The potential impacts of the US “One Big Beautiful Bill"

June 09, 2025
  • Investor Services
What portfolio investors and financial intermediaries should know

Provisions of US tax bill

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The current 2025 tax bill as recently passed by the US House of Representatives could impact the income streams of portfolio investors and the regulatory compliance obligations of financial intermediaries.

The proposal would create a new US Income tax Code Section (899) which could impose and increase statutory US nonresident tax rates in 5-percentage point annual increments up to a maximum of 20 percentage points above the statutory rate in cases countries were determined by the US to subject US residents to “extraterritorial” or “discriminatory” taxes.

If passed into law in 2025, provisions that impose the additional tax could take effect as early as January 1, 2026.

This provision remains as a revenue raising provision in the version that now sits with the US Senate for consideration.

What portfolio investors and financial institutions can do now:

  • Portfolio investors should assess whether and to what extent such an additional tax on investment income would impact their investment returns and inform future investment strategy.
  • Financial Institutions (including entities acting as Qualified Intermediaries, non-Qualified Intermediaries, and Withholding Agents) should assess the development required modify US nonresident tax withholding systems, operating, and reporting models.

Brown Brothers Harriman (BBH) will continue to monitor and communicate updates as these proposals move through the legislative and regulatory development process.

More in depth information regarding the current Bill proposal can be found here.

If you would like to learn more about challenges and the potential opportunity of tax transparency, please contact us.

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