Section 899 of the "One Big Beautiful Bill Act," passed by the U.S. House of Representatives on May 22, 2025, introduces a surtax targeting investors from "discriminatory foreign countries" that impose taxes deemed unfair by the U.S., such as digital services taxes (DSTs), undertaxed profits rules (UTPRs), or diverted profits taxes (DPTs). Here's how it impacts retail investors buying U.S. stocks:

### Key Impacts on Retail Investors
1. **Increased Taxation on Passive Income**:
- Section 899 imposes a surtax on U.S.-source passive income (e.g., dividends and interest) for investors from countries with "unfair" taxes. The surtax starts at 5% above the standard rate and increases by 5% annually, up to a maximum of 20% above the statutory rate. For example, if the standard withholding tax on dividends is 30% (or 15% under a tax treaty, like with Canada), this could rise to 35%–50% over four years for affected investors.[](https://www.cnbc.com/2025/05/30/us-set-to-weaponize-taxes-on-foreign-investors-via-section-899.html)[](https://beaconhillwm.ca/understanding-section-899-how-the-new-u-s-tax-bill-could-impact-canadians/)
- Retail investors holding U.S. stocks or bonds in these countries could see significantly reduced returns due to higher withholding taxes on dividends or interest.

2. **Unaffected Capital Gains**:
- The proposed surtax does not apply to capital gains from the sale of U.S. public company stocks, which remain exempt from U.S. tax for non-U.S. persons. This means retail investors can still sell U.S. stocks without facing the additional Section 899 tax.[](https://www.mwe.com/insights/the-proposed-us-tax-regime-for-non-us-investors-and-companies/)

3. **Potential Impact on Investment Decisions**:
- The increased tax burden may discourage retail investors from countries like France, Germany, Canada, or Australia (which have DSTs or UTPR) from holding U.S. stocks, as the higher taxes could erode returns. For instance, Canadian retail investors might face dividend withholding taxes rising from 15% to 35% or more, prompting some to sell U.S. assets or avoid new investments.[](https://beaconhillwm.ca/understanding-section-899-how-the-new-u-s-tax-bill-could-impact-canadians/)
- Sentiment on platforms like X reflects concern, with users like @CanRetireSafe noting that Section 899 could "crush" retirees relying on U.S. investment income.

4. **Indirect Market Effects**:
- The surtax could reduce foreign demand for U.S. stocks, potentially leading to lower stock prices or increased volatility, as warned by Wall Street analysts. This could indirectly affect retail investors globally, including those not directly subject to the surtax, by impacting market valuations.[](https://www.reuters.com/business/finance/wall-street-fears-foreign-tax-budget-bill-may-reduce-allure-us-assets-2025-05-29/)[](https://finance.yahoo.com/news/obscure-tax-item-trump-big-195608308.html)
- If foreign investors, including institutional ones, shift away from U.S. assets, retail investors might face a less liquid market or higher yields on bonds to compensate for reduced demand.[](https://www.ainvest.com/news/navigating-section-899-crossroads-protecting-portfolios-shifting-treasury-landscape-2505/)

5. **Exemptions and Uncertainties**:
- Investors from countries without DSTs, UTPRs, or DPTs (e.g., Japan, as noted for its stable bonds) are unaffected unless their country adopts such taxes.[](https://www.ainvest.com/news/navigating-section-899-crossroads-protecting-portfolios-shifting-treasury-landscape-2505/)
- Entities majority-owned by U.S. persons (e.g., Vanguard Ireland, a subsidiary of Vanguard USA) may qualify for the "Majority US Owner Exception," potentially shielding investors using such funds. However, this depends on specific ownership structures and Treasury regulations, which remain unclear.[](https://www.reddit.com/r/stocks/comments/1kyvstx/section_899_of_the_big_beatiful_bill_implications/)
- The vague definition of "unfair foreign taxes" and the Treasury Secretary’s discretion to designate taxes as discriminatory create uncertainty, potentially affecting investor confidence.[](https://beaconhillwm.ca/understanding-section-899-how-the-new-u-s-tax-bill-could-impact-canadians/)

