In the US, Congress has been considering the 'One Big Beautiful Bill Act' Bill (the " Bill "). The Bill was passed by the House of Representatives on 22 May 2025, and is now heading to the Senate.

From a tax perspective, the Bill comprises both domestic and international provisions, including an extension of soon-to-expire tax cuts that were passed in 2017, during President Trump's first term in office. Additionally, and of particular interest to certain non-US persons, are the Bill's retaliatory tax measures which could, if passed in their present form, impact UK corporates with US operations. These measures are considered further below.

Retaliatory tax measures – Section 899

The Bill (at section 112029) introduces a new section 899 'Enforcement of Remedies Against Unfair Foreign Tax

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