Recent US tax developments - Sec. 891 and Sec. 899 IRC

Frisch serviert - der Steuerpodcast · Feb 19, 2025 · 42m

In this episode Arne Schnitger and Christian Kaeser welcome Pat Brown, a Partner and Co-leader of PwC's Washington National Tax Services practice. They focus on recent developments relating to US tax policy, particularly Sec. 891 and Sec. 899 of the Internal Revenue Code (IRC). Sec. 891 IRC, enacted in the 1930s and never brought into force until now, allows to double the tax rate on citizens and corporations from countries engaged in extraterritorial and discriminatory taxation against the US. President Trump has authorized an analysis of whether or not countries are engaged in…