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Trump’s ‘revenge tax’ and what it means for your US investments 

Oh god, what now? What now is Section 899 of the One Big Beautiful Bill – Trump’s monster-truck ‘tax and spend’ act currently bouncing around the halls of Congress.

Section 899 has been dubbed a ‘revenge tax’ because it targets individuals, corporations, and governments of foreign countries who are deemed to be hitting US entities with ‘unfair foreign taxes’.

Foreign countries like China, North Korea, and that island where all the tariff-loving penguins live, right?

Not necessarily. Quite possibly foreign lands like the UK, the EU, Australia and Japan. Plus anyone else who perhaps had Big Tech in mind when they drew up undertaxed profits rules (UTPRs), digital services taxes (DSTs), or diverted profits taxes (DPTs).

How does Section 899 affect ME?

Yes, I hear you.

The most likely impact at the time of writing is that you, an individual resident in a major US trading partner and ally, quietly building up your nest egg chock full of American assets, could be on the hook to pay a higher rate of US withholding tax (WHT).

There could be other spillover effects too but I’m going to concentrate on the most immediate – and talk about how you could mitigate the worst, should it happen.

Currently, withholding tax is due on income paid by US assets to overseas owners.

Many Monevator readers already pay withholding taxes on US equities and bonds1, although that’s not always apparent.

For example, a non-US domiciled fund will pay withholding tax on your US income before distributing the balance as dividends or interest (or reinvesting the cash back into the fund.)

That’s so much background. The nub of the problem is that anyone paying US withholding tax – whether directly or indirectly – could be in the firing line.

WHT? WTF more like

The main rate of US withholding tax is 30%. It’s levied on income, not capital gains.

Right now, you’re typically in for 15% WHT on US securities held via an Irish-domiciled fund or ETF. You get 50%-off the main rate due to a Double Taxation Agreement (DTA) that exists between the United States and Ireland.2

UK domiciled funds also qualify for the 15% withholding tax rate. Mighty Blighty has a deal with Uncle Sam, too.

Fund managers have to actively claim the rebate, which I imagine is much like wangling a gift voucher out of your mobile phone provider: “Only valid when accompanied by an original receipt, recent dental X-ray, and proof of being heir to the throne…”

It’s commonly accepted that Irish ETFs only pay 15% WHT but it may be worth checking the specifics if you invest in another type of fund.3

Got a portfolio of individual US stocks? Then fill in a W-8BEN form to reduce your WHT rate to 15%.

Ideally hold your portfolio of Made In America assets in a pension or SIPP. Choose the right platform and your SIPP scoops a 0% rate – no paperwork required.

What are the withholding tax hikes proposed under Section 899?

Section 899 goes from bad to worse depending on which version of the legislation we’re talking about.

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 WHTHouse versionSenate version
WHT rate after phase-in50%15% to 45% depending on existing treaty rates
Phased rise5% per year5% per year
DTA discount effectAll 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.

Let’s say you (or your fund) currently pays a 15% WHT rate on US dividends. In this case the House plan will demand 50% of your income in year seven after Section 899 is invoked.

That’s the ceiling rate. You’ll pay 50% from there on in (as will everyone else once the 5% per year phased hikes have done their work.)

The Senate version still screws you, but it’s gentler, possibly more classy. The lovely senators jack the rate three times and respect your DTAs.

F’r instance, a 15% payer caps out at 30% after three years.

It’s still less than ideal.

How bad?

You can estimate your loss of return by multiplying your investment’s dividend yield by your WHT percentage.

The S&P 500’s dividend yield is 1.3% according to the current S&P Dow Jones factsheet. So your loss to withholding tax is approximately:

WHT rate0%15%30%45%50%
Loss of return0%-0.2%-0.39%-0.59-0.65%

Thus if you pay 15% WHT now, your dividend return is reduced from around 1.3% to 1.1%

The House’s 50% revenge rate would cut your dividends in half. You’d be losing 0.65% based on the current yield.

That will add up over time.

Moreover, the S&P 500’s yield is near its historic low. An average yield of 1.5% to 2% is more typical.

The effect is worse still if you’re invested in higher-yielding stocks, such as a US dividend growth strategy.

Run away?

It’s important we don’t lose our heads.

