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Trump's 'revenge tax' has foreign investors worried

The Trump administration is backing a provision in the Republican reconciliation bill that would allow the Treasury Department to implement a so-called “revenge tax” on certain foreign investors.

The provision, called Section 899, in the bill first gained steam among Republicans in 2023 as a response to former President Joe Biden‘s endorsement of a 15% global minimum corporate tax rate. It was added to the House’s tax legislation before its passage last month.

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Now that an amended Section 899 has made it into the Senate’s version of the One Big Beautiful Bill Act, foreign companies and financial organizations from Europe, Canada, and beyond have ramped up their lobbying against the provision. The Trump administration argues that it will be a critical tool in Trump’s efforts to reset trade and tax relationships with American partners.

The provision itself allows the Treasury Department to identify countries that levy Digital Service Taxes, Undertaxed Profits Rule taxes, and other deemed unfair taxes on American companies abroad as “discriminatory.” Second, the provision allows the Treasury to raise taxes on income generated inside the U.S. by foreign companies, or domestic companies with foreign ownership, on an annual basis with an eventual cap of 15%.

Andrew Lautz, the associate director

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