FICC日报 | 2025-06-06 中美两国元首通话，市场信心改善 市场分析 关注经济事实验证。4月国内数据好坏参半，4月出口整体略超预期，但转口支撑的特征明显，叠加中美关税缓和， 短期出口有支撑；但4月投资数据有所走弱，尤其是地产边际压力再增；4月财政收入和支出同步回升，收入主要 受到土地出让金的支撑；同时消费也略有承压。面对关税下的外需压力和内部的稳增长诉求，关注财政进一步加 码的可能。中国5月财新服务业PMI升至51.1，显示服务业扩张加速，但成本上升与销售价格下行导致企业盈利压 力加剧。5月9日—12日何立峰副总理于瑞士访问期间与美方举行会谈，中美日内瓦经贸会谈取得实质进展，双方 承诺暂停部分加征关税并建立协商机制。中美两国元首于6月5日晚进行通话，市场信心改善。7月前宏观预计更多 围绕经济事实验证展开，尤其关注关税和谈后是否出现新一轮的"抢出口"。 特朗普关税再反转。5月28日，美国国际贸易法院裁定，特朗普政府依据《国际紧急经济权力法》实施的加征关税 行政令越权，判定总统无权以贸易失衡为由对多国加征全面关税，该行政令将被撤销并禁止执行。5月30日，特朗 普表示，将把进口钢铁的关税从25%提高至5 ...

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 ...

Group 1 - The US dollar has experienced its worst year-to-date performance on record, with an 8.4% decline in the first five months of the year, marking the worst start against a basket of global currencies [1][2] - The dollar index is currently trading near its lowest level since spring 2022, indicating a significant depreciation [1][2] Group 2 - A controversial provision in the recently passed federal tax and spending bill, known as the "retribution tax," could escalate trade tensions into a capital war by imposing new taxes on foreign investments from countries with perceived unfair tax systems [3] - This provision poses a direct threat to foreign investors holding trillions of dollars in US assets, potentially leading to a mass withdrawal of foreign investments [3] Group 3 - The proposed "asset tax" could impose additional costs on investors from Europe and other regions when repatriating capital gains, dividends, or interest payments from US Treasury securities [4] - Major market participants are already reacting, with the euro appreciating by 11% this year despite a weak eurozone economy, while the Japanese yen and British pound have also seen increases of 9% and 8%, respectively [4]

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].

Group 1 - The U.S. Congress is advancing a budget proposal that includes a progressive tax of up to 20% on passive income from foreign investors, which may suppress demand for U.S. Treasury securities and the dollar [1] - The tax provision, included in Section 899 of the bill, targets entities or individuals from countries deemed to have "unfair tax practices," with an estimated revenue increase of $116 billion over the next decade if passed by the Senate [1] - The new tax could escalate the trade war into a capital war, potentially negatively impacting demand for U.S. government debt at a time when reliance on foreign investment is critical due to rising fiscal deficits [1] Group 2 - Analysts warn that the proposed tax could lead to a significant reduction in foreign investment in U.S. assets, thereby weakening the dollar [2] - European investors with passive income in the U.S. are expected to be the most affected, although specific impact estimates have not been provided [2] - The tax could have severe long-term implications for international companies operating in the U.S., affecting American workers rather than foreign bureaucrats [2] Group 3 - The legal ambiguity surrounding the potential taxation of U.S. Treasury interest has caused panic among foreign investors, with concerns that borrowing costs could rise significantly if such taxes are implemented [2] - Foreign clients are reportedly expressing concern and seeking clarification regarding the implications of the new tax provisions on U.S. debt [2]

一项埋藏在千页预算法案深处的"隐秘条款"，正悄然引发华尔街恐慌—— 这个被称为第899条的模糊税收条款，可能将贸易战升级为资本战，直接威胁外国投 资者持有的数万亿美元美国资产。 这项条款出现在上周美国众议院通过的《大漂亮法案》税收与支出议案中，其标题为"针对不公平外国税收的执法补救措施"。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。 具体而言，这项措施将对目标国家投资者在美国的被动收入（如利息和股息）征收递增式惩罚税， 首先提高5个百分点，然后每年再增加5个百分点，最高可达 法定税率基础上的20个百分点。 第899条款的风险在周三美国法院阻止特朗普对等关税后变得更加紧迫。 关税一直被视为资助特朗普减税计划的重要来源——而减税正是其《大漂亮法案》的 标志性内容。关税收入的不确定性，让政府更迫切地寻找替代资金来源。 这一策略与白宫经济顾问委员会主席Stephen Miran去年11月提出所谓海湖庄园协议高度吻合。 Miran当时呼吁对美国国债的外国投资者征收"使用费"，以削 弱美元并提高美国制造商竞争力。 如果该立法获得通过，它将有效引入自1984年《赤字削减法 ...

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].