Do You Know What Section 899 Is?

Several clients hailing from the global allocator community have schooled us to the existence of the “Section 899,” a feature of the “One Big Beautiful Bill Act” (OBBBA) that passed the House of Representatives on May 22. The bill is currently being reviewed by the Senate and Section 899 – which adds a new section to the US tax code titled “Enforcement of Remedies Against Unfair Foreign Taxes” – is likely to remain in place.