KEY POINTS

  • The “One Big Beautiful Bill Act,” includes the most sweeping changes to the tax treatment of foreign capital in the U.S. in decades under a provision known as Section 899.
  • Section 899 will hit entities from so-called “discriminatory foreign countries” that impose levies that disproportionately affect U.S. companies.
  • Under the new tax bill, the U.S. would hit investors from such countries by increasing taxes on U.S. income by 5 percentage points each year, potentially taking the tax rate up to 20%.