Nobody wants to lose halve their dividend return, but here’s what it would have looked like (red line) compared to the returns you actually made investing in the S&P 500 this past decade while paying 15% WHT (blue line).

Nominal USD annual total return data from Aswath Damodaran. Fund costs not included. June 2025.

In the worst-case 50% WHT scenario you’d have booked a 12.1% annualised return instead of a 12.7% annualised return over ten years.4

As I say: not great. It does hurt!

But you would still have been better off investing in US equities versus the World ex-US over this period, even if ultimately exposed to the hardcore version of Section 899.

Tax tail meet investment dog

Of course we can argue that the S&P 500 would have been less attractive to global investors, or that US holdings will henceforth come with greater political risk attached…

I’d sign up to all of that.

But pre-emptively moving now to down-weight the US in our portfolios solely on the basis of Section 899 looks premature to me.

For a start the US is likely to remain one of the most dynamic markets in the world and trying to guess what will happen next is a fools’ errand. Perhaps now more than ever.

Secondly, there’s a great way to get around Section 899 – SHOULD IT HAPPEN. (Sorry about the all-caps, just channelling my inner Trump there.)

The work around

There are #reasons to think you won’t have to face the revenge tax even if the bill passes.

Synthetic ETFs don’t have to pay US WHT. They duck the tax by using a financial derivative to pay the index return – as opposed to the normie approach of actually holding the shares that comprise the index.

This isn’t regarded as a tax dodge.

Synthetic S&P 500 ETFs have been operating since 2010. They’ve accumulated billions in assets under management. They’re not in the cross-hairs of the IRS.

iShares, Xtrackers, and Amundi have all launched new synthetic S&P 500 ETFs in the last few years as word spread that their withholding tax advantage gave them the edge over physical ETFs.

World and global synthetic ETFs are available, too.

Sure, the US government could level the playing field later.

But for now this is an obvious get-out.

Are US Treasuries affected?

In a word, “No.” In three words, “No, for now.”

The Senate bill clarified that even the House formulation doesn’t intend to go after foreigners who are helping to fund the US deficit by owning US fixed income.

So we can rest easy on that.

Even if some maniac flips out and changes their mind then the obvious remedy would be to forget Treasuries and hold gilts instead.

Negotiation tool

(Ooh, I’m pleased with that one. Just when I thought I was all out of nicknames for Trump!)

Section 899 is intended as a tool for negotiation. It would cease to apply in the tax year after a country drops whatever tax displeases the US Treasury Secretary.

From that perspective, the phased 5% hikes are a useful way of turning the tax thumb screws: “Don’t make me do this.”

Of course, the UK or the EU may not cave. (Well, we probably will. But they may not.)

I’d need to consult a tax lawyer to understand what would happen if the UK quietly mothballed the offending taxes while Ireland didn’t.

Irish-domiciled ETFs are typically structured as Irish corporations and pay withholding tax at the fund level, so UK domiciled funds could gain a competitive advantage in that scenario.

There’s also a Section 899 exemption for ‘United States-owned’ foreign corporations. This applies if more than 50% of the entity’s vote or value is held by US persons.

Could that mean we’d be protected from Section 899 by funds from US firms like iShares, Vanguard, or State Street? Again, I’m not an international tax lawyer on a MAGA retainer. (Though I wish I was paid like one).

What’s more, a cavalcade of financial industry special interests and lobbyists is apparently working to water down the provisions as they stand.5

Finally, the One Big Beautiful Bill Act could fail to pass into law. That does happen in Congress. So this is far from a done deal.

Finally, finally, we could club together and send Trump a new Statue of Liberty. But with his face. Made out of gold. He’d like that. 

Take it steady,

The Accumulator

P.S. ‘Section 891’ already exists in US law to punish foreigners adjudged to impose unfair taxes on US citizens and interests. It’s never been invoked. Apparently Section 899 is thought more likely to be implemented (if it becomes law) because it’s not as harsh.

P.P.S. Other Section 899 provisions could adversely impact the profits of non-US companies. But that doesn’t seem worth getting into yet given all the uncertainties. Also, the damage estimates seem small, and companies could legally shape-shift their ownership structure to avoid the incoming.

