Section 899 was a proposed tax measure in the 2025 bill debate, but it was removed before enactment. The One Big Beautiful Bill Act, Public Law 119-21, was signed on July 4, 2025, without Section 899. It is not a tax imposed by that Act.
What was the Section 899 “revenge tax”?
Section 899 was a proposed retaliatory tax provision. It was framed as a response to foreign taxes the United States considered unfair or discriminatory. Legal summaries describe it as potentially raising U.S. tax rates on certain U.S.-source income received by non-U.S. taxpayers connected to jurisdictions deemed discriminatory. “Revenge tax” was a label used in public debate, not the enacted name of a current tax. Legal analysis of the bill and another legal summary describe the proposal at a broad level.
The affected parties and mechanics depended on the proposal version. The available summaries do not establish a complete draft-by-draft account of covered taxpayers, exceptions, or effective dates, so those details should not be treated as settled features of a single final provision.
Did Section 899 become law?
No. Section 899 was omitted from the final One Big Beautiful Bill Act, Public Law 119-21, signed on July 4, 2025. The Act therefore did not enact the proposed Section 899 tax. The enacted law and legal coverage of the measure confirm its omission.
What would the proposal have done?
Broadly, the proposal contemplated increased U.S. taxes affecting certain foreign persons or entities and investment income associated with countries regarded as imposing discriminatory taxes. The exact reach varied by draft and should not be collapsed into one definitive rule.
One House-proposal rate summary
The Tax Foundation’s 2026 summary describes an early House proposal as increasing rates by five percentage points per year, up to a 20-point cap. That figure describes a proposal version—not current law—and is not a complete explanation of every draft’s rate rules. Tax Foundation’s summary provides that characterization.
Why was Section 899 removed?
The Associated Press reported that congressional Republicans agreed to remove the proposal after Treasury Secretary Scott Bessent requested its removal. AP connected the request to an understanding with other countries concerning the OECD global tax deal. The AP report covers that political context.
A legal analysis describes the G7 understanding as addressing the treatment of U.S.-parented groups under global minimum-tax rules. The legal analysis discusses that understanding. These accounts explain the reported backdrop to the decision; they do not, by themselves, establish every legal detail or subsequent implementation of the international arrangement.
Recommended Free Tools
What does this mean for taxpayers and investors?
For purposes of the 2025 Act, the key distinction is between a proposal debated by Congress and a provision enacted into law: Section 899 was the former, not the latter. Descriptions of its possible tax effects should be attributed to the relevant draft rather than presented as rules currently imposed by Public Law 119-21.
Sources discussed possible investment effects, but the cited material does not establish a measured market outcome caused by the proposal or its removal. Nor does it resolve how each draft would have applied to every taxpayer or investment structure. Readers with separate cross-border tax questions should evaluate those circumstances under applicable current law; this history is not individualized tax advice.
Quick Recap
Product prices and availability are accurate as of the date/time indicated and are subject to change. Any price and availability information displayed on Amazon at the time of purchase will apply.
