本周，数十家跨国公司高管本周集体涌向华盛顿游说国会，试图阻止特朗普预算法案中一项可能重塑国 际资本流动格局的条款，警告这一措施将冲击数百万美国就业岗位。 6月9日，据报道，全球商业联盟主席Jonathan Samford透露，约70家公司的代表将于本周与国会议员 会面，第899条款将成为"核心议题"。 这一税收威胁已令该游说组织近200家在美外资企业感到不安， 其中包括壳牌、丰田、SAP和LVMH等巨头 。 数据显示这一担忧并非空穴来风： 外资银行在美国承销了70%以上的外国公司债务发行，占美元计价 债务发行总额的近三分之一 。 2023年，这些外资银行向美国公司放贷超过1.3万亿美元，其国际融资业务支撑了5.4万亿美元的外国直 接投资，创造了2700亿美元收入。 "希望第899条款不会被实施" 据悉， 这些外资企业在美国提供了840万个就业岗位，而第899条款的实施可能直接威胁到这一庞大的 就业基数 。 这场史无前例的游说攻势直指特朗普"大漂亮"税收法案中的第899条款——一个被外界视为"资本驱逐 令"的条文。该条款一旦获得国会批准，将允许美国对来自"税收政策惩罚性"国家的公司和投资者征收额 外税收。 税收 ...

Group 1: Core Insights - The "mysterious 899 clause" in U.S. tax law may escalate trade tensions into a capital war, imposing punitive tax burdens of up to 20% on foreign investors, particularly targeting countries like the EU that do not comply with U.S. trade demands [1][3] - Major Wall Street institutions warn that this clause could fundamentally alter the tax treatment of foreign capital in the U.S., being described as a "nuclear option" by the Trump administration [1][3] Group 2: Details of the 899 Clause - The 899 clause, officially known as "Enforcement Measures Against Unfair Foreign Taxes," is part of the recently passed "One Big Beautiful Bill Act" [2] - It aims to impose retaliatory taxes on non-U.S. individuals, companies, and governments from countries deemed to impose "unfair/discriminatory" taxes on U.S. entities [3] Group 3: Definition of "Discriminatory" Taxes - "Discriminatory" taxes include Digital Services Taxes (DST), Digital Profit Taxes (DPT), and low-tax profit rules under the OECD's global minimum tax framework [4] - The U.S. opposes the OECD framework, arguing it disproportionately affects American companies with significant global influence [4] Group 4: Tax Implications - The 899 clause could raise the statutory tax rate on U.S.-sourced income from interest, dividends, rents, and royalties by up to 20 percentage points for countries considered "discriminatory," increasing by 5 percentage points annually [5] - Investment portfolio interest may be exempt, but non-U.S. financial institutions relying on treaty-based exemptions could still be affected [6] Group 5: Revenue Projections - The 899 clause is expected to generate approximately $120 billion in tax revenue over ten years, equating to an annual increase of $12 billion, which is relatively minor compared to the overall U.S. tax landscape [7] Group 6: Impact on U.S. Deficit - The clause may influence foreign demand for U.S. assets, potentially helping to reduce the current account deficit, although rising yields could offset some revenue gains [8] Group 7: Legislative Uncertainty - There is uncertainty regarding the passage of the 899 clause in the Senate due to potential jurisdictional issues and the delegation of tax powers to the executive branch [9] Group 8: Affected Companies - Goldman Sachs has begun assessing the risk exposure of EU companies to the 899 clause, creating a "GS EU 899 Clause Basket" that includes firms with significant U.S. sales [10] - The basket consists of companies with an average U.S. sales exposure of about 48%, while excluding those with high U.S. ownership [10] Group 9: Market Performance and Valuation - Despite better earnings expectations for the GS EU 899 Clause Basket compared to the GS Domestic Quality Basket, its performance has weakened since early May, with current valuations still above historical ranges [12] - High trading congestion and negative earnings momentum for the GS EU 899 Basket suggest continued pressure on performance [14]