  1. Lots of other countries levy similar withholding taxes but we’re not concerned with that here. []
  2. Remember it’s the fund that pays. While you don’t incur withholding tax on dividends paid directly to you by Irish-based funds and ETFs, that’s because they’ve already settled accounts with Uncle Sam before you get a sniff. []
  3. Contact the fund manager or look in the annual report. Find the section that details the amount of overseas dividends received and tax paid. Divide the tax paid by the dividend amount. Multiply by 100 to discover the effective withholding tax rate. Note, this will only give you the effective US withholding tax rate if the fund invests 100% in US assets. []
  4. Nominal USD returns. []
  5. Hard to believe I’m cheering on this crew. []
{ 30 comments… add one }
  • 1 Dumb Radish June 24, 2025, 1:31 pm

    A big chunk of my retirement income is due to come from my US dividend growth SIPP portfolio. I don’t pay any withholding tax at the moment by filling in a W8-BEN form. This seems complicated but any idea whether that situation will remain the same. I guess the answer is we will have to wait and see…

  • 2 The Accumulator June 24, 2025, 1:44 pm

    As it stands, if the House version prevailed then you’d pay 50% WHT after a decade of 5% rises – assuming no negotiation from affected countries.

    If the Senate version won out then you’d be in for 15% once the ratchet effect was complete.

    Again, that assumes no amends to the current position, no negotiation, or climbdown, or launch of swap-based dividend growth ETFs.

    There’s a long way to go.

  • 3 Jeffrey Beranek June 24, 2025, 3:37 pm

    Note that if you’re a U.S. citizen resident in the UK and hold individual U.S. company shares, then it’s a W-9 form that you send to your platform. Also, if you file a US return (as you typically will be required to) then depending on your personal tax situation you might be able to get any US withholding tax refunded. Unfortunately I don’t think this would work with funds, as the fund pays the WHT, not you. Just be warned that dividends (and capital gains or losses) on US shares are potentially treated differently than “foreign” shares, and can complicate any foreign tax credit claim calculations.

  • 4 trufflehunt June 24, 2025, 4:07 pm

    Bearing in mind that much of the chaos that has engulfed stock and bond markets in the not too distant past has been caused by the various permutations of derivatives…, that is precisely why, in my fund choices, I try to avoid anything other than ‘physical’.

  • 5 Howard June 24, 2025, 4:30 pm

    The Blue and Red line ($3.31 end value & 12.7% CAGR v $3.13 & 12.1%): all to the good and yes *generally* speaking US firms go for buybacks over dividends or for growthy stuff eschew dividends entirely (I see the very first reader comment on Monevator ever was about this latter point). That all serves to greatly mitigate this section 899 madness – if it comes to pass (many things are too stupid to be credible but nothing is too cretinous to actually happen).

    But there’s a cloud to that silver lining.

    Many very tastily valued (some might venture undervalued) international stocks (ex US Developed Market and Emerging Market / Frontier Markey) are only really accessible in the UK via the NYSE.

    These include some perhaps interesting dividend payers (or at least interesting to me – YMMV).

    Going Deep Value here, in the much loathed and shunned EM / FM oil sector and in the equally hated cyclical tanker sector you’ve got Columbia’s EcoPetrol (EP) with a 18% dividend yield, Brazilian Petrobas (PBR) on 14%, and then Nordic American Tankers and International Seaways, each on 10% yields.

    If Uncle Sam is going to end up withhold multiples of the 15% allowed under DTAs for WHT then that will surely make a big difference to those stocks, even though (in the case of the first two examples) neither Columbia or Brazil get any say in it, nor any benefit from it (notwithstanding that each State effectively backstops EP and PBR respectively).

  • 6 talexe June 24, 2025, 4:49 pm

    A dumb question, just to be certain: will I notice the impact of this tax as a hidden drag on returns, or is the cost borne by the fund manager and passed on as higher fees?

  • 7 The Accumulator June 24, 2025, 7:04 pm

    @talexe – it’s a drag on returns.

  • 8 Lurker June 24, 2025, 8:37 pm

    This is a direct assault by the US on the US/UK tax treaty. That is, the treaty – which the US signed on to – specifically limits the US to 15% in tax on dividends. This law simply and intentionally overrides (reneges on) that, in contravention of the Vienna Convention on the Law of Treaties.

