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Canada-ON-KALADAR Azienda Directories
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Azienda News:
- Section 899 to Bring Challenges But Will Survive in Senate Budget . . .
The OBBBA would create Code Section 899, borne from Republican opposition to the Organization for Economic Development’s (OECD) two-pillar global tax model in various stages of implementation among 140 non-U S tax jurisdictions
- Section 899 Targets France in New U. S. Tax Bill - National Law Review
OBBBA’s Section 899 would hike U S taxes on French firms in response to France’s DST, posing major risks for cross-border investors and tech companies
- The One Big Beautiful Bill Act: An Initial Analysis of Key Tax . . .
The OBBBA includes new Section 899, which incorporates certain parts of the “Defending American Jobs and Investment Act” (H R 591) and the “Unfair Tax Prevention Act” (H R 2423) proposed earlier this year, with several modifications
- U. S. Budget Bill Targets Foreign Companies with New Tax Hikes: What . . .
The new bill introduces a new section to the U S Internal Revenue Code Section 899 What Is Section 899? Section 899 is a proposed tax provision that would raise U S tax rates on foreign individuals and companies from countries the U S deems to have “unfair” tax policies
- House tax bill would impose taxes on cross-border transactions
If section 899 is not enacted until later in 2025 or 2026, section 899 may not apply until 2027 Section 899: The road to enactment The U S Senate has taken up the OBBBA with the goal of enacting the broad taxation-and-spending legislation by July Fourth
- A First Look at the Proposed Section 899 Targeting… | Doeren Mayhew
One of those proposed provisions is Section 899, Enforcement Remedies Against Unfair Foreign Taxes, which is intended to increase the income tax of persons and corporations from jurisdictions who levy “unfair taxes” on U S persons
- United States: A Closer Look at How Proposed Section 899 Would Increase . . .
On May 22, 2025, the House passed the One Big Beautiful Bill Act of 2025 as modified by the manager's amendment from the Rules Committee No modifications were made to the retaliatory tax provision in proposed section 899, which has garnered interest from US inbound companies
- Understanding Section 899: A New Fiscal Doctrine in U. S.
At its core, Section 899 transforms the U S tax code into a tool of capital filtration and jurisdictional alignment —disciplining cross-border financial flows through graduated penalties rather than outright bans
- One Big Beautiful Revenge Tax: Hits Foreigners From “Unfair Tax . . .
The One Big Beautiful Bill Act Adds IRC Section 899: Here’s How It Would Work The punitive bite of Section 899 would be an escalating increase of U S tax rates on foreign persons from any discriminatory foreign country
- What is section 899 and what could it mean for investors?
Section 899, part of the “One Big Beautiful Bill Act” (OBBBA) that passed the U S House in May 2025, is now being reviewed by the Senate If enacted, it would empower the US Treasury to impose additional, far-reaching taxes on foreign investors and companies – especially if they are from countries that the US see as unfairly taxing
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