executive branch under various trade authorities, reflecting not only corrective measures against unfair trade practices but also geopolitical considerations and negotiations. This complexity suggests that achieving and maintaining symmetric BAT rates—and thus trade neutrality—will be challenging.

Designing a refund mechanism for exporters

Refundability for exporters posed a significant administrative challenge under the DBCFT and is likely to do the same under a pure BAT. Under the DBCFT, excluding imports and exports from the tax base raised concerns about U.S. exporters with substantial domestic production. These businesses would have been thrown into a loss position, owing no tax liability this year and carrying forward losses to use to reduce future positive tax liability. In other words, losses are not immediately refundable under the current U.S. system. With this in mind, it was unclear how to ensure the symmetric treatment of imports and exports under the DBCFT, threatening the trade-neutrality.

We prefer the pure BAT as outlined in this paper precisely because it allows export subsidies to be credited against other regular tax payments like payroll and income taxes. This provides a more straightforward mechanism for refunding export subsidies without requiring broader changes to the U.S. tax code. However, firms with insufficient tax liabilities may be unable to fully utilize the credit, again raising administrative challenges. If export subsidies are not immediately paid, the BAT’s trade neutrality will not hold.

Conclusion

To be clear, the contours of the tariff policies endorsed by President Trump do not equate to a BAT. Instead, candidate Trump enthusiastically supported a 10% broad-based tariff with a 60% tariff for Chinese goods, and President Trump has proposed a series of broad-based tariffs on many of our trading partners. A tariff in isolation and particularly the large-scale tariffs endorsed by the Trump campaign would be likely to cause serious, worldwide economic disruptions, including price effects and retaliatory trade wars (Zandi, LeCerda, and Begley, 2024; Clausing and Lovely, 2024). Moreover, tariffs are known to be regressive taxes, putting more of the burden of taxation on lower-income households (Clausing and Lovely, 2024). Finally, tariffs of differing rates for different trading partners distorts production by incentivizing firms to shift supply chains and otherwise engage in transfer pricing in order to minimize tariff liabilities.

As we show in this brief, if President Trump were to instead pair a broad-based tariff with a symmetric, broad-based export subsidy, this could become a hallmark of his administration. Economists have long-noted the potential benefits of a border-adjustment tax for the U.S. economy. House Republicans have twice introduced this policy in recent history, once in 2006 with the Growth and Investment Plan and once in 2016 with the “Better Way” Tax Reform Blueprint. Adopting a BAT would level the playing field for American businesses and help ensure that America is the best place to do business.