    Additionally, look at the “remittance tax” in the same bill. It’s drafted to apply a 3.5% (currently) tax on all money sent out of the US by non-US citizens. It is unclear if it affects non-US residents holding US accounts, but either way, that’s a second tax treaty override there, then. It is also the start of US capital controls.

    Now, the modest returns drag from 5% here or there on dividends might not make you reconsider investing in US stocks. However, it is the evident contempt the US has for tax treaties, and the offhand and cavalier way in which the US is prepared to simply ignore them, that is the real cause for concern. This would be the reason to reconsider.

    Even if this nonsense doesn’t pass now, it will crop up later. By merely proposing it, the US has signalled strongly that it can no longer be considered a safe or reliable place in which to invest.

    Section 899 is already causing large sovereign funds to avoid making new investment into the US, and to halt the progress of any ongoing ones. Maybe TACO, but if not, the end point of this could be ugly for all sides.

  • 9 FunkyDrummer June 24, 2025, 11:30 pm

    I think it might be worse: If the DTA is not updated promptly, could it mean that, when paying taxes on US investments held directly (as I am sure quite a few of us UK-based non-US international people do), we would only get the current UK 15% rebate as per DTA on the WHT at 50%? That would mean an additional rate UK tax payer normally paying 39.35% tax on dividends (to the US and US in aggregate as per UK tax) would end up be paying not “just” 50% (to the IRS via WHT), but would also still be paying (39.35%-15%) to HMRC, for an insane total of 74.65%. Please tell me I am wrong…

  • 10 Howard June 25, 2025, 8:06 am

    @Lurker @FunkyDrummer #8, #9: like so much with MAGA s 899 tramples int’ law, agreements & norms. But as volatility is the price of admission to equities maybe s 899 will be the price to access best of class established growth? Where else can you find a quadi monopolistic company like Nvidia which has gone from just $10 bn income in August 2023 to $76 bn in the last quarter whilst its TTM PE has reduced from 247 (compared to 24 for the market at that time) to just 46 (it’s forward PE is just 29 now).

    And this is no isolated example:

    – Amazon had a 742x PE in 2015, net income then exploded from $600 million in 2015 to $66 billion in 2025.

    – Tesla had an 862x TTM PE in 2020 and is now still trading at 174x, but even after the recent drawdown, you would have doubled the return of the S&P 500.

    – Broadcom had a 137x TTM PE last year. Now it’s up 57%, 5x the performance of the S&P 500

    So, maybe we just have to lump it with s 899 if it comes in??

  • 11 The Accumulator June 25, 2025, 10:15 am

    @Funkydrummer – Yes, you’re right. Though the tax would phase in at 5% a year giving you time to rethink tax shelter priorities.

  • 12 Jeffrey Beranek June 25, 2025, 10:47 am

    @FunkyDrummer according to the current tax treaty you can potentially claim up to 15% tax relief on US share dividends using foreign tax credits on your UK self-assessment tax return, assuming you’ve been “double taxed” on the same income in the UK (i.e. not ISA or SIPP dividends, nor the dividends within the personal dividend allowance).

  • 13 Lurker June 25, 2025, 11:02 am

    @Howard #10. “Lumping” section 899 is indeed one option. For now.

    What you have to start thinking about is, what next? Section 899 simultaneously increases (political) risk and decreases returns for US stocks – quite a feat. At minimum, expect US stock prices to fall to compensate. The tail risk is that given enough capital flight, the US extends capital controls, applies capital gains tax to non-US investors, adds exchange controls to the mix, and so on. We are no longer dealing with anything even close to a rational administration.

    The cognitive dissonance on display with all of this is astonishing. Tariffs aim to push companies towards moving to the US, and then this punitively taxes any company that does. Springing a tax trap before you’ve even enticed your victims in is pure incompetence.

  • 14 FunkyDrummer June 25, 2025, 12:14 pm

    @Jeffrey, correct and my point is that if the treaty doesn’t get updated to take effect at the same time as the increased WHT, that will probably mean we will be double-taxed until the treaty exempts for the same amount as WHT (or at least the UK rate)

  • 15 FunkyDrummer June 25, 2025, 12:21 pm

    @TA #11, thanks for confirming and for writing this article.

