Section 899 would also override the benefits under Section 892, which generally exempts certain U.S.-source income of foreign governments and their controlled entities from U.S. taxation.

To this end, investment funds would be collateral damage to the intended focus of section 899." Letter from ICI sent to Senate Finance Committee, seen by CNBC.

Senate Finance Section 899 generally tracks House Bill Section 899 but is expanded to cover certain U.S. branches of non-publicly traded foreign corporations and reapplies the base erosion ...

In this episode of Tax Notes Talk, Alan Cole of the Tax Foundation discusses the international tax provisions in the One Big ...

Section 899 would be a central topic of their talks. The fear of higher taxes has made the almost 200 foreign-owned companies in the US nervous. These companies include Shell, Toyota, SAP, and LVMH.

Trump tax plan may cost 360K jobs, $55B in U.S. growth A new analysis warns Trump's Section 899 tax proposal could cost 360,000 U.S. jobs and $55B in GDP, deterring foreign investment in key states.

‘Collateral damage': Fund managers lobby Congress over Section 899 to avert foreign investors leaving the U.S. By Ganesh Rao, CNBC • Published June 10, 2025 • Updated on June 10, 2025 at 4:16 am ...