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Senate Weighs Trump’s Section 899 Surtax on Foreign Investors

Treasury Secretary Scott Bessent said the surtax will prevent hundreds of billions in U.S. corporate taxes from flowing to foreign treasuries.

U.S. Treasury Secretary Scott Bessent testifies before a House Financial Services Committee hearing entitled "The Annual Testimony of the Secretary of the Treasury on the State of the International Financial System," on Capitol Hill in Washington, D.C., U.S., May 7, 2025. REUTERS/Nathan Howard/File Photo
President Donald Trump speaks during an "Invest in America" roundtable with business leaders at the White House, Monday, June 9, 2025, in Washington. (AP Photo/Evan Vucci)
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Treasury Secretary Scott Bessent testifies before the House Ways and Means Committee hearing on Capitol Hill in Washington, Wednesday, June 11, 2025. (Jose Luis Magana/AP)

Overview

  • The Senate is reviewing Section 899 as part of the 'One Big Beautiful Bill Act' that passed the House in May.
  • Section 899 would impose escalating surtaxes starting at 5% and rising to 20% on U.S. income of foreign entities from countries deemed to levy 'unfair' taxes on American companies.
  • The administration frames the provision as a tool to compel foreign governments to reverse digital services taxes and OECD Pillar Two top-up levies rather than to generate tax revenue.
  • Investment firms and trade groups warn the surtax could spur foreign investors to flee U.S. equity markets, potentially triggering capital outflows, market volatility and lower fund revenues.
  • Analysis by the Global Business Alliance forecasts the levy could cost 360,000 U.S. jobs and cut annual GDP by $55 billion over a decade, while experts caution it may provoke reciprocal measures abroad.