Canada's DST may trigger proposed US IRC Section 899

05 June 2025|Tax Alerts, Information Reporting, Information Reporting, Legislation & Policy, National/Federal Taxation, Information Reporting, Legislation & Policy, Global|United States, Canada

The "One Big, Beautiful Bill Act," passed by the US House of Representatives on 22 May 2025, in part introduces IRC Section 899, which is intended to address certain "unfair" taxes imposed by foreign countries — and could have a significant effect on certain Canadian businesses.
By virtue of Canada's enactment of the Digital Services Tax Act (DSTA), Canada would effectively be classified as a "discriminatory foreign country" under IRC Section 899, subjecting Canadian entities to higher income and…

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