US Senate Finance Committee Makes Changes to Proposed Section 899

By Julie Burrall, Steven D. Garden, Lucas Giardelli, David Goett, Jared B. Goldberger, Michelle Jewett, Kenneth Klein, Russell E. Nance, Warren S. Payne, Remmelt Reigersman, Sam Riesenberg & Brennan W. Young on June 23, 2025

Posted in Tax

The US Senate Finance Committee has released a substitute (the “Senate version”) for the tax provisions of the “One Big Beautiful Bill,” the budget reconciliation bill currently under consideration by Congress. An earlier version of this bill was passed by the US House of Representatives on May 22, 2025 (the “House version”). Our prior Legal Update, US House Passes Bill Targeting ‘Unfair Foreign Taxes’, provided a summary and analysis of the House version of the retaliatory tax measures introduced by Proposed Section 899. Here, we highlight the important changes in the Senate version of Proposed Section 899.

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