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"Dead on arrival: 'Revenge tax' proposal scrapped"

Treasury Department and Congress take steps on Thursday to annul a notorious retaliatory tax, previously designed to increase taxes on foreign investments, causing concern among Wall Street figures and international business executives.

"Revenge Tax' Shelved Just Short of Implementation"
"Revenge Tax' Shelved Just Short of Implementation"

"Dead on arrival: 'Revenge tax' proposal scrapped"

No More "Revenge Tax" Shivers for Wall Street

In a relief for Wall Street and global businesses, the controversial "revenge tax" proposed by former President Donald Trump's administration has been effectively eliminated. The Treasury Department, in collaboration with Congress, has taken steps to ensure Section 899, the tax provision at the center of the debacle, no longer remains a threat.

Treasury Secretary Scott Bessent announced a deal with G7 partners that would exclude US companies from some global taxes in exchange for the removal of Section 899 from the Republican's "One Big Beautiful Bill Act." In a post on platform X, Bessent requested Congress to delete Section 899 from the budget bill. Senators Mike Crapo and Rep. Jason Smith, co-chairing the joint committee on taxation, acknowledged the request and agreed to remove Section 899 from the bill.

Originally, Section 899 aimed to target foreign entities with taxes perceived as "unfair" to American businesses. Analysts at Citi explained that this section would facilitate penalty taxes on foreign companies operating in the US if such firms were deemed to be operating within "discriminatory" tax systems.

The "revenge tax" title stems from its retaliatory nature. It was designed to counteract a global tax framework agreed upon by the Biden administration and the Organization for Economic Cooperation and Development (OECD) in 2021. The framework aimed to set a global minimum tax rate of 15%, a proposal that Republican officials opposed, arguing it surrendered taxation authority. Furthermore, Section 899 was also aimed at retaliating against digital services taxes perceived as discriminatory by the Trump administration.

The repeal of Section 899 offers a fresh perspective on future global tax negotiations, leaving space for collaboration rather than retaliation. Bessent reassured that the Trump Administration "remains vigilant against all discriminatory and extraterritorial foreign taxes applied against Americans." However, it also represents a significant diplomatic breakthrough, fostering a collaborative spirit that supports broader OECD global tax framework efforts.

Wall Street's concern over Section 899's implications and potential impact on foreign investments in the United States have been alleviated for now. International business groups in Washington voiced their approval, acknowledging that the formerly contentious provision would have "squandered opportunity" and contributed to "further isolation."

The "revenge tax" serves as an illustration of the broader complications associated with multinational companies' tax avoidance strategies, particularly via profit shifting. Future negotiations surrounding global tax frameworks will likely address these challenges while endeavoring to strike a balance between fostering fair taxation and maintaining a supportive investment environment.

  1. Following the removal of Section 899 from the Republican's "One Big Beautiful Bill Act," the disagreement over the "revenge tax" now leaves room for collaboration in future global tax negotiations.
  2. The repeal of the "revenge tax" not only relieves Wall Street and global businesses from potential implications but also fosters a diplomatic spirit beneficial for the broader OECD global tax framework efforts.

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