Is Trump’s ‘Revenge Tax’ About to Shake Your US Investments—And How to Outsmart the Storm Before It Hits?
Currently, one version has been passed by the US House of Representatives and another is due to be voted on by the Senate.
It’s worth saying that the entire bill is still subject to amendment as it journeys through Congress. Section 899 is not yet set in stone.
But here’s where we’re at:
| Section 899 WHT | House version | Senate version |
| WHT rate after phase-in | 50% | 15% to 45% depending on existing treaty rates |
| Phased rise | 5% per year | 5% per year |
| DTA discount effect | All rates rise 5% per year until the 50% cap is reached. | DTAs cushion the blow e.g. Existing 0% rate rises to max 15%. 30% rate rises to max 45%. |
A quick example may help you better understand these proposals.
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