President Donald Trump’s One Big Beautiful Bill Act (H.R.1), a sweeping budget reconciliation plan, passed the House of Representatives on May 22, 2025, and is now under review by the US Senate. Buried in its one thousand-plus pages is Section 899, a hitherto obscure clause that could unsettle global capital markets and test investor confidence in America’s financial leadership and market stability.
Section 899 and Trump’s strategy
As passed by the House, Section 899 would empower the Department of the Treasury to publish a quarterly list of “discriminatory foreign countries,” which are jurisdictions that it deems to impose “unfair” taxes on US businesses, such as digital services taxes or the undertaxed profits rule in the Organisation for Economic Co-operation and Development’s Pillar Two…
