On July 3, 2025, the U.S. House passed the “One Big Beautiful Bill Act” and progressed the Bill to the President for signature. The Section 899 provision was not included in the final bill as passed and signed into law by the President on July 4, 2025.
Several drafts of the U.S. Government’s 2025 spending and tax bill contained a provision that would have created a new US Income Tax Code Section (899), the purpose of which was to impose a new tax on countries that imposed what the United States deemed “unfair” (extraterritorial or discriminatory) taxes on US residents and companies.
If the provision were to have been included in the final law, it would have significantly impacted both the income streams of portfolio investors and the regulatory compliance obligations of financial intermediaries.
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