Conversations on International Expansion
The Orsa Saiwai Podcast is your ultimate guide for North American businesses and CPAs navigating the complexities of expanding internationally.
Whether you're a business owner looking to explore new opportunities or a CPA supporting clients in their international ventures, this podcast is tailored just for you. essential topics such as tax regulations, HR requirements, and strategic expansion tips are going to be covered
Conversations on International Expansion
Episode 7: Section 899: Unpacking the "One Big Beautiful Bill Act" and its Global Tax Implications
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In the podcast David Tuomey from Orsa Saiwai Europe and Sean King from Align Global dive into Section 899 of the proposed "One Big Beautiful Bill Act" (OBBBA), currently under Senate review after passing the U.S. House in May 2025. This episode explores how this pivotal legislation could empower the U.S. Treasury to levy significant new taxes on foreign investors and companies, particularly those from nations perceived as unfairly taxing American businesses.
We break down the potential impact of measures like Digital Services Taxes (DSTs), the OECD’s Undertaxed Profits Rule (UTPR), and Diverted Profits Taxes (DPT), and discuss how Section 899 could affect a broad spectrum of U.S.-sourced income, including dividends, corporate bond interest, property rent, and profits from U.S. branches of foreign companies.
Tune in to understand the far-reaching implications for global finance and international tax policy.