On June 26, 2025, both the US House Ways and Means Committee and Senate Finance Committee Chairpersons issued statements regarding Section 899 and their intentions to remove proposed tax code Section 899 from H.R.1; the “One, Big, Beautiful Bill Act”.
Initial House and Senate drafts of the US 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 proceed, it would have significantly impacted both the income streams of portfolio investors and the regulatory compliance obligations of financial intermediaries.
Brown Brothers Harriman (BBH) will continue to monitor and communicate updates as these proposals move through the legislative and regulatory development process.
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