JD Supra

Proposed IRC section 899 ‘revenge tax’ targets residents of certain discriminatory/offending foreign countries

On June 16, 2025, the Senate Finance Committee released its proposed version of the “One Big Beautiful Bill Act” (the Senate Bill). The House of Representatives passed its version of the bill on May ...
JD Supra

Senate Updates Code Section 899

On Monday, 16 June 2025, the Senate Finance Committee released its version (the Senate Proposal) of the Section 899 retaliatory tax provisions that also are included in the “One Big Beautiful Bill Act ...
American Enterprise Institute

We Should Be Worried About “Section 899”

The version of the One Big Beautiful Bill (OBBB) passed by the House of Representatives includes a new set of “retaliatory” taxes on inbound foreign investment called Section 899. Since its passage, ...
NBC DFW

‘Collateral damage': Fund managers lobby Congress over Section 899 to avert foreign investors leaving the U.S.

American fund managers are lobbying Congress over a provision tucked inside President Donald Trump's tax bill that they say could lead to foreign investors "quickly" pulling investments out of the U.S ...
CNBC

Why the U.S. tax bill's Section 899 could push European firms to list in the U.S.

The decision by U.K. fintech firm Wise to move its primary stock listing to the U.S. is the latest in a series of blows to the London market — and a new provision tucked inside a U.S. tax bill could ...
Wall Street Journal

‘Revenge’ Tax? Section 899 Is More Like Repair

Journal Editorial Report: The week’s best and worst from Kyle Peterson, Allysia Finley and Kim Strassel. Much of the financial press has taken to labeling Section 899 of the reconciliation bill a ...