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‘Big, scary moment’? What’s up with Section 899 and its ‘retaliatory’ taxes?

With the market taking a closer look at the “One Big Beautiful Bill Act” after it was narrowly passed by the US House of Representatives on May 22, a clause called Section 899 has caught the attention of investors worldwide by including a new set of “retaliatory” taxes on inbound foreign investment. As the bill now awaits Senate consideration, there are growing concerns that some of the most sweeping changes to the tax treatment of foreign capital in the US in decades could lead to a sharp...


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