“大而美法案”中第“899条款”，为何可能引发美国外资危机？

Core Viewpoint - The proposed Section 899 of the "Big and Beautiful Act" aims to impose higher taxes on foreign investors in the U.S., causing significant concern and opposition from multinational corporations and financial institutions [1][2][4]. Group 1: Impact on Multinational Corporations - Approximately 70 multinational corporations, including Toyota, Shell, LVMH, and SAP, are set to discuss the implications of Section 899 with U.S. lawmakers [1]. - The International Bankers Association plans to lobby against the clause, highlighting its potential negative impact on global banking giants like HSBC and BNP Paribas [1][2]. Group 2: Taxation Details - Section 899 allows the U.S. Treasury Secretary to unilaterally determine "unfair foreign taxes" and impose punitive tax rates of up to 20% on affected foreign investors [2][4]. - The tax rate will start at an increase of 5 percentage points, rising annually by 5 percentage points, capped at 20 percentage points above the statutory rate [5]. Group 3: Economic Implications - The clause is projected to raise $116 billion over the next decade, but its revenue generation is considered limited compared to the overall debt increase of $2.4 trillion expected from the entire "Big and Beautiful Act" [5]. - The clause may deter foreign direct investment, potentially leading to market volatility and threatening job opportunities in various U.S. communities [6][7]. Group 4: Opposition from Business Associations - Business associations argue that Section 899 could severely impact the long-term growth of multinational companies operating in the U.S. [6]. - The International Financial Institute warns that the measure could have unintended negative effects on U.S. businesses and employment [7]. Group 5: Future Considerations - There is a possibility that the final version of the clause may be weakened or adjusted in its implementation, as the concept of foreign entities paying taxes in the U.S. gains traction in Congress [7].