The AFIRE Podcast
The AFIRE Podcast
AFIRE
Tax Drama: New US Policy Impact on Cross-Border Investors
26 minutes Posted Sep 2, 2025 at 4:20 pm.
AFIRE CEO Gunnar Branson intro
Welcome Shiukay Hung, Partner & Co-Chair, DLA Piper
Cross-border investor concerns
How big was the retaliatory tax threat?
What does the bill mean now?
Section 899 is gone, but the risk remains
What should investors be paying attention to?
Can the bond market keep us in check?
Who really influenced policy?
What investors are missing?
Final remarks
0:00
26:09
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Show notes
The One Big Beautiful Bill is now signed into law, prompting questions about tax risks, retaliatory measures, and impacts on U.S. real estate. So what does it all mean for cross-border investors in property markets?
AFIRE CEO Gunnar Branson sat down with DLA Piper tax partner Shiukay Hung to discuss the impact of the bill. “The Big Beautiful Bill is a very interesting piece of legislation,” says Hung, “Perhaps it's one of the few tax legislations in recent memory that came with a lot of tax drama.”
The bill, which aimed to maintain tax cuts, proposed a 50% retaliatory tax on foreign investors from countries with unfair tax practices, and could have significantly affected investment returns. Despite initial concerns, the retaliatory tax provision, Section 899, was dropped before passing.
Now that the bill is law, how should cross-border investors weigh domestic tax exemptions against international treaties, and what role does the bond market play in shaping policy? It’s all in the latest episode of the AFIRE podcast.
LINKS
Register for the 2025 AFIRE Annual Member Meeting Sept. 9-10 in NYC https://www.afire.org/events/amm25/
Read Shiukay’s paper on the Big Beautiful Bill
https://www.dlapiper.com/en-ca/insights/publications/2025/06/litigation-funding-tax-and-retaliatory-tax
Watch the AFIRE POV series of investor interviews
https://www.youtube.com/playlist?list=PLOrtO-j6M9aS8Hr7DHeg562A8-HQrxi8o
Read the latest articles from Summit Journal Issue #18
https://www.afire.org/summit/
Access the episode webpage featuring links to audio-only platforms here:
https://www.afire.org/podcast/202515cast/
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