    In my case I would have to weigh selling US assets to lower dividend taxes over X years (had not plan to get rid of them until retirement/when needed) vs the very significant UK capital gains tax that would immediately follow. Is there an article that helps with this type of decision?

    Will you keep us updated if this bill gets approved? If it does, is there any clarity as to when it would be effective? Many thanks!

  • 16 FireIT June 25, 2025, 12:42 pm

    @Lurker – Thanks for pointing out the 3.5% tax.

    I work remotely in IT for a US company and a portion of my renumeration is ‘paid’ in RSUs which vest after a period of time. These are (currently) held by a US provider where I sell them once they vest and transfer the cash out of the US to the UK. Thanks to your heads up I’ve fired off a question to HR & Finance to see if we can move the RSU holding company out of the US. Not worth doing it for just me, but they have ~50k+ employees outside the US that it will also affect.

  • 17 wireless June 25, 2025, 9:46 pm

    Thanks TA for this good article.

    According to the WSJ (23/6/25) the Trump administration’s proposed tax bill on foreign investors is already causing European and Asian investors to rethink investments in U.S. private capital funds. Apparently some European investors have delayed signing subscription documents.

  • 18 Hak June 26, 2025, 11:44 am

    As someone that has all that US equities invested into Berkshire and, given it does not pay any dividend, I am presuming this will not hurt me as their is no income derived from my ownership.

  • 19 xxd09 June 26, 2025, 11:17 pm

    Some comment on Bloomberg tonight that Trumps “Revenge Tax” has been killed
    xxd09

  • 20 The Investor June 27, 2025, 9:12 am

    @xxd09 — Indeed, similar in the FT last night. It sounds like the usual story of the more reasonable people (the US Treasury/Scott Bessent in this case) trying to reign in the extremists (the MAGA wing), as we saw with the tariffs before:

    https://www.ft.com/content/5d99c735-97e4-4574-be16-81da32ac48eb

  • 21 The Accumulator June 27, 2025, 12:44 pm
  • 22 Howard June 27, 2025, 10:28 pm

    Is this a Sell the News moment?

    SPY at ATH again.

    Climbed the wall of tariff woe, war fears and then revenge tax worry from 4835 to 6187 intraday in all of two and a half months (7/4 to 27/6).

    Only FX matket betrays ebbing confidence in US fiscal, investment and trade policy probity.

    Problem is that everytime I end up pondering the mad king Trump and look concerningly at all the many, many measures of US large growth (USLG) overvaluation (Q ratio, market cap to GDP, CAPE blablah), both relative to their own history and to other matkets; I end up returning to this question:

    Just what exactly is the alternative here?

    Put another way:

    Where is non US listed equivalent:
    – to Nvidia, AMD, ARM, Cadence Design and Applied Materials (semis), or
    – to Palantir and Crowdstike (enterprise AI) or
    – to Microsoft and Amazon (cloud) or
    – to Broadcom and Arista Networks (data centres) or
    – to Meta (wearables/social network) or
    – to Tesla (robotics/FSD/batteries, with a legacy EBV business) etc?

    Amsterdam’s got ASML for sure, but I can’t honestly see the likes of UK AI minnows Bytes Tech, Kainos Group, Eagle Eye Solutions and Softcat being or ever becoming peers to the Americans here.

    Avoiding USLG on fears over s. 899, over tariffs or over Trump more generally means avoiding tech and favouring instead cheap but low to no growth.

    That might turn out to be the right call to make, but it’s not obviously such now.

  • 23 Jonathan the Evil June 29, 2025, 10:06 am

    “Oh god, what now?”

    Proper nouns take an initial capital in English.

  • 24 SemiPassive June 30, 2025, 10:30 am

    Excuse my laziness but does anyone know if iShares US $ High Yield Corp Bond Irish-domiciled distributing ETF, ticker SHYU, is impacted (held in SIPP)?

  • 25 Seeking Fire June 30, 2025, 8:46 pm

    RE graduate jobs – I would argue that in many, not all cases, the jobs being eradicated were adding questionable value. Universities continue to churn out graduates with degrees that are adding no value. Hence there isn’t much work for an events management or criminology graduate – waste of time. Politics cannot really trump capitalism despite the vested interests. I feel your typical ‘blue collar’ type work will start to command a > premium to so called ‘white collar’ jobs. Good luck chat gpt’ing your way to fixing your toilet if you don’t want to get your hands dirty. This is probably good news in the long run but painful for many people. But tough luck.

