Update: 899 Penalty Tax Will NOT Go Forward – Secretary Bessent Claims Mission Accomplished!

Prologue

I have been following the discussion about the “Big Beautiful Bill” and written blog posts about the proposed IRC S. 899 Tax titled:

“Enforcement Of Remedies Against Unfair Taxes”

The blog posts are here:

Take YOUR Money And Run: Understanding The Proposed § 899. ENFORCEMENT OF REMEDIES AGAINST UNFAIR FOREIGN TAXES

http://citizenshipsolutions.ca/2025/05/20/take-your-money-and-run-understanding-the-proposed-%C2%A7-899-enforcement-of-remedies-against-unfair-foreign-taxes/

The Proposed S. 899 Penalty Tax On U.S. Source Income And The Decision To Renounce U.S. Citizenship

https://citizenshipsolutions.ca/2025/06/25/the-proposed-s-899-penalty-tax-on-u-s-source-income-and-the-decision-to-renounce-u-s-citizenship/

UPDATE – June 26, 2025

It now appears that the S. 899 tax will NOT be included in the “Big Beautiful Bill”.

An early indicator of this decision came from Zorka Milin here:

This was followed by a general announcenent from Secretary Bessent here:

Senator Crapo here:

Representative Smith here:

Good commentary here:

I will add more later.

John Richardson – Follow me on X.com @ExpatriationLaw

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