### Strategic Considerations for Retail Investors
- **Monitor Legislation**: The bill awaits Senate approval, where modifications are expected. It takes effect no earlier than January 1, 2026, giving investors time to adjust.[](https://www.mwe.com/insights/the-proposed-us-tax-regime-for-non-us-investors-and-companies/)
- **Diversify Holdings**: Investors in affected countries might consider non-U.S. assets (e.g., European or Asian equities) or bonds from countries like Germany or Japan to avoid the surtax.[](https://www.ainvest.com/news/navigating-section-899-crossroads-protecting-portfolios-shifting-treasury-landscape-2505/)
- **Review Structures**: Ensure proper documentation of entity residency and beneficial ownership to avoid missteps, as simply holding assets through neutral jurisdictions (e.g., Cayman Islands) may not suffice.[](https://www.mwe.com/insights/the-proposed-us-tax-regime-for-non-us-investors-and-companies/)
- **Hedge Against Volatility**: Some advisors suggest using derivatives like Treasury futures to hedge against potential market turbulence caused by capital flight.[](https://www.ainvest.com/news/navigating-section-899-crossroads-protecting-portfolios-shifting-treasury-landscape-2505/)

### Broader Context
Section 899 aims to counter foreign taxes perceived as targeting U.S. companies (e.g., DSTs hitting tech giants like Amazon and Google). However, it risks deterring foreign investment, including by retail investors, at a time when the U.S. relies on foreign capital to fund its deficit. Critics argue it could weaken the dollar and depress U.S. stock prices, impacting all investors.[](https://www.reuters.com/business/finance/wall-street-fears-foreign-tax-budget-bill-may-reduce-allure-us-assets-2025-05-29/)[](https://www.axios.com/2025/05/30/taxes-section-899-big-beautiful-bill)

Retail investors should consult tax professionals to assess their exposure based on their country of residence and investment structures, while closely tracking Senate developments and Treasury guidance.[](https://www.gtlaw.com/en/insights/2025/5/section-899-proposed-legislation-would-increase-us-tax-rates-on-many-foreign-individuals-companies-and-governments)

hey

it is the big beautiful bill

China US come to an agreement already.

and FED is expected to lower rate in 2nd half. Trump is pushing for lower usd. so fund will flood the stock market.

This post has been edited by ipohps3: Jun 28 2025, 01:08 AM

TSMC, Supermax factories already in US soil. more will come.

tonight market sell off

NVIDIA is on the way to become the 2nd largest stock market after US itself, closing in with Japan stock market.



This post has been edited by ipohps3: Aug 26 2025, 12:46 AM

Nvidia going below 4T?

What Intel gets: ASIC-style wins, with a cannibalization watch-out

Intel will design and manufacture custom client and data-center CPUs for Nvidia. That looks like ASIC economics—contracted volumes and clearer cost visibility—tied to Nvidia's growth. The flip side is channel conflict with Intel's own Core and Xeon lines, so investors should watch product fencing and pricing.

Intel is arguably a major loser in the current AI wave. Its "Datacenter and AI" business name is somewhat of a misnomer, as revenue is overwhelmingly from server CPUs, not AI accelerators. Even in its server CPU stronghold, Intel continues to lose market share to AMD, which has grown its x86 server share from under 5% to over 40% in recent years.

The deal is more than a capital injection; it's a strategic realignment that could reshape the semiconductor landscape for the next decade, creating a formidable new axis against $Advanced Micro Devices (AMD.US)$ and testing the foundry dominance of $Taiwan Semiconductor (TSM.US)$ .

AMD ATH



This post has been edited by ipohps3: Oct 6 2025, 08:14 PM

read Trump truth social

what's the news that caused this?

Wall Street closed sharply lower on Thursday as steep losses in Nvidia, Tesla, Broadcom, and other artificial intelligence (AI) heavyweights weighed on major U.S. indexes. Investors scaled back expectations for interest rate cuts amid inflation worries and divisions among Federal Reserve policymakers over the health of the U.S. economy.

what's the news that caused it?

the tpu is designed in collaboration with Broadcom and more recently MediaTek