Proposed IRC Section 899: U.S. Strikes Back at Discriminatory Foreign Taxes
On May 22, 2025, the U.S. House of Representatives narrowly passed the “One Big Beautiful Bill Act”, a $3.8 trillion tax reconciliation package. Tucked inside is the proposed Section 899, a powerful new provision targeting what the U.S. considers discriminatory foreign tax practices. While the legislation now moves to the Senate—where changes are likely—the introduction of Section […]
The One Big, Beautiful Bill: What the 2025 Tax Reform Means for Businesses, Employees, and Investors
International Tax Policy Updates TCJA Provisions Made Permanent: The bill locks in lower international tax rates: GILTI (10.5%), FDII (13.125%), and BEAT (10%). New Section 899: Penalties for Discriminatory Foreign TaxesImposes escalating taxes on foreign entities from “discriminatory countries,” aligning with U.S. efforts to resist the OECD global minimum tax. Estate & Gift Tax Changes $15M Unified Credit Exemption Made Permanent […]