The Trump administration has recently advanced a series of initiatives that significantly expand the scope of U.S. economic protectionism, targeting foreign tax practices perceived as discriminatory against American interests. These measures, which include the introduction of proposed Section 899 and the potential activation of Section 891 of the Internal Revenue Code, represent a marked shift in U.S. policy, with important implications for international businesses and cross-border tax planning.

Implications for Canadian businesses and investors

Canadian institutional and retail investors with holdings in the U.S. that yield dividends or interest (directly or through investment vehicles) will see the return on their investment affected by the additional 5% withholding taxes.

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