May 29, 2025

House Tax Bill Provision Could Substantially Increase Taxes on Non-US Lenders – A Dilemma for Financing Transactions

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The “One Big Beautiful Bill Act” approved by the House of Representatives on May 22, 2025, proposes to add a new Section 899 to the Internal Revenue Code. If enacted in its current form, the provision would significantly increase US taxes, including withholding taxes, on investors and lenders from certain countries viewed as having imposed “discriminatory taxes” aimed at US persons.

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