Jun 25, 2025
A Deep Dive into the Implications of Proposed Section 899 in the Big Beautiful Bill
The U.S. House of Representatives has recently passed a bill incorporating a significant amendment to the Internal Revenue Code known as Proposed Section 899. This provision, titled 'Enforcement of Remedies Against Unfair Foreign Taxes', is aimed at corporations, individuals, and governments of countries that levy discriminatory or extraterritorial taxes on U.S. citizens or corporations. The measure seeks to counter these practices by subjecting the entities involved to heightened U.S. tax rates.
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