Abstract
In this article, Cui argues that the One Big Beautiful Bill Act’s formerly proposed section 899, targeting “unfair” foreign taxes, was more sensible than many observers initially perceived, and that, if seen as a restrained deployment of U.S. market power, it represented a defensible and ultimately acceptable approach for addressing the undertaxed profits rule and digital services taxes.
| Original language | English |
|---|---|
| Pages (from-to) | 19-28 |
| Journal | Tax Notes International |
| Volume | 119 |
| Publication status | Published - Jul 7 2025 |