    RE US Revenge Tax – you can see the US making it considerably harder to own US assets for Jonny foreigner in the coming decades. Why should people outside the US benefit from what a US company generates? Think WHT, Dividend Tax, Super CGT etc etc.

    I’m strongly of the view – the US is the best place to be to live and work in future decades not withstanding the media madness that’s going on. Get yourself over there if you are smart enough to do so.

    In the UK, its going to be privatisation of key services by stealth, greater taxes – think freezing of the bands and more wealth tax, much more immigration to counter balance people retiring, greater expansion of the welfare state and no appetite at all to turn things around. No growth in the pie, just fight over the sharing. Continued managed decline is the best to hope for. Needs a reset – Reform might hurry along the process once they are exposed for the charlatans they are in govt. The only puppeteer the UK has now is the bond market. If you’re well north of 7 figures liquid you’ve got options, everyone else…best of british!

  • 26 The Accumulator July 1, 2025, 1:08 pm

    Section 899 seems to be officially dead.

    @Seeking Fire – I’d much rather live in Europe than the US. And I love the US. I don’t think we can project trends ever outwards. Pre-GFC the UK was reeling in US GDP per capita hand-over-fist. Then we weren’t.

    Go back to the 1970s – we’re the sick man of Europe. That was the spur that enabled reform. It seems at least as likely to me that our current predicament can be used to force through the changes required. (Admittedly, the current Labour administration is beset by division but so was Thatcher’s.)

    Another example: Germany’s economic model performed brilliantly after the GFC but looks precarious now.

    The US could be a very bad place to be – especially for an immigrant – if Trump and his successors successfully subvert US democracy. Perhaps better not to take that risk? To seek a life in a friendlier country?

    I totally agree there is a massive opportunity in the trades.

    Re: US revenge taxes et al. The US benefits from allowing the rest of the world to finance their deficit. That’s why cooler heads in the administration are killing Section 899.

  • 27 Lurker July 1, 2025, 1:34 pm

    TA @26 “The US benefits from allowing the rest of the world to finance their deficit. That’s why cooler heads in the administration are killing Section 899.”

    That’s one way of looking at it, I suppose. Another is that Section 899 has already accomplished its purpose, which is to coerce other countries into backtracking on some taxes the US doesn’t like. Which they have done.

    What the US emphatically did not do is kill this because it openly tramples virtually every US tax treaty. Its mere proposal is fully indicative of the level of disdain the US really has for its treaty partners.

    With blackmail, if you pay it you can expect the perpetrator to return later for more. Section 899 is blackmail. It is not (and now never will be) dead. It is merely asleep and waiting to be dusted off and used again when expedient.

  • 28 Howard July 1, 2025, 2:31 pm

    Foreigners own $19tn of US equities, $7tn of US Treasuries and $5tn of US corporate bonds (Apollo’s Torsten Sløk). That’s a lot of selling USD if s. 899 had proceeded as planned. A weak $ does not MAGA make. The Greenback’s off to its worse H1 since 1973. ‘Sad’ as the Donald might put it.

  • 29 The Accumulator July 1, 2025, 4:23 pm

    @Lurker – I believe you are right to a degree, though Howard makes a good counterpoint.

    Yet another way to look at it is that we know this administration needs off-ramps. You throw them some ‘bend the knee’ meat that they can show to the base. Needn’t be a massive concession.

    I also don’t think we’re dealing with the “US” yet. We’re dealing with Trump’s administration or the MAGA movement. I think it’s unlikely these tactics would be used by a Democratic administration. It’s not impossible to believe that “America First” could become a consensus position in the future. But I don’t think we’re there yet.

  • 30 The Investor July 12, 2025, 1:47 pm

    (For now…?) section 899 *is* dead, it didn’t make the final bill as passed.

    Good deep dive into why not here:

    https://spinningfields.raymondjames.uk.com/wp-content/uploads/2025/07/section-899-has-been-struck-out-of-the-us-one-big-beautiful-bill-legislation.pdf

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