Last month, we published briefings considering the 'retaliatory' tax measures (referred to as 'section 899') that were included in the One Big Beautiful Bill Act during the early stages of its passage through US Congress. The measures, targeting certain overseas taxpayers with interests in the US, were removed before the Bill was finalised, alongside the G7 and the US reaching a shared understanding regarding the exemption of US parented groups from aspects of the Pillar Two global minimum tax rules.
The Act itself was signed by President Trump on 4 July 2025. Our US tax team has analysed its tax measures, and a link to their article can be found here.
Key contacts
Toby Eggleston
Partner, Melbourne
Pamela M. Capps
Partner, Head of State and Local Tax, US, New York
Barry Herzog
Partner, Head of Tax, US, New York
Abraham (Avi) Reshtick
Partner, New York
Disclaimer
The articles published on this website, current at the dates of publication set out above, are for reference purposes only. They do not constitute legal advice and should not be relied upon as such. Specific legal advice about your specific circumstances should always be sought separately before taking any action.