The Capital War Nobody Saw Coming: How Section 899 Could Reshape Your Portfolio

From trade wars to capital wars—and why your retirement account is suddenly in the crosshairs

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Picture this: Claire Dubois manages $2 billion for a French pension fund. For decades, she's invested heavily in U.S. markets—Apple stock, Microsoft bonds, Manhattan real estate. It's been a win-win: French retirees get stable returns, and U.S. companies get crucial capital.

Then came Section 899.

Under the new tax bill, the U.S. would hit investors from such countries by increasing taxes on U.S. income by 5 percentage points each year, potentially taking the tax rate up to 20%. Suddenly, Claire's "safe" U.S. investments became 20-40% less profitable overnight.

The result? Claire started selling. And she's not alone.

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Section 899 Explained: The Mechanics That Matter

What It Is (Simple Version)

Section 899 is a tax weapon disguised as policy reform. It defines a "discriminatory