关税战后是资本战？隐藏“资本税”伏笔，特朗普“大漂亮”法案引发市场强烈警惕

Core Viewpoint - The introduction of Clause 899 in the recent tax and spending bill poses a significant threat to foreign investors holding U.S. assets, potentially escalating the trade war into a capital war [1][2]. Group 1: Legislative Impact - Clause 899 aims to impose increased tax rates on investors from countries deemed to have "discriminatory" tax policies, starting with a 5% increase on passive income, escalating by 5% annually, up to a maximum of 20% [1]. - This legislation represents the most extensive unfavorable change to foreign capital tax treatment since the 1984 Deficit Reduction Act and the 1966 Foreign Investor Tax Act [2]. Group 2: Targeted Entities - The clause primarily targets countries that impose digital services taxes on large tech companies like Meta, including Canada, the UK, France, and Australia, as well as those utilizing global minimum corporate tax agreements [3]. - Affected parties include sovereign wealth funds, pension funds, government investment entities, retail investors, and companies holding U.S. assets [3]. Group 3: Market Reactions and Predictions - Analysts predict that the clause could disrupt bond markets even before it is utilized, as it is seen as a tool for the Trump administration to negotiate against digital services taxes [5]. - The clause is expected to receive broad Republican support, increasing its likelihood of being included in the final Senate reconciliation bill [5]. Group 4: Economic Consequences - If passed, Clause 899 could generate an estimated $116 billion in tax revenue over ten years, but it may also lead to a significant withdrawal of foreign investment from U.S. assets [6]. - The current market response appears calm, but U.S. assets have underperformed this year, with the S&P 500 rising only about 0.4%, compared to a 20% increase in the German benchmark index [6]. Group 5: Broader Implications - The clause's implementation could undermine the attractiveness of U.S. Treasury securities for foreign investors, further pressuring the dollar and potentially increasing long-term interest rates [7]. - The overall sentiment suggests that the U.S. may face challenges in maintaining its status as a favorable investment destination due to the adverse tax environment introduced by Clause 899 [7].