面对隐藏在《大漂亮法案》中的第899条税收条款，大摩警告华尔街面临史上最大"资本税"冲击。 华尔街见闻此前提及，在美国众议院此前通过的《大漂亮法案》税收与支出议案中，一条标题为"针对不公平外国税收的执法补救措施"的条款提出，对于被美 国认定存在"歧视性"税收政策的国家，将大幅提高该国企业和个人在美投资的税率。 如果参议院未能澄清适用范围，市场可能面临美债收益率曲线陡化、美元走弱及信用利差扩大的多重冲击。 万亿美元级别的税收"核弹"即将引爆 报告指出，899条款的杀伤力在于其"递增式惩罚税"设计：对被认定存在"歧视性"税收政策国家的投资者，首先提高5个百分点税率，然后每年再增加5个百分 点，最高可达20个百分点的额外税负。 并且，该条款涵盖的目标极其广泛，包括美国被动收入、房地产投资、商业利润，甚至可能波及外国央行和主权财富基金——这些此前享受免税待遇的"特权阶 层"。 尽管目前文本暗示固定收益资产可能不在范围内，但专家们仍对"金融资产"是否会被纳入"实际资产"范畴存在分歧。 报告数据显示，截至2024年12月，美国对外国实体的总负债高达39.8万亿美元，占名义GDP的134%。其中，证券持有占83%，长期证券 ...

Core Viewpoint - The introduction of Section 899 of the "Big Beautiful Act" poses a significant threat to Wall Street, potentially leading to the largest capital tax impact in history, particularly affecting foreign investors in the U.S. market [1][2]. Tax Implications - Section 899 introduces a "progressive penalty tax" for investors from countries deemed to have "discriminatory" tax policies, starting with a 5% increase in tax rates, escalating by 5% annually, with a maximum additional burden of 20% [2]. - The scope of this tax is extensive, potentially impacting passive income, real estate investments, business profits, and even foreign central banks and sovereign wealth funds that previously enjoyed tax exemptions [2]. Market Impact - The ambiguity surrounding whether financial assets will be included in the tax scope raises concerns among experts, despite current indications suggesting fixed income assets may be excluded [3]. - As of December 2024, U.S. liabilities to foreign entities are projected to reach $39.8 trillion, accounting for 134% of nominal GDP, with securities holdings comprising 83% and long-term securities at 96% [3]. Foreign Investment Dynamics - Foreign official investors hold a significantly larger share of U.S. fixed income markets compared to equities, meaning any tax policy changes could directly affect U.S. Treasury yield curves [6]. - The report indicates that foreign private investors tend to hold longer-term Treasuries, while official investors prefer shorter maturities, suggesting that rising tax costs could lead to greater selling pressure on long-term bonds [8]. Regional Effects - Europe is likely to be the biggest "victim" of these tax changes, with $3.5 trillion of the $5.39 trillion in foreign direct investment in the U.S. coming from Europe, making Eurozone countries the largest holders of U.S. fixed income and equity securities [11]. Currency and Credit Market Effects - The tax implications signal a negative outlook for the U.S. dollar, as the 4% current account deficit heavily relies on foreign capital inflows, and the new tax could deter foreign investment, leading to a weaker dollar against G10 currencies [14]. - In the corporate bond market, liquidity pressures and credit spreads may widen, with foreign investors holding about 25% of U.S. corporate debt, which could face volatility if additional tax burdens are imposed [14]. Securitized Products and Real Estate - Foreign investors show a stronger demand for agency bonds compared to securitized credit; unfavorable tax policies on non-government-backed assets could benefit GNMA mortgage-backed securities (MBS) [15]. - In commercial real estate (CRE), where foreign buyers account for 5-10% of transactions, tax changes could have a more pronounced impact on valuations compared to residential real estate [15]. Hedge Fund Risks - The definition of "applicable persons" in the tax clause could significantly affect hedge funds, as a 20% tax rate increase could eliminate arbitrage opportunities, fundamentally disrupting the business models of quantitative hedge funds reliant on U.S. markets [17]. Legislative Outlook - The likelihood of the worst-case scenario materializing from Section 899 remains uncertain, with the primary aim of the clause being to provide leverage in tax and trade negotiations [18][21]. - The Senate is seen as a potential "lifeline" to clarify the applicability of Section 899, with expectations that it may review the details, including income scope and applicable entities [22].

Core Points - The Senate is currently reviewing the "Section 899 Tax Clause" (referred to as the "Capital Tax") within a tax proposal [1] Group 1 - The Republican leader in the Senate, Mitch McConnell, is leading the review of the tax